Privacy Policy

• Company Information
• Types of Information Collected
• Cookies
• Personal Data Disclosure
• Personal Data Storage
• Privacy Rights
• Indemnity
• Updates to Privacy Policy
• Contact Support

This policy (together with our terms of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. 

The Data Protection Act 2018 gives data subjects (living individuals in respect of whom personal data is processed) enhanced rights and protections in relation to their personal data.  We are committed to safeguarding the privacy of the users of our services and any other person whose personal data we handle.  Therefore, we have updated our Privacy Policy so we are completely clear as to what personal data we collect, why we collect that personal data and how we handle it.  We, SFO of 14 Berkeley Street, Mayfair, London W1J 8DX are the Data Controller (as that term is defined in data protection legislation) of the personal data identified in this Privacy Policy.

Please read the privacy policy carefully. By visiting our website (www.sfocapitalpartners.com) you are accepting and consenting to the practices described in this policy.

company information

types of information collected

We may process the following data about you:

Information you give us.

How and why we process your personal data:	How and why we process your personal data:
Client information: Information about you which relates to your, or your employer’s account with us. This information will include your name, your address(es), your email address and your telephone and/or mobile number. Where you are a client instructing us on behalf of your family, we will retain information which relates to your family and staff, including the names of your family members, their date of birth, and where they are adults, their contact details such as their email address, telephone number, mobile number and address(es). We will also retain any other personal information, which we need in order to provide our services to you.	We will process this data to maintain your account with us, to provide our services to you, to communicate with you and to back up our database.  The reason we process this data is to fulfil the contract we have with you to provide services to you.  We will also seek your consent (which you will give to us on your behalf and on behalf of any dependents who will benefit from our services) when we collect personal information from you. Finally, we also need to process this personal information to ensure the proper administration of your account and our business (our legitimate interest).
Investor Information: Where you are an investor client who uses our investor portal, we will process information about you, which relates to your account with us, including personal data relating to you and (where applicable) any of your employees who have access to our investor portal.  This information will include the names, email addresses and telephone and/or mobile numbers of you and those individuals.  We will also process data relating to your investment(s).	We will process this personal data to maintain your account with us, to provide our services to you, to communicate with you and to back up our database.  The reason we process this data is to fulfil the contract we have with you.  We will also seek your consent to process such personal data when we collect personal information from you. Finally, we also need to process this personal information to ensure the proper administration of your account and our business (our legitimate interest).
Communication Information: Information you provide when you contact us to find out more about our services, make an employment enquiry with us, or if you report a problem with our website. The information you give us may include your name, address, e-mail address and phone number.	We will process this data so we can deal with your enquiry and/or communication.  The reason we process this data is to ensure the proper administration of your registration and our business (our legitimate interest).
Notification Data: Where you have been the recipient of our services, or where you subscribe to receive emails and/or newsletters providing information about and promoting our services, we will process your data so that we can send such emails and/or newsletters to you.  If you prefer not to receive such communications, you can notify us at [email protected].	The legal basis for us processing this data is that you have consented to such processing.
Regulatory Data: We may process your data if we need to do so in order to comply with our legal and/or regulatory obligations, so that we can protect and ensure the safety of you or another natural person.	The reason we will process such data is to protect the vital interests of you or another natural person.

Information we collect about you

With regard to each of your visits to our website we do not collect any information from visitors, whether technical information or any other information about your visit.

Information we receive from other sources

This is information we receive about you if you use any of the other websites we operate or access other services we provide. We operate as a group of companies which provide complimentary services to our clients in various jurisdictions.  Accordingly, we will share your personal information between our group of companies so that you can receive the best service possible from us. We have mechanisms in place to allow for such data to be shared to ensure your personal data is protected and kept secure at all times.

We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, credit reference agencies). We may receive personal data about you from these organisations. Those organisations will have their own privacy policies detailing how they process personal data.  

Cookies

Our website uses necessary cookies which are basic cookies that ensure the internet-facing application works properly. We do not use preferences cookies which are personal cookies that save preferences such as the language you choose to use, or any other type of cookies that tracks your activity on our website.

personal data disclosure

We will share your personal information with members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. These terms are defined in section 1159 of the UK Companies Act 2006. We will only share such personal information where this is necessary for the purposes set out in this policy.

We may need to share your personal information with certain selected third parties including:

– Our business partners, suppliers and sub-contractors for the purpose of performing any contract we have with you or them. In particular, we use third party companies to process your personal data in order to enhance your experience on our investor portal;

– Screening and due diligence databases such as World Check which help to assess and manage financial, regulatory and reputational risks by identifying Politically Exposed Persons and heightened risk individuals and organisations.

We will also disclose your personal information to third parties in the following circumstances:

– If we sell or buy any business or assets, in which case we may need to disclose certain personal data to the prospective seller or buyer of such business or assets.

– If all or most of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.

– If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any legal agreement we have with you; or to protect our rights or property, or the safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

personal data storage

It is necessary for us to transfer your personal data outside the European Economic Area, as we are part of a group of companies which is based in various jurisdictions. Accordingly, where it is necessary for us to transfer your personal data outside the European Economic Area, we have mechanisms in place to ensure your personal data is properly protected. This includes robust security mechanisms to ensure your personal data is protected and contractual provisions, based on the standard contractual clauses approved by the European Commission for the transfer of data outside the EEA or such other appropriate standards as are required from time to time by the European Commission or the UK Government. You consent to the transfer of your personal data outside of the EEA, as long as we comply with these requirements. 

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, and we will maintain appropriate technical and organisation measures to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 

Storage and deletion of personal data

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it which will include satisfying any legal, accounting, or reporting requirements. Any personal data that we process will be deleted from our systems once we have completed the purpose for which we were processing the personal data. In some cases, the purpose for which we are processing your personal data will last for a considerable period (for example, if you are a long-term customer of ours, we will need to store your data until our relationship with you comes to an end).

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will take into consideration a number of factors such as your relationship with us, your engagement with us, and the fulfilment of contracts we have with you. 

We may need to retain your personal data where this is necessary to comply with our legal or regulatory obligations, or to protect the vital interest or the vital interests of another natural person.     

Data security

We have appropriate security measures in place to prevent personal information from being accidentally lost or from being used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

privacy rights

Under data protection laws you have the following fundamental rights:

– The right to access the personal data we hold about you;

– The right to have your personal data corrected if there are errors or inaccuracies in it, or your personal data is incomplete;

– The right to restrict the processing we carry out in relation to your personal data;

– The right to object to the processing we carry out in relation to your personal data;

– The right to have the personal data we hold about you provided to you in a useable format;

– The right to complain to a supervisory authority (in the UK this is the Information Commissioner’s Office) about how and/or why we are processing your personal data;

– The right to tell us you no longer consent to us processing your personal data. In practice, you will usually agree in advance to us using your personal data for marketing purposes and if you no longer wish us to use your personal data for marketing purposes, you can opt out of receiving such marketing messages at any time. You can do this either by unsubscribing from the marketing messages we send you or by notifying us in writing at [email protected]

– You can ask us to provide you with details of any personal data we hold about you. You do not have to pay us a fee to access your personal data unless we believe your access request is unfounded, repetitive or excessive.  In this case we may charge you a reasonable fee to access your personal data or we may decide not to comply with your request.  We will notify you if this is the case. We will require you to provide appropriate evidence of your identity before we respond to your request. Typically, this identification evidence will be a photocopy of your passport or photo driving licence, which a solicitor or bank has certified as being a true copy of the original and a copy of a recent utility bill detailing your current address.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Certain statements on our website are forward-looking statements with respect to projected financial performance and potential investment returns. All such projections are estimates only and are not guarantees of future performance or investment returns. They are subject to known and unknown risks, and uncertainties that may cause actual results to differ materially from the projections of future performance. Although such projections are based upon what are believed to be reasonable assumptions, there can be no assurance that they will prove to be accurate, as actual results and future events may differ materially from those anticipated. Given the risks and uncertainties, clients are cautioned not to place undue reliance on forward-looking statements. Past performance is not indicative of future results, and no representation is being made that any investment or transaction will or is likely to achieve profits or losses similar to those achieved in the past.

If you think that any of the data we hold about you is incorrect or inaccurate, you can contact us to correct such data. Please contact us at [email protected] for these purposes.

indemnity

As a condition of use of this website, the client agrees to indemnify and hold harmless SFO and its affiliates, and the partners and employees of SFO and its affiliates from and against any and all liabilities, claims damages, losses or expenses, including legal fees and expenses, arising out of the client’s access to or use of this website, save to the extent that SFO may not exclude or limit its own liability for such losses pursuant to applicable laws or regulations. We reserve the right to assume the exclusive defence and control of any matter for which a client is required to indemnify us, and the client agrees to cooperate with our defence of these claims.

updates to privacy policy

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

contact support

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to: