Privacy Policy

Privacy Policy

This is the Privacy Policy of STAR Capital. Our business is the provision of investment management services to professional investors. In the course of our interaction with investors, prospective investors and other business contacts, we hold and process personal information. STAR Capital respects the privacy of every individual whose personal information that it holds. We set out below important information about our processing of data relating to individuals by reference to the purposes for which we do so in the context of our business.

For the purposes of this Privacy Policy "STAR Capital" (and "we" and "us") shall mean STAR Capital Partnership LLP, STAR Capital Partners Limited and their related affiliates and its or their partners, members, directors, officers and employees, as the context requires. This Privacy Policy does not apply to any website to which this website (www.star-capital.com) may link.

The "data controllers" (as defined in the Data Protection Legislation) in respect of your personal information will be Star Capital Partnership LLP with company registration number OC402487.

Information we collect

In order that we can provide our investors and prospective investors with the services that meet their requirements and to comply with the legal and regulatory requirements applicable to us, we may (to the extent relevant and appropriate) collect and hold information from investors and potential investors via telephone in writing, including email or otherwise.

What sort of Personal Data do we collect?

• Professional contact details (including name, email address, phone number, facsimile numbers and mailing address)
• Identification documentation (including photographic ID, date of birth and mailing address)
• Financial details (including source of wealth, bank details and tax status)
• Associated third party information (e.g. financial intermediary and beneficiaries of trusts)

If representatives of other businesses (including banks, corporate finance advisers, tax and accountancy practices, legal advisers, insurance providers) or individuals (including management candidates) choose to contact us and provide their professional contact details to us, we will collect and store this information in a way that allows us to relate it to them personally, including but not limited to their names, e-mail addresses, phone numbers, facsimile numbers and mailing addresses.

How and why we use this information

The purposes for which we use the information are as follows, but depend upon individual circumstances:

1. Marketing to prospective investors (where we may use the information provided to us to communicate directly via email and/or to provide information relating to our business, events and the performance of the investments we manage)
2. Accepting investors (where we may use and share the information with third parties to comply with our legal and regulatory obligations to know our clients and prevent money laundering, terrorism financing and other financial crimes)
3. Dealing with investors (where we may use the information to comply with our contractual obligations under relevant investment documentation, including fund documents and reporting obligations)
4. Performing our services (where it is in the legitimate interests of our business to process personal information relating to other business contacts in order to provide investment management services to our investors – and may also be in the interests of the third party)
5. Operating our business (where we process personal data using a client relationship management system, local and wide area network and an internal/corporate system)

STAR Capital’s partners and employees use computer and communications equipment to access these systems, in order to perform their duties, and in particular work stations, laptop computers, other mobile computing devices and mobile phones. Personal data is stored on these devices appropriate to the use at the relevant time.

Who we share the information with

The legal basis on which we deal with people who are not investors or prospective investors, nor associated with an investor or prospective investor, depends on the circumstances. In all cases we make sure that we have a legitimate reason to do so in connection with running and promoting our business.

We communicate and deal with a variety of persons from time to time in the ordinary course of our business, whether with vendors or acquirers of businesses or assets, advisers, managers of portfolio companies, suppliers, regulators or other competent authorities. In the course of doing so, having regard to the nature and purpose of those dealings, we will obtain and process personal data. We do not use the data for any purpose other than that for which it was given to us for no longer than necessary.

We may share information with certain third party organisations who perform certain tasks on our behalf. Information is only shared with these third parties to the extent necessary in order to enable them to provide the services required on our behalf. These third parties act on our instructions and are processors of the information. These organisations may:

• provide IT or depositary/custody services to us;
• provide credit reference services;
• provide background checks;
• provide AML and Sanctions screening services;
• provide cloud hosting solutions;
• other subsidiaries of STAR Capital and affiliated entities;
• provide professional advice (such as accountancy, tax, legal and compliance advice); and
• have a direct contractual relationship with the individual (e.g. as an administrator, custodian, investment adviser or appointed agent). In these circumstances, the third party may also be a controller of the information for their own purposes. In these circumstances, we will seek to ensure that we have in place strong data sharing protocols with these third parties to govern and guide the sharing of information.

If you are involved in a transaction that STAR Capital and/or the funds that it manages or advises enters into, or a potential transaction that STAR considers, we may store personal information relating to you. This might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out.

We collect and store this information for the purposes of:

• assessing potential transactions;
• maintaining records of investments;
• administering any transaction that we enter into;
• assessing your suitability for involvement in a transaction, including by verifying your identity;
• complying with our regulatory and legal obligations, including assessing and managing risk;
• safeguarding our legal rights and interests;
• seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
• providing periodic business updates.

The personal information we hold about actual or potential management teams may be shared with:

• companies who process personal information on STAR Capital’s behalf, such as providers of cloud hosting solutions and other third-party outsourced services providers;
• credit reference agencies;
• financial intermediaries;
• professional advisors, such as accountants, lawyers or other consultants;
• other persons who have an interest or involvement in, or who are considering an interest or involvement in, a STAR Capital transaction, including co-investors, other providers of finance and investors in STAR Capital’s funds; and
• other subsidiaries or companies within the STAR Capital group and affiliated entities.

In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running our business, in particular by considering potential investments, and administering transactions that we enter into. If we enter into a transaction that you are involved in, it will also be necessary for us to process your personal information for the purpose of performing that contract and to comply with our regulatory and legal obligations.

Cookies

We use small files which are stored on your hard drive by your browser (“cookies”) to monitor your use of this website during the time you access it. We do not collect personal data about you nor are these cookies used to create behavioural profiles of users or for advertising purposes.

This site uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a number of cookies in order to evaluate your use of the site and compile reports for us on activity on the site.

if you wish to restrict or block the cookies which are set by our website, you can do this through your internet browser settings. Please visit www.allaboutcookies.org if you require instructions to do this.

How we protect information

Protecting the security and confidentiality of personal information is important to us.

All personal data which is collected and recorded, whether on paper or electronically, has appropriate safeguards in line with our legal obligations.

Our internal data protection policies and procedures are designed to minimise loss or damage. Our partners and employees undertake regular training in relation to data protection and are subject to duties of confidentiality in respect of the personal data we obtain and process.

Our information security controls are regularly reviewed to ensure they are aligned to industry standards and good practice. This provides a secure control environment that effectively manages risks to the confidentiality, integrity and availability of information. Additionally, our controls ensure we can restore data in situations where the data is corrupted or lost in a disaster recovery situation.

Where appropriate, we use encryption or other additional access restrictions or security measures to protect information. We also review our security procedures periodically to consider appropriate new technology and updated methods. But, despite our reasonable efforts, no security measure can ever be perfect or impenetrable.

Where the information is processed

Personal information is processed in the UK and European Economic Area (EEA). If and to the extent that personal information is being processed outside of the EEA, we will take additional steps to ensure that it is protected to at least an equivalent level as required by applicable data protection laws.

How long we keep the information

We have a legitimate interest to keep all records relating to our business for our internal purposes and to deal with queries or complaints which may arise.

As a regulated business we also need to keep records for 5 years from the date of the last contact with you or longer if required.

We keep personal data of investors only where and for so long as it is necessary to provide our services and afterwards for so long as necessary to meet our legal or regulatory obligations or, if longer, in relation to claims which could be made against us.

Your rights

You have several rights under data protection law in relation to how STAR Capital processes your Personal information and may be entitled to access your personal data, request it is erased, restrict processing or request that any inaccurate personal data is rectified. Your rights are identified below. More information can be obtained from the Information Commissioner’s website at ico.org.uk.

• Right to be informed

  You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with. We do so by means of this Privacy Policy.

• Right of access

  You have the right to know what personal data we process and to be provided with access to the information. If you wish to receive a copy of the personal information, we hold on you, you may make a subject access request by writing to ejudd@star-capital.com.

• Right to request rectification of personal information

  STAR Capital will take all reasonable steps to keep your personal information accurate and, where necessary, up to date. If you believe your personal data are inaccurate or incomplete, you can require that they are corrected by writing to ejudd@star-capital.com.

• Right to request erasure

  You can ask for your information to be deleted or removed if there is not a compelling reason for STAR Capital to retain it.

• Right to restrict processing

  You can ask to block or suppress the processing of your personal data for certain reasons. This means that we are still permitted to keep your information but only to ensure we don’t use it in the future for those reasons you have restricted.

• Right to data portability

  You can ask for a copy of your personal data for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way; for example, if you were moving your pension to another pension provider.

• Right to object or withdraw consent

  You can object to STAR Capital processing your personal data where it is based on our legitimate interests, in which case we can no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

  You can object at any time to our use of personal data relating to you in connection with our direct marketing with a view attracting you as an investor. Where you do so, the personal data shall not afterwards be processed for such purposes.

  Where we are processing personal data about you with your consent you can withdraw it at any time. However, where you do it may not be possible for us to continue to fulfil your instructions adequately or at all.

Contact Information and Complaints

You can opt out of receiving communications from us at any time by sending an e-mail to ejudd@star-capital.com or by contacting our Legal & Compliance Team at the address listed below.

If you have any questions about this Privacy Policy or the personal data we will obtain and process about you, please contact:

STAR Capital Partnership LLP
15th Floor
33 Cavendish Square
London
W1G 0PW
FAO: Compliance Officer

If you do not believe we have handled your information as set out in our Privacy Policy, or you otherwise wish to complain about our handling of personal data relating to you, please contact our Compliance Officer at the above e-mail address or by post.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Telephone: 0303 123 1113
Fax: 01625 524510

Changes to Privacy Policy

STAR Capital may amend this Policy at any time, when we make any changes we’ll post the updated privacy policy on our website so that you’re always aware of what personal information we collect, how we use it and under what circumstances we disclose it. If you do not agree to any changes that we make you should not access the website or continue to access the website.

STAR Capital Partnership LLP/STAR Capital Partners Ltd

Last updated 14 August 2020