Gambit Corporate Finance LLP (“We”) are committed to protecting and respecting your privacy. We will comply with all applicable requirements of the Data Protection Legislation. This policy is in addition to, and does not relieve, remove or replace, our obligations under the Data Protection Legislation.
Any reference to Data Protection Legislation in this policy means (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998.
Data Controller, Data Processor and Personal Data have the meanings as defined in the Data Protection Legislation.
For the purpose of the Data Protection Legislation, the data controller is Gambit Corporate Finance whose registered office address is at 23 Berkeley Square, London, W1J 6HE.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Jason Evans, who has been appointed the Data Privacy Manager, using the details set out below.
We may collect and process the following data about you:
- Information you give us.
You may give us information about you by corresponding with us by phone, e-mail or otherwise. This includes information you provide when subscribing to newsletters or other updates, make an enquiry or participate in social media functions on our site. The information you give us may include your name, address, e-mail address and phone number, employer and job title.
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.
Lawful Basis for Using your Personal Information
- Performance of Contract (see Glossary) – It is necessary for us to process your personal information to perform a contract to which you are a party, or to take steps at your request prior to you entering into a contract.
- Consent – You have consented to us using your personal information for this purpose (for example, when you create an account with us, agree to receive marketing emails from us or create an alert). You can withdraw your consent at any time by deleting the information from your account or updating your marketing preferences.
- Legitimate interests (see Glossary) – It is in our legitimate interests to use your personal information to operate, improve and promote our services and to protect our business.
- Comply with a legal or regulatory obligation – It is necessary for us to use your personal information for us to comply with legal or regulatory obligations placed on us.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your information: see below for further information.
In some circumstances we may anonymise your personal information (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.
Uses made of the information
Information you give to us.
- To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, services that you request from us;
- To provide you with information about other services we offer that are similar to those that you have already enquired about;
- To provide you with information about services we feel may interest you
- To notify you about changes to our service;
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing.
All information you provide to us is stored on our secure servers
We will not transfer any Personal Data outside of the European Economic Area unless the following conditions are fulfilled:
- We and the Provider have provided appropriate safeguards in relation to the transfer;
- You have enforceable rights and effective legal remedies;
- The Provider complies with its obligations under the Data Protection
- Legislation by providing an adequate level of protection to any Personal Data that is transferred; and
- The Provider complies with reasonable instructions notified to it in advance by us with respect to the processing of the Personal Data
- Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- 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 your personal data. 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. However, 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. The right to object exists 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 your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data. 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.
- Right to withdraw consent. This right exists 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 may 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 may 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.
We will ensure that we obtain all necessary appropriate consents to enable lawful processing and transfer of your Personal Data.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to websites of interest. If you follow a link to any of these websites, please note that 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.
We will ensure that we have in place appropriate technical and organisational measures, reviewed and approved by us regularly, to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures (those measures may include, where appropriate, pseudonymising and encrypting Personal Data, ensuring confidentiality, integrity, availability and resilience of our systems and services, ensuring that availability of and access to Personal Data can be restored in a timely manner after an incident, and regularly assessing and evaluating the effectiveness of the technical and organisational measures adopted by us);
We will ensure that all personnel who have access to and/or process Personal Data are obliged to keep the Personal Data confidential.
We will ensure we comply with our obligations under the Data Protection Legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators;
We will notify you without undue delay on becoming aware of a Personal Data breach;
Our full details are:
Full name of legal entity: Gambit Corporate Finance LLP
Jason Evans, Partner
Email address: email@example.com
Postal address: 23 Berkeley Square, London, W1J 6HE.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
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 information 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
Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.