Purpose of this Notice
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR) effective from 25 May 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Turquoise International Limited (“we”, “us”, “our” and “ours”) is a specialist corporate finance and investment management company authorised and regulated by the Financial Conduct Authority. We are registered in England and Wales as a limited company under number 04460635 and our registered office is at Turquoise, c/o Holden Granat LLP, Springfield House, 23 Oatlands Drive, Weybridge KT13 9LZ. For the purposes of data protection law, we are a data controller in respect of your personal data. We collect and use your personal data as described below. We are responsible for ensuring that we use your personal data in compliance with data protection law.
If you have any questions about this notice, about how we process personal data or about your rights over your personal data, our Data Protection Officer can be contacted via email at firstname.lastname@example.org or by post at our registered address shown above
This notice only applies to personal data we receive from you or otherwise create in connection with your subscription to our email newsletter via the www.turquoise.eu website or when you fill in the form to download an industry whitepaper. It is important that you take the time to read this notice so that you understand how we will use your personal data and your rights in relation to your personal data.
Personal data that we collect about you
We will collect and use the following information about you:
Information you give us
- We use the information about you that you provide to us, including the information that you provide when you complete the newsletter subscription form or the whitepaper download form (such as your name, company name, e-mail address, occupation, and your preferences for receiving email alerts from us) and any update to your information that you provide to us when corresponding with us by phone, e-mail or otherwise.
Information we collect or generate about you
- When you submit information to us, we may use this information to help build a better picture of the topics and materials that interest you or may interest you.
- Website Usage Information – Our website uses Google Analytics to automatically gather certain statistical information such as the number and frequency of visitors and their IP addresses. This information is used as aggregated statistical information about users, providing usage by IP address. We do not identify individual users from this type of data and it does not involve the processing of personal data about you. This information helps us to measure how individuals use the website and our services, so that we can continually improve them.
- We sometimes record telephone conversations to resolve complaints, improve our service and for training and quality assurance purposes.
- We generate data for statistical analysis.
How we use your personal data
Your personal data may be processed by us for the following purposes:
- to provide you with e-mail updates relating to the topics that you request;
- to administer and maintain your subscription account for e-mail newsletter; and
- to communicate with you in relation to the administration of your subscription account or to carry out quality control research.
Legal basis for processing your personal data
We process your personal data pursuant to the following legal bases:
- you may have consented for us to use your personal data to send you certain e-mail updates when you signed up for our e-mail newsletter;
- the use of your personal data as described is necessary for our legitimate business interests which are:
- contacting you with email updates that you have requested from us;
- conducting business development activities and marketing Turquoise International’s services; and
- keeping a record of what individuals are interested in hearing about from us.
- You may cancel your subscription to e-mail newsletter at any time by using the unsubscribe link within the email that you receive from us.
Sharing your personal data
We may disclose your personal data within Turquoise International and to third party service providers in the circumstances described below:
- to facilitate the delivery and maintenance of our e-mail alert service;
- to conduct and/or improve the business development activities of any member of Turquoise International;
- to ensure the safety and security of our data; and
- as part of our internal research and statistical analysis activity.
We will take steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this notice.
We may also share your personal data outside of Turquoise International:
- if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
- if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
- to third party agents or contractors (for example, the providers of our electronic data storage services or call centres) for the purposes of providing services to us; and
- with your consent, to third party affiliates who may wish to offer you products and services which may be of interest to you.
Sharing of date with such third parties will typically be subject to confidentiality requirements requiring them to only use data we provide them, including your personal data, purely for the purpose provided.
We may also share your personal data outside of Turquoise International to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, and to establish, exercise or defend our legal rights.
We have put in place commercially reasonable and 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 data security breach and will notify you and/or any applicable regulator of a suspected breach in line with applicable regulations.
Transfer of personal data outside the European Economic Area
We will not transfer the personal data we collect about you outside of the EEA.
How long we keep your personal data
How long we hold your personal data for will vary. The retention period will be determined by various criteria including:
- the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose (for example, to provide e-mail alerts to you for so long as you remain subscribed to them); and
- legal obligations – laws or regulation may set a minimum period for which we have to store your personal data.
You have a number of rights in relation to the personal data that we hold about you. These rights include:
- the right to object to our processing of your personal data where we process your personal data pursuant to our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we are legally entitled to refuse that request;
- the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
- the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
- in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
- the right to request that we rectify your personal data if it is inaccurate or incomplete;
- the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
- the right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request;
- the right to object to the processing of your personal data for direct marketing purposes; and
- the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns
Changes to this privacy notice
We keep this privacy notice under regular review. Any changes we make to this notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back regularly if you wish to see any updates or changes to this privacy notice.
This privacy notice was last updated on 28 July 2020..
Turquoise International is a company registered in England and Wales. Our registered address is at Turquoise, c/o Holden Granat LLP, Springfield House, 23 Oatlands Drive, Weybridge KT13 9LZ our company registration number is 4460635.
If you have any questions about this notice, our privacy notices or personal data that we may hold about you our Data Protection Officer can be contacted via email at email@example.com or by post at our registered address shown above.