SuperScalers Privacy Policy

Effective date: September 4, 2024

 

Data privacy is important to SuperScalers Limited and maintaining your trust is our priority. This Privacy Policy explains how we collect, store, use and share personal data that we obtain through this website or from third party sources and when we are in contact with you by other means, such as on social media, by email or in person.

TOPICS:

This Privacy Policy is divided into the following sections:

•  About this Privacy Policy
•  About SuperScalers Limited Limited
•  Contacting us
•  Personal data we collect
•  How we use your personal data
•  Who we share your personal data with
•  International transfers
•  Security of your personal data
•  How long we keep your personal data
•  Your rights
•  Links
•  Complaints
•  Changes to this Privacy Policy 

ABOUT THIS PRIVACY POLICY

This Privacy Policy applies when you use our website https://www.finnCap.com (and any mobile site or applications that link to this Privacy Policy) (collectively, the “Sites”), and where we interact with you in other ways for business purposes.

This Privacy Policy does not apply to personal data you might provide to us, or we might collect, in the context of our providing corporate finance services. Where we are engaged to provide such services, our Client Data Protection Policy will apply (see below).

CONTACTING US

If you have any questions about this Privacy Policy or your personal data, or to exercise any of your rights as described in this Privacy Policy or under data protection laws, you can contact us:

[email protected]

PERSONAL DATA WE COLLECT

Personal data you provide us

You may provide us with personal data when you are introduced to us, when we meet you in person, or when we are in contact by phone, email, via the Sites and when you register on the Sites or otherwise.

The categories of personal data you may provide includes:

•  first and last name;
•  job title and company name;
•  email address;
•  phone number;
•  postal address;
•  demographic information;
•  any information, feedback or other matters you give to us by phone, email, post or via social media;
•  password to register and use restricted parts of the Sites.

Personal data we collect from third parties

We collect most of this personal data from you directly. We also work in conjunction with third parties (including, for example, business partners, professional advisors, search information providers, credit reference agencies) and may receive information about you from them.

We also collect personal data about you:

•  from publicly accessible sources, e.g. Companies House;
•  from third party sources of information, e.g. client due diligence providers;
•  which you have made public on websites associated with you or your company or on social media platforms such as LinkedIn;
•  from a third party, e.g. a person who has introduced you to us or other professionals (such as solicitors) you may engage.

Personal data we collect online

If you interact with us via the Sites, we use cookies and other technological tools to collect information about your device and your use of the Sites, such as your device’s IP address, your user ID and session identifiers, what pages your device visited, and the time that your device visited our Sites.

Special category personal data

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law. This includes personal data revealing a person’s racial or ethnic origin, religious or philosophical beliefs, or data concerning health.

We do not generally seek to collect special category personal data on the Sites, but this may be collected if you provide it to us or in the context of us providing our services (for information on this, please see out Client Data Protection Policy). If we collect any special category personal data, we will ensure we are permitted to do so under data protection laws, such as by asking for your explicit consent to our proposed use of that special category personal data at the time of collection or where the processing is necessary to establish, exercise or defend legal claims.

Children

The Sites are not intended for or directed at children under the age of 16 years and we do not knowingly collect data relating to children under this age.

HOW WE USE YOUR PERSONAL DATA

Under data protection law, we can only use your personal data if we have a proper reason, eg:

•  where you have given consent;
•  to comply with our legal and regulatory obligations;
•  for the performance of a contract with you or to take steps at your request before entering into a contract; or
•  for our legitimate interests or those of a third party.

A legitimate interest is when we have a business reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The purpose for which we use and process your personal data (excluding special category personal data) and the legal basis on which we carry out each type of processing is explained below.

To enter into and perform contracts with you.

•  It is necessary for us to process your personal data in this way in order to enter into a contract with you and to fulfil our contractual obligations to you.

To provide you with information and services that you request from us.

•  It is in our legitimate interest to respond to your queries and provide any information requested in order to generate and develop business. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.

To enable you to register on the Sites and access restricted areas, and sign up to our e- newsletters and blogs.

•  It is in our legitimate interest to provide our services to you and to register you at your request.

To send you e-newsletters, blogs and other marketing communications concerning SuperScalers Limited, market developments or notifications we believe may be of interest to you (including inviting you to seminars, events, or other functions we believe may be of interest to you).

•  For email marketing to an individual subscriber (that is, a non-corporate email address) with whom we have not previously engaged as a client, we need your consent to send you unsolicited email marketing. Where you provide consent, you can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal.
•  Where consent is not required under applicable law (for example, email marketing to a corporate email address, or where we have previously provided services to you and you have not opted out of receiving our marketing communications), it is in our legitimate interests to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
•  You can always opt-out of receiving direct marketing-related email communications or text messages by sending us an email or by following the unsubscribe link.

To populate our database which we use for marketing purposes.

•  It is in our legitimate interest to ensure that the contacts in our database are relevant and up-to-date. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

To enforce the terms and conditions and any contracts entered into with you.

•  It is in our legitimate interests to enforce our terms and conditions of service. We consider this use to be necessary for our legitimate interests and proportionate.

To send you information regarding changes to our policies, other terms and conditions and other administrative information.

•  It is in our legitimate interest to ensure that any changes to our policies and other terms are communicated to you. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.

To administer the Sites including troubleshooting, data analysis, testing, research, statistical and survey purposes; to improve the Sites to ensure that content is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access the Sites; and to keep the Sites safe and secure.

•  For all these categories, it is in our legitimate interest to continually monitor and improve our services and your experience of the Sites and to ensure network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.

To occasionally monitor emails which you send to us or which we send to you.

•  It is in our legitimate interest to carry out occasional spot checks or audits of such emails to ensure compliance with applicable law and regulation, professional standards and our internal compliance policies.

If you do not wish to provide us with your personal data and processing such personal data is necessary for the performance of a contract with you, we may not be able to perform our obligations under the contract between us.

SuperScalers Limited 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 we need to use your personal data for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.

WHO WE SHARE YOUR PERSONAL DATA WITH

We respect your privacy and will not share your personal data with third parties except as provided in this Privacy Policy.

We share your personal data where required to allow us to provide the services that you have requested, in particular:

•  to enable you to gain access to restricted parts of the Sites;
•  to enable us to provide or for you to receive and/or pay for a service;
•  to enable you to receive information you have requested to be sent to you;
•  in order to fulfil a request you may have made.

We share your personal data with the following third parties:

•  with our directors, staff and consultants and with other companies for the time being within the SuperScalers Limited Group of companies, as necessary to carry out the purposes for which the personal data was provided or collected;
•  with our auditors, lawyers, insurance brokers and other professional advisors;
•  with our third party data processors and service providers who assist with the running of the Sites or who provide other services including marketing and IT support services such as website hosts, data storage/back up services and disaster recovery. Our third party processors and service providers are subject to security and confidentiality obligations and are only permitted to process your personal data for specified purposes and in accordance with our instructions.

In addition, SuperScalers Limited may disclose personal data about you in the following circumstances:

•  if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation. For instance, we may disclose personal data to the FCA and to any other regulatory authority to which we are subject and to any investment exchange on which we may deal or to its related Clearing House (or to auditors, inspectors or agents appointed by them), or to any person in power to require such information pursuant to any applicable law;
•  in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, in which event the recipient of any of your personal data will be bound by confidentiality obligations;
•  if all or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
•  if necessary to protect the vital interests of a person; and
•  to enforce or apply our terms and conditions or to establish, exercise or defend our rights or those of our staff, customers or others.

INTERNATIONAL TRANSFERS

To deliver services to you, it is sometimes necessary for us to transfer and store your personal data outside the UK or the European Economic Area (“EEA”) as follows:

•  with our service providers located outside the UK or the EEA;
•  if you are based outside the UK or the EEA;
•  where there is an international aspect to the Services we have been asked to provide.

Where personal data is transferred to and stored outside the UK or the EEA, we take steps to provide appropriate safeguards to protect your personal data, including:

•  transferring your personal data to a country, territory, sector or international organisation which the UK Government has determined ensures an adequate level of protection, as permitted under applicable data protection laws;
•  entering into standard contractual clauses approved by the UK Government, obliging recipients to protect your personal data as permitted under applicable data protection laws;
•  if we cannot or choose not to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK or the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection laws.

If you would like further information about transfers of your personal data out of the UK or the EEA, please contact our Privacy Manager using the details set out under Contacting Us above.

SECURITY OF YOUR PERSONAL DATA

We use industry standard physical and procedural security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. This includes encryption, firewalls, access controls, policies and other procedures to protect personal data from unauthorised access.

We limit access to your personal data to those who have a genuine business need to access it.

Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal data.

Despite these precautions, however, SuperScalers Limited cannot guarantee the security of personal data transmitted over the Internet or that unauthorised persons will not obtain access to personal data. We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

HOW LONG WE KEEP YOUR PERSONAL DATA

Your personal data will not be kept for longer than is necessary for the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

The criteria we use for retaining different types of personal data, includes the following:

•  General queries – when you make an enquiry or contact us by email or telephone, we will retain your personal data for as long as necessary to respond to your queries. After this period, we will not hold your personal data for longer than 5 years if we have not had any active subsequent contact with you.
•  Direct marketing – where we hold your personal data on our database for direct marketing purposes, we will retain your personal data for no longer than 5 years if we have not had any active subsequent contact with you.
•  Legal and regulatory requirements – we may need to retain personal data for up 7 years after we cease providing services and products to you where necessary to comply with our legal obligations, resolve disputes or enforce our terms and conditions.

YOUR RIGHTS

Access to your personal data

You have the right to access the personal data which we hold about you. If you so request, we shall provide you with a copy of your personal data which we are processing (“data subject access request”).

Data portability

You have the right to receive any personal data which you provided to us in a structured and commonly used format so that it can be transferred to another data controller in certain circumstances.

Right to object

Direct marketing – you have the right to object at any time to our processing of your personal data for direct marketing purposes.

Where we process your personal data based on our legitimate interests – you also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Rectification

We want to make sure that your personal data is accurate and up to date. You have the right to have inaccurate personal data rectified, or completed if it is incomplete.

You can update your details or change your privacy preferences by contacting us as provided in “Contacting us” above.

Erasure (also known as the right to be forgotten)

In certain situations, you can request the erasure of your personal data that we hold.

Restriction of processing

You can request that we restrict the processing of your personal data to processing in certain circumstances.

Right to not be subject to automated individual decision making

You have the right to not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our Sites.

Exercising your rights

You can exercise any of your rights as described in this Privacy Policy and under data protection laws by contacting our Privacy Manager as provided in “Contacting us” above.

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

Save as described in this Privacy Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

LINKS

The Sites may, from time to time, contain links to and from third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and SuperScalers Limited does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

COMPLAINTS

If you have any questions or concerns regarding our Privacy Policy or practices, please contact our Privacy Manager as provided in “Contacting Us” above. We hope we will be able to resolve any issues you may have.

You also have the right to make a complaint at any time to the UK Information Commissioner’s Office who can be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone on 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

From time to time, we may change this Privacy Policy and so you should review this page periodically. The current version of this Policy will always be available from us in hard copy or on the Sites.

If we make any material changes to this Privacy Policy, we may notify you by email or by means of a prominent notice on the Sites to notify you of any such changes to this Policy or update you by other appropriate means.