Unlock Capital Advisory Partners – Privacy Policy
Welcome to the Privacy Policy of Unlock Capital Advisory Partners (we, us or similar). We respect your privacy and are committed to protecting your personal data. This privacy policy (which we will refer to as the policy) will inform you as to how we look after your personal data when you use our website (however you access it) or communicate with us, and will tell you about your privacy rights and how the law protects you.
This policy should be read alongside the Unlock Capital Advisory Partners Terms of Business, which explain how we provide our services, and the arrangements and relationships between you, us and the third party providers of foreign exchange and international payment transactions which we may make you aware of from time to time (third-party providers).
1. Important information and who we are
Purpose of this privacy policy
This policy aims to give you information on how we collect and process your personal data through your use of our website, including any data you may provide when you set up an account, provide information about your requirements or communicate with us in respect of our services.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy supplements other notices and privacy policies and is not intended to override them.
Controller
Unlock Capital Advisory Partners Limited, a limited company registered in England and Wales under company number 15098330, is the controller of personal data collected in connection with our website and services, and references in this policy to we or us refer to this company.
If you have any questions about this policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this policy or our privacy practices, please contact us by email at: giles@unlockcapitalap.com.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in February 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data which has been processed in such a way that it cannot be linked to any individual (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you (and about other individuals whose personal data you provide to us) which we have grouped together as follows:
• Identity Data includes billing address, delivery address, email address and telephone numbers.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes your bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services) or able to facilitate your contracts with other users of our website.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
• create an account on our website;
• ask us to list a request;
• make a proposal to fulfil a request;
• request marketing to be sent to you;
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Technical Data from analytics providers (such as Google).
• Transaction Data from the third-party providers of foreign exchange and international transfer services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as the Electoral Register.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to use your personal data to perform the contract we are about to enter into or have entered into with you, or to facilitate arrangements between requesters and travellers using our website.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (see below for more information on what is meant by the term legitimate interests).
· Where we need to use your personal data to comply with a legal obligation that we are subject to.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
1) Purpose/Activity
To register you as a new user of our website
Type of data
(a) Identity
(b) Contact
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
2) Purpose/Activity
To allow us to communicate with third-party providers in respect of your requirements, communicate the relevant offers made to you by third-party providers, and coordinate arrangements (including commission-related arrangements) in connection with such introductions
Type of data
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to calculate payments due to us)
3) Purpose/Activity
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
4) Purpose/Activity
To enable you to partake in promotions we may organise from time to time or complete a survey
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
5) Purpose/Activity
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
6) Purpose/Activity
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Lawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
7) Purpose/Activity
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data
(a) Technical
(b) Usage
Lawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
8) Purpose/Activity
To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. For that reason we have established the personal data control mechanisms described below.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or have used our services and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table titled Purposes for which we will use your personal data above.
• Other users of our website, to the extent required for the posting and fulfilment of requests, and for the provision of feedback and user reviews.
• Our third-party providers of forging exchange and international transfer services – as described in the Unlock Capital Advisory Services Terms of Business.
• Third parties providing IT, hosting and administration services to us (acting as processors of your personal data strictly on the basis of our instructions) – as at the date of the latest update to this policy, these include our database system called “Notion”, which operates in accordance with the Privacy Policy published at https://www.notion.so/security.
• Our professional advisers (acting as processors or independent controllers) including lawyers, bankers, auditors and insurers who provide services to us.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
The nature of our website necessitates the international transfer of personal data relating to our users.
We are a UK business, and whenever we transfer your personal data internationally, we ensure a similar degree of protection is afforded to it as would be afforded in the UK.
This requirement is satisfied in respect of transfers to some countries automatically, since they have been deemed to provide an adequate level of protection for personal data by the ICO. Where we share personal data with third parties based in countries that have not been deemed to provide an adequate level of protection for personal data by the ICO, we may use specific contracts approved by the ICO which give personal data transferred subject to such contracts the same protection it has in the UK.
We implement confidentiality agreements with the third-party providers, and require our third-party providers to comply with relevant data protection requirements.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data internationally.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, data protection laws give you the right to:
• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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