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Privacy Policy

Primary respects your privacy and is committed to protecting your personal information (“Personal Data”). We want to be transparent with you about how we collect and use your Personal Data in making available our website (“Site”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

•  Who we are and how to contact us.

•  Your rights relating to your Personal Data.

•  Marketing communications preferences. 

•  What Personal Data we collect.

•  How we use your Personal Data and why.

•  How we use cookies and other tracking or profiling technologies.

•  Who we share your Personal Data with. 

•  How we keep your Personal Data secure.

•  How long we store your Personal Data.

•  Our policy on children.

 

This Privacy Policy is intended to meet our duties of transparency under the General Data Protection Regulation (“GDPR”).

 

We will post any modifications or changes to this Privacy Policy on this page.


Who we are and how to contact us

 

Primary Capital Partners LLP is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as “Primary”, “we” or “us” in this Privacy Policy).

 

Our address is Augustine House, Austin Friars, London, EC2N 2HA.

 

You can contact us by emailing primary@primaryeurope.com


Your rights relating to your Personal Data

 

By law you have the right to:

 

•  Request access to your Personal Data. 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 the Personal Data 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 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 exercised your right to object to processing (see below).

 

•  Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing 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 Data for direct marketing purposes.

 

•  Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

 

•  Request the transfer of your Personal Data.  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.

 

•  Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

 

How to exercise your rights

 

If you want to exercise any of the rights described above, please contact us by emailing primary@primaryeurope.com

 

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

 

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.

 

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.

 

Complaints

 

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us by emailing primary@primaryeurope.com. We will reply to your complaint as soon as we can.

 

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK is the Information Commissioner’s Office.

 

Marketing communications preferences

 

You can ask us to stop sending you marketing messages at any time by emailing primary@primaryeurope.com. Where you opt out of receiving marketing messages, this will not apply to e-mails relating directly to our investments. 

 

What Personal Data we collect 

 

All the Personal Data we collect is outlined below.

 

Category of Personal Data collected: Technical Data

 

What this means: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.

 

No Special Categories of Personal Data

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.

 

How we use your Personal Data and why

 

We will only use your Personal Data for the purposes for which we collected it as listed below, 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 update this Privacy Policy and we will explain the legal basis which allows us to do so.

 

What is our “legal basis” for processing your Personal Data?  

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. We have set out below the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data:

 

1. Improving your online experience

Category(ies) of Personal Data involved: Technical Data.

Why do we do this: To improve your experience of using our Sites by “remembering” you and any preferences (e.g. language).

Our legal basis for this use of data: 

1.1 Legitimate Interests.

1.2 It is in our legitimate interests that we are able to “remember” you so that your experience of our Sites and associated systems and services is improved.

 

2. Troubleshooting

Category(ies) of Personal Data involved: Technical Data

Why do we do this: To track issues that might be occurring on our systems.

Our legal basis for this use of data: 

2.1 Legitimate Interests.

2.2 It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.


How we use cookies & other tracking or profiling technologies 


We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website.  We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site. 

 

We use first party cookies which are served directly by us to your computer or mobile device.  We do not use third party cookies, i.e. cookies which are served by service providers on our Site. 

 

Our Site uses the following types of cookies for the purposes set out below:

 

1. Essential Cookies

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

 

2. Functionality Cookies

These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences and remembering the changes you make to other parts of our Site which you can customise.  The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.

 

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings.  

 

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site. 

 

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

 

Who we share your Personal Data with 

 

The table below describes who we share your Personal Data with, what we share and why we share it:

 

Recipients: Service Providers.

Category(ies) of Personal Data we share: Technical Data.

Why we share it: Our service providers provide us with IT and system administration services.

Location(s): Within Europe. 

 

We do not transfer your Personal Data to any parties located outside the European Economic Area. This includes our staff, representatives and advisors.
 

How we keep your Personal Data secure


We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. 

 

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

 

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data. 

 

How long we store your Personal Data

 

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above, unless a longer retention period is required by law (for example for regulatory purposes).

 

Our policy on children

 

This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.  

 

PRIMARY CAPITAL PARTNERS LLP, 2018

 

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