This document (“Privacy Notice”) refers to “Personal Data”: this is defined as information concerning any living person (a natural person who hereafter will be called the “Data Subject”) that is not already in the public domain.
The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulation (GDPR) which is EU-wide and far more extensive, seek to protect and enhance the rights of Data Subjects. These rights cover the safeguarding of Personal Data, protection against the unlawful processing of Personal Data and the unrestricted movement of Personal Data within the EU.
CleanTech Capital Advisors (“CCA”) is pleased to provide the following information in relation to its GDPR policy:
Who we are?
CCA is an international corporate finance advisory boutique providing services to B2B companies and investors in the cleantech and resource efficiency sector.
CCA uses the information collected from Data Subjects to provide business proposals, make telephone contact and to email them marketing and PR information which the CCA believes may be of interest to them and their business. In making initial contact with us, the Data Subject consents to CCA maintaining a marketing dialogue with them until they either opt out (which they can do at any stage) or CCA decide to desist in promoting our services. CCA also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, CCA will be acting on the instruction of its client, and will work hard to ensure that the client is also fully GDPR-compliant.
Some Personal Data may be collected about the Data Subject from records of our meetings, correspondence and phone calls as well as details of visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. CCA may from time-to-time use such information to identify its visitors. CCA may also collect statistics about the behaviour of visitors to its website.
Any information CCA holds about a Data Subject and their business encompasses all the details we hold about them, including any third-party information we have obtained about them from public sources and our own information providers. CCA will only collect the information needed so that it can provide the Data Subject with corporate finance advisory services; the firm neither sells nor brokers their data, although coincidentally there may be times when their information could be contained in data that CCA has purchased from a third-party list broker, on behalf of a client.
Legal basis for processing any Personal Data
To meet CCA contractual obligations to clients and to also respond to marketing enquiries.
Legitimate interests pursued by CCA and/or its clients
To promote the corporate finance advisory services offered by CCA and/or provide information in relation to CCA’s existing clients.
Through agreeing to this Privacy Notice the Data Subject is consenting to CCA processing their Personal Data for the purposes outlined. The Data Subject can withdraw consent at any time by emailing firstname.lastname@example.org or by writing to us; see the last section for full contact details.
CCA may on occasion pass the Data Subject’s Personal Data to third parties exclusively to process work on its behalf. CCA requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. CCA neither broker nor pass on information gained from the Data Subject’s engagement with the firm without their consent. However, CCA may disclose the Data Subject’s Personal Data to meet legal obligations, regulations or valid governmental request. The firm may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of CCA, its clients and/or the wider community.
CCA will process Personal Data during the duration of any contract and will continue to store only the Personal Data needed for six years after the contract has expired to meet any legal obligations. After six years any Personal Data not needed will be deleted.
Data is held directly in the United Kingdom. Some data is also backed up securely via third-party cloud providers, including Microsoft Corporation, DropBox and Box.com, and is subject to those companies’ own GDPR policies.
Your rights as a data subject
At any point whilst CCA is in possession of or processing your Personal Data, all Data Subjects have the following rights:
- Right of access: the right to request a copy of the information that we hold about you;
- Right of rectification: the right to correct data that we hold about you that is inaccurate or incomplete;
- Right to be forgotten: in certain circumstances the Data Subject can ask for the data we hold about them to be erased from our records;
- Right to restriction of processing: where certain conditions apply the Data Subject has a right to restrict the processing;
- Right of portability: the right to have the data we hold about the Data Subject transferred to another organisation;
- Right to object: the right to object to certain types of processing such as direct marketing;
- Right to object to automated processing, including profiling: the right not to be subject to the legal effects of automated processing or profiling.
In the event that CCA refuses a Data Subject’s request under rights of access, we will provide them with a reason as to why, which they have the right to legally challenge.
CCA at the Data Subject’s request can confirm what information it holds about them and how it is processed.
The Data Subject can request the following information:
- – Identity and the contact details of the person or organisation (CCA) that has determined how and why to process their data;
- Contact details of the data protection officer, where applicable;
- The purpose of the processing as well as the legal basis for processing;
- If the processing is based on the legitimate interests of CCA or a third party such as one of its clients, information about those interests;
- The categories of Personal Data collected, stored and processed;
- Recipient(s) or categories of recipients that the data is/will be disclosed to;
- How long the data will be stored;
- Details of the Data Subject’s rights to correct, erase, restrict or object to such processing;
- Information about the Data Subject’s right to withdraw consent at any time;
- How to lodge a complaint with the supervisory authority (Information Commissioner’s Office, ICO);
- Whether the provision of the Data Subject ‘s Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the Data Subject is obliged to provide the Personal Data and the possible consequences of failing to provide such data;
- The source of Personal Data if it wasn’t collected directly from the Data Subject;
- Any details and information of automated decision-making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what Personal Data is held, identification will be required
CCA will accept the following forms of ID when information on the Data Subject’s Personal Data is requested: a copy of their driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If CCA is dissatisfied with the quality, further information may be sought before Personal Data can be released.
All requests should be made to email@example.com or by phoning +44 (0) 7852 211 278 or writing to us at the address further below.
In the event that a Data Subject wishes to make a complaint about how their Personal Data is being processed by CCA or its partners, they have the right to complain to Cleantech Capital Advisor’s Managing Partner. If they do not get a response within 30 days the Data Subject can complain to the ICO.
The details for each of these contacts are:
CleanTech Capital Advisors
attention of the Managing Partner Ben Lynch
15 Old Bailey
London EC4M 7EF
Telephone +44 (0) 7852 211 278 or email firstname.lastname@example.org
ICO Wycliffe House,
Water Lane, Wilmslow, SK9 5AF
Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/