Privacy policy
Privacy Policy
Lupia Capital Advisers is responsible for ensuring that it uses your personal data in compliance with data protection law. The purpose of this notice (the “Privacy Policy”) is to explain what personal data Lupia Capital Advisers collects and how Lupia Capital Advisers uses it. For the purposes of data protection law, Lupia Capital Advisers is a data controller in respect of your personal data. “Personal data” is any data that can be used to identify you or that Lupia Capital Advisers can link to you and which Lupia Capital Advisers has in its possession or control.
Personal data that Lupia Capital Advisers collects
Lupia Capital Advisers will collect and process the following personal data:
- Information that you or someone acting on your behalf provides to Lupia Capital Advisers or its Associates. This includes information about you that you give Lupia Capital Advisers by communicating with Lupia Capital Advisers, whether face-to-face, by phone, e-mail or otherwise. If you are a client or are connected with one of our client's matters, this may include personal data about you or others that is provided to Lupia Capital Advisers in connection with the provision of services to that client.
- Information Lupia Capital Advisers collects or generates about you. We will also collect information about you when you use our services or when we otherwise interact or correspond with you. We do not collect or store information about you when using your website but our web-hosting service, 1&1 IONOS, may do so. For their privacy policy please click here.
Uses of your personal data
Personal data may be stored and processed by Lupia Capital Advisers in the following ways and for the following purposes:
- to contact you in connection with your work with Lupia Capital Advisers and the products and services that Lupia Capital Advisers provides to you or a client to whom you are connected;
- to perform the contract with you or a client/supplier to whom you are connected (including performing Lupia Capital Advisers' obligations and exercising Lupia Capital Advisers' rights);
- to engage in marketing and business development activity and to advise you or a client to whom you are connected of other products and services similar to those which you or a client to whom you are connected receive from Lupia Capital Advisers and/or its Associates;
- to notify you about changes to Lupia Capital Advisers's service;
- to comply with Lupia Capital Advisers's legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations and tax reporting obligations;
- to use it to look into any complaints or queries you or a client/supplier to whom you are connected may have.
- Consent - we may (but usually do not) need your consent to use your personal data. You can withdraw your consent by contacting us (see below).
- Performance of a contract - we may need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you or a client to whom you are connected.
- Legitimate interest - we may use your personal data for our legitimate interests, some examples of which are given above. • Compliance with law or regulation - we may use your personal data as necessary to comply with applicable law/regulation.
Disclosure of personal data to third parties
Lupia Capital Advisers may disclose personal data to its Associates in the circumstances described below:
- to provide the services or perform its obligations in connection with your contract or the contract of a client/supplier with whom you are connected;
- for the management and administration of the Lupia Capital Advisers business;
- for the management and administration of internal policies and procedures within Lupia Capital Advisers.
Lupia Capital Advisers may also disclose personal data outside of Lupia Capital Advisers and its Associates, as follows:
- to third party agents, service providers or contractors, bound by obligations of confidentiality, who will only use personal data on Lupia Capital Advisers' behalf for the purposes described in this Privacy Policy;
- to the extent required by law, regulation or court order for example if Lupia Capital Advisers is under a duty to disclose personal data in order to comply with any legal or regulatory obligation; and
- in order to establish, exercise or defend Lupia Capital Advisers's legal rights, for example if Lupia Capital Advisers needs to obtain external legal advice or provide personal data in connection with judicial proceedings.
Transfers of personal data outside the European Economic Area
Personal data may be transferred to or stored at a destination outside the European Economic Area (“EEA”).
Where Lupia Capital Advisers stores data outside the EEA, Lupia Capital Advisers will ensure that it is protected in a manner that is consistent with how personal data will be protected by Lupia Capital Advisers in the EEA.
In other circumstances the law may permit Lupia Capital Advisers to otherwise transfer personal data outside the EEA. In all cases, however, Lupia Capital Advisers will ensure that any transfer of personal data is compliant with applicable data protection law.
Retention of personal data
How long Lupia Capital Advisers holds personal data for will vary. The retention period will be determined by various criteria including:
- the purpose for which Lupia Capital Advisers is using it - Lupia Capital Advisers will need to keep the data for as long as is necessary for that purpose; and
- legal obligations - laws or regulation may set a minimum period for which Lupia Capital Advisers has to retain personal data.
Rights in relation to personal data
You have a number of legal rights in relation to the personal data that Lupia Capital Advisers holds about you. These rights include:
- the right to obtain information regarding the processing of your personal data and access to the personal data which Lupia Capital Advisers holds about you;
- the right to request that Lupia Capital Advisers rectify your personal data if it is inaccurate or incomplete;
- the right to request that Lupia Capital Advisers erase your personal data in certain circumstances. Please note that there may be circumstances where you ask Lupia Capital Advisers to erase your personal data but Lupia Capital Advisers is legally entitled to retain it;
- the right to object to, and the right to request that Lupia Capital Advisers restrict, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask Lupia Capital Advisers to restrict, its processing of your personal data but Lupia Capital Advisers is legally entitled to continue processing your personal data and / or to refuse that request;
- in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that Lupia Capital Advisers transmit such 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 Lupia Capital Advisers;
- the right to withdraw your consent, although in certain circumstance it may be lawful for Lupia Capital Advisers to continue processing your data where Lupia Capital Advisers has another legitimate reason (other than consent) for doing so. Lupia Capital Advisers is not relying on your consent in order to process your personal data for the purposes and in the manner set out in this Privacy Notice; and
- the right to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by Lupia Capital Advisers.