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 the following information from investors and potential investors:
- 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:
- 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)
- Accepting investors (where we may use the information to comply with our legal and regulatory obligations to know our clients and prevent money laundering, terrorism financing and other financial crimes)
- Dealing with investors (where we may use the information to comply with our contractual obligations under relevant investment documentation, including reporting obligations)
- 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)
- 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 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.
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 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.
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 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 information. These are identified below. More information can be obtained from the Information Commissioner’s website at www.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.
Right to request rectification of personal information
If your personal data are inaccurate or incomplete, you can require that they are corrected.
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
STAR Capital Partnership LLP
33 Cavendish Square
London W1G 0PW
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
STAR Capital Partnership LLP/STAR Capital Partners Ltd
Last updated 24 April 2018