Privacy Notice

    Welcome to our privacy notice. Novalpina Capital is committed to protecting your personal information when you use our services.  This notice explains how we collect, retain and process your personal information. 

    YOUR RIGHTS REGARDING PROCESSING OF YOUR PERSONAL INFORMATION

    Under certain circumstances, by law you have the right to:

    • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
    • Request access to the personal information we hold about you.
    • Request correction of the personal information that we hold about you.
    • Request erasure of your personal information.
    • Request the restriction of processing of your personal information.
    • Request the transfer of your personal information to another party in a commonly used form.

    For more information on your rights, click here.  To exercise one of these rights, please see contact us, which provides various ways that you can get in touch with us.

    Information used for marketing purposes

    Here we set out how the personal information that we collect about you will be used.

    We are committed to observing relevant legal and regulatory requirements and employing appropriate security measures in order to protect your personal information.

    For the purposes of data protection legislation, Novalpina Capital LLP is a “controller” meaning that we determine the purpose and means of processing the information we collect from you.

    If you ever have any questions, comments or complaints about this notice, or any of its contents, please contact us via any of the following means and we will be pleased to assist you:

    By post: info@novalpina.pe
    By phone:
    (+44) 203 907 4444

    • information that you provide to us from time to time including through our website request or use any of our services, or when you submit queries to us;
    • if you contact us by any means, we will keep a record of that correspondence and information that you provide to us in that correspondence;
    • details of transactions you carry out using our products or services;
    • details of your visits to any of our websites, please see Internet Cookies for details;

    How we use your information

    We use information supplied by you:

    • to confirm your identity and allow us to carry out checks in the interest of security and to prevent fraud;
    • to regulatory anti-money laundering and “know your client” purposes;
    • to provide you with services;
    • to improve the products and services that we offer;
    • to respond to your queries;
    • to carry out our obligations under any contracts entered into between you and us;
    • to notify you about any changes to our services and/or our websites;
    • to comply with legal and regulatory requirements that apply to us;
    • for general statistical analysis.

    From time to time we will contact you by email (with your consent) and/or telephone to provide you with details of our other services and/or events that we think may be of interest to you.  We will not contact you by SMS about those products and services and/or events, unless you have consented to such contact, or in the case of such products and services, where these are similar to those that we have already provided to you.

    SHARING YOUR INFORMATION

    You have the right to ask us not to process your personal data for marketing purposes at any time.  You can exercise your right to prevent such processing by:

    • checking certain boxes on the forms we use to collect your data
    • by replying directly to the marketing message
      • in case you wish to withdraw from all marketing communications, you can also unsubscribe from all marketing by clicking the appropriate link in any email you receive. 
      • at any time by contacting the Financial Controller via the email address stated above.

    LAWFUL PROCESSING

    In terms of the legal bases we rely on to process your information, these are where the processing is necessary:

    • for the performance of a contract with you for provision of our services or to take steps at your request prior to entering into such a contract;
    • to comply with our legal obligations;
    • for our legitimate interests in:
      • ensuring the quality of the services we provide to you;
      • communicating with you; and
      • statistical analysis; or
    • where you have consented to such use.

    We process your sensitive and special categories of information (this includes data concerning your health, personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or data concerning sexual orientation) where we have asked for your explicit consent or otherwise where this is necessary:

    • for the establishment, exercise or defence of legal claims;
    • in the case that you have obviously made information public (e.g. on social media) we will process sensitive/special categories of information for the purposes of carrying out our legal obligations.

    If provision of your personal information is a legal or contractual requirement or a requirement necessary to enter into a contract with us, and you choose not to provide it, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you.

    If you do choose to provide your consent you can withdraw it at any time by contacting the Financial Controller.

    We will not pass your information on to third parties except:

    • we will provide your information to our service providers to allow them to assist us with delivering the products or services that you have requested, under the following categories:
      • accountants
      • administrators or depositaries
      • auditors
      • credit reference agencies
      • law enforcement agencies
      • lawyers
      • Information technology (e.g. web developers) and information security providers
    • law enforcement agencies and regulators where we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation, or if we reasonably consider that this is necessary to help prevent or detect fraud or other crime or to protect the rights, property, or safety of Novalpina Capital, our investors or others;
    • if we are under a duty to disclose or share your information with HM Revenue & Customs (HMRC), who may transfer it to the government or the tax authorities in another country where you may be subject to tax;
    • if Novalpina Capital were to be acquired by a third party, in which case personal data about you as one of our investors would be one of the transferred assets;
    • if you have consented to any disclosure to a third party.

    We currently do not transfer, use and/or store your personal information outside of the European Economic Area (“EEA”). In the event that our data processing needs change and we need to transfer personal data outside of the EEA to countries which do not provide a similar level of data protection, we will update this notice to provide relevant information on such transfers.

    Transfers to our third party service providers are to enable them use and store your personal information on our behalf.  We will, however, put in place appropriate security procedures in order to protect your personal information. We will also ensure that, at any time when your information is transferred to any country outside the EEA this is done using specific legally-approved safeguards.  You can request further details and a copy of these by contacting the Financial Controller.

    SECURITY

    We currently do not transfer, use and/or store your personal information outside of the European Economic Area (“EEA”). In the event that our data processing needs change and we need to transfer personal data outside of the EEA to countries which do not provide a similar level of data protection, we will update this notice to provide relevant information on such transfers.

    Transfers to our third party service providers are to enable them use and store your personal information on our behalf.  We will, however, put in place appropriate security procedures in order to protect your personal information. We will also ensure that, at any time when your information is transferred to any country outside the EEA this is done using specific legally-approved safeguards.  You can request further details and a copy of these by contacting the Financial Controller.

    We will keep your information only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the Data Protection Officer.

    When determining the relevant retention periods, we will take into account factors including: 

    • legal obligations under applicable law to retain data for a certain period of time
    • statute of limitations under applicable law(s)
    • (potential) disputes, and
    • guidelines issued by relevant supervisory authorities.

    In certain cases, we will retain data which we believe is of particular historical interest for our museum. If we wish to retain your data for this purpose, we will inform you directly. Otherwise, we securely erase your information once this is no longer needed.

    YOUR RIGHTS

    We have put in place measures to protect the security of your information.

    These measures are intended to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information 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 any applicable regulator of a suspected breach where we are legally required to do so.

    Unfortunately, the transmission of information via email is not secure.  Therefore, if you use email for communicating with us, we cannot guarantee that it will remain confidential whilst in transit.

    You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this notice.

    Your rights in connection with personal information

    Under certain circumstances, by law you have the right to:

    • Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
    • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
    • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see above).
    • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
    • Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.

    If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing.

    CHANGES TO OUR PRIVACY NOTICE

    The various rights are not absolute and each is subject to certain exceptions or qualifications. In some cases, these rights do not become a legal requirement until 25th May 2018. In these cases we may not be able to fulfil your request to exercise the right before this date. Where we cannot provide a full response to you for this reason, we will let you know about this in our initial reply to your request.

    Your duty to inform us of changes

    It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

    Fees

    You will not have to pay a fee to access your personal information (or to exercise any of the other rights).  In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

    Right to complain

    If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, contact the Financial Controller (see section 1.1 for contact details).

    If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (“ICO”): https://ico.org.uk/global/contact-us/  or 0303 123 1113.

    We keep our privacy notice under regular review and any updates in the future will be posted on our website and the most recent version of this “Privacy Notice”.  Where appropriate, changes may be notified to you by post or email.