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.
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.
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.
The purposes for which we use the information are as follows, but depend upon individual circumstances:
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.
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:
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:
The personal information we hold about actual or potential management teams may be shared with:
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.
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.
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.
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.
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.
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
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 email@example.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 firstname.lastname@example.org.
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.
You can opt out of receiving communications from us at any time by sending an e-mail to email@example.com or by contacting our Legal & Compliance Team at the address listed below.
STAR Capital Partnership LLP
33 Cavendish Square
FAO: Compliance Officer
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
Cheshire SK9 5AF
Telephone: 0303 123 1113
Fax: 01625 524510
STAR Capital Partnership LLP/STAR Capital Partners Ltd
Last updated 14 August 2020
15th Floor, 33 Cavendish Square
London W1G 0PW
Tel: +44 (0)20 7016 8500
Important Notice: we have become aware that an organisation with a similar name has been targeting individuals in the UK through unsolicited calls to make cryptocurrency investments. Our firm, STAR Capital Partnership LLP, does not engage in this type of activity. Please see here for information on how to protect yourself from financial fraud and, if you have fallen victim to it, please report it to the UK Financial Conduct Authority by telephone or email: https://www.fca.org.uk/consumers/protect-yourself-scams.