1 About this notice
This notice (the “Privacy Notice”) provides information about how and why AlbR Capital Limited (“we”, “us”, “our”, “AlbR”) requests, processes, and retains your personal data.
AlbR is required to comply with the legal requirements as set out in the Data Protection Act 2018 and are regulated by the Information Commissioner’s Office (ICO) under registration number ZA399079. The ICO provide guidance to firm’s on how to comply with the Act’s requirements.
AlbR Capital Limited (registered number 05879560), having its registered office at 80 Cheapside, London, EC2V 6EE, is the ‘controller’ of your personal data for the purposes of the Data Protection Act 2018. This means we are responsible for determining the purpose for which your personal data is used. Our staff and third-party service providers are ‘processors’ of your personal data. Should you have any questions or concerns about this Privacy Notice or the processing of personal data we hold about you, please contact us at privacy@albr.com.
2 Our commitment
We are committed to respecting the confidentiality of the personal data you supply to us. Your personal data will be held securely and all data provided will be processed in accordance with this Privacy Notice and Data Protection Act 2018. We will never sell your personal data and will provide you with options to manage your marketing choices.
3 What is Personal Data
The terms ‘personal information’ or ‘personal data’ are interchangeable and means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, telephone number, email, ID, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
4 Lawful Basis
AlbR may only process your personal data with a valid ‘Lawful Basis’. There are six lawful bases for processing which are consent, contract, legal obligation, vital interests, public task, and legitimate interests.
AlbR will process your personal data using the lawful bases of consent, contract, legal obligation, and legitimate interests. AlbR will process and retain your personal data for specific ‘purposes’ which are aligned to the lawful bases, which are as follows.
| Purpose | Activity | Lawful Basis |
| To become a client | To fulfil legal and regulatory requirements relating to financial crime such as fraud and money laundering prevention both initial and on an ongoing basis. | Legal obligation and legitimate interest |
| To provide you with services | To provide you with corporate advice and broking services. | Contract |
| To provide corporate finance contacts with information about our clients | To provide you with information relating to corporate actions such as placings. | Contract |
| To improve our website | To tailor our website with information which is appropriate and relevant for clients and prospective clients. | Contract |
| To administer legal rights | To tailor our website with information which is appropriate and relevant for clients and prospective clients. | Legitimate interest |
5 Personal data we collect
The data we collect will depend on our relationship with you, but in general the personal data we will require includes but not limited to the following and we collect your information either in writing, in person, via our website, by telephone, at events or through third party service providers
- Personal Information such as name, date of birth, photographs, identification numbers
- Contact information such as email addresses, telephone numbers, postal addresses.
- Financial Information such as bank account details.
6 Who we share information with
So that we may provide you with corporate advisory and broking services we will share your personal data with third parties such as:
- Regulatory and Law enforcement bodies
- Regulatory reporting obligations under MIFID II
- Any applicable tax authorities
- Information technology firms in respect of storage for instance
- Exchanges and markets such as LSE, AIM or Aquis
- Prospective buyers and sellers
- Custodians as applicable
- Third party service providers such as screening agencies
7 Personal data security
We have put in place appropriate physical and technical measures to safeguard the personal data we collect in connection with our services. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to receive and process your data. They will only process personal data on our instructions and are subject to a duty of confidentiality.
We maintain security and incident response plans in the event of a physical or technical incident to handle this in a timely manner and limit any negative effect of such an incident. However, please note that although we take appropriate steps to protect personal data no device, computer system, transmission of data or wireless connection is completely secure and therefore we cannot guarantee the absolute security of your personal data.
8 Your rights
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights in respect of your data.
If you do not agree with our use of your personal data as set out in this Privacy Notice, you should not submit your personal data to us. However, if you do not wish to submit your personal data, or if you wish to exercise your rights to prevent us using your data, you should be aware that we may not be able to do business with you.
Under the Data Protection laws, you have rights including:
| Your right of access | Your right to data portability |
| Your right to rectification | You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. |
| Your right to erasure | You have the right to ask us to erase your personal information in certain circumstances. |
| Your right to restriction of processing | You have the right to ask us to restrict the processing of your personal information in certain circumstances |
| Your right to object to processing | You have the right to object to the processing of your personal information in certain circumstances. |
| Your right to data portability | You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. |
You are not required to pay any fee for exercising your rights. If you make a request, we respond to you within 28 days. If your request is complex, we may take up to 3 calendar months to respond but in any event will keep you updated as to manage your expectations.
9 Retaining personal data
We will only retain your personal data for as long as necessary but are also required to retain personal data for specific time periods to fulfil regulatory obligations and will use the legal and legitimate lawful bases to retain personal data appropriately.
Your personal data will be retained on third party servers within the United Kingdom. However, there may be circumstances where your data will be retained in other jurisdictions due to reasons such as business continuity and disaster recovery.
10 Cookies
Our website uses cookies and other methods to track your activity when visiting our website. This assists us in gaining a greater understanding of the way in which our website is used so that we may provide you with a better experience. No information which personally identifies you (other than as provided by you, such as in signing up for our mailing list) will be collected by us through our website. Our website is hosted by an external provider, and we also use Google’s analytics service, each have their own privacy policy. You may seek further information at www.allaboutcookies.org. Our Cookie Policy can be found on our website.
11 Transferring personal data
AlbR will not routinely transfer your data to jurisdictions which do not have the same level of protections as the United Kingdom. Should we need to transfer your personal data outside of the above then we will ensure that the relevant jurisdiction has been assessed as having adequate and equivalent protections in place to ensure the transfer and retention is secure.
12 Changes to our privacy notice
From time to time, we may amend our privacy notice of which the latest version will be available on our website. We will notify you and gain consent should we process your personal data for different purposes.
13 Data privacy queries or complaints
If you have any questions or concerns about our use of your personal data, please contact AlbR’s Data Protection Officer. You may withdraw your consent for us to process your personal data any time.
Data Protection Officer
AlbR Capital Limited
80 Cheapside
London
EC2V 6EE
Email: privacy@albrcapital.com
You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data. The ICO’s contact details follow.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: http://www.ico.org.uk