Total Capital Partners LLP is committed to protecting and respecting your privacy. This Privacy Policy describes how we collect, use and otherwise process personal data relating to you, or that you provide to us.
For the purposes of laws regarding data protection, the data controller is Total Capital Partners LLP (‘Total Capital’), a limited liability partnership registered in England and Wales with registered no. OC337648 and registered office address at 33 Cavendish Square, London, W1G 0PW.
If you have any questions regarding this privacy policy, please direct your questions to our Data Protection Manager by email via info@totalcapital.co.uk.
Personal information: business contacts
If you have interacted with Total Capital, whether through email, meeting someone from Total Capital, or otherwise, we may keep limited amounts of your personal information. This might include your name, job title, employer organisation and contact details. We do this for the purposes of:
- providing business updates (further described below);
- maintaining a list of contacts; and
- asking you along to events such as presentations or organising meetings between you and Total Capital’s representatives.
In accordance with Data Protection Laws, our legal basis for collecting and storing such personal information is that such processing is necessary for our legitimate interests in running and promoting our business. Whilst Total Capital does not routinely obtain consent as the legal basis upon which it stores and processes personal data, it will, if necessary, and to the extent required by Data Protection Laws, obtain the consent of the data subject to hold and process personal information. If consent is provided, it can be withdrawn by the data subject at any time.
The length of time such personal information will be held by Total Capital will depend on why it was collected initially. The requirements of applicable laws or regulations will also affect this.
Personal information: actual or potential management teams
If you are involved in a transaction that Total Capital and/or the funds that it advises enters into, or a potential transaction that Total Capital is contemplating, we may keep certain limited amounts of your personal information.
This might include information relating to your financial status and dealings, your CV, details of your previous employment history and professional activities, your nationality (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence we may have conducted. We collect and store this information for the purposes of:
- evaluating potential transactions;
- keeping records of assets and investments;
- assessing your suitability for involvement in a transaction, including by verifying your identity;
- meeting with our regulatory/legal obligations, including assessing and managing risk;
- administering any transaction that we are involved with;
- safeguarding our own legal rights and interests;
- receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
- providing business updates (further described below).
As required under Data Protection Laws, our legal basis for collecting and storing such personal information is that such processing is necessary for our legitimate interests in running our business, in particular in order to properly review potential investments, and administering any and all transactions that we are party to. In addition, Total Capital may be required to obtain and hold personal information (such as passports and other key identifying documentation) so as to comply with money laundering and related regulation and in order to conduct satisfactory ‘Know Your Client’ checks.
For any matter or transaction that you are involved in, it may also be necessary for us to process your personal information for performing that transaction and to comply with our relevant regulatory/legal duties. Whilst Total Capital does not routinely obtain consent as the legal basis upon which it stores and processes personal data, it will, if necessary, and to the extent required by Data Protection Laws, obtain the consent of the data subject to hold and process personal information. If consent is provided, it can be withdrawn by the data subject at any time.
In certain limited circumstances personal information may be received by Total Capital from a third party, for example a recruiter. In such circumstances it will be held in accordance with this Notice and Data Protection Law. The length of time such personal information will be held by Total Capital will depend on why it was collected initially. The requirements of applicable laws or regulations will also affect this.
Please note that Total Capital has carefully considered and balanced the rights and interests of its data subjects and does not believe such rights and interests have been overridden by Total Capital’s own interests. In making this assessment, Total Capital has considered the nature of all such data subject’s interests, any impact of processing and the relevant safeguards that have been put in place.
Personal information: suppliers and professional advisors
We will store limited amounts of personal information relating to suppliers to Total Capital, or to Total Capital’s professional advisors. This may include names, job titles, qualifications, employer organisations and contact details. This personal information will be stored for the purposes of managing and preserving records of services or advice we have received and authorising further services.
In accordance with the Data Protection Laws, our legal basis for storing personal information that you provide to us is that such storage is necessary for our legitimate interests in running and promoting our business. Whilst Total Capital does not routinely obtain consent as the legal basis upon which it stores and processes personal data, it will, if necessary, and to the extent required by Data Protection Laws, obtain the consent of the data subject to hold and process personal information. If consent is provided, it can be withdrawn by the data subject at any time.
The length of time such personal information will be held by Total Capital will depend on why it was collected initially. The requirements of applicable laws or regulations will also affect this.
Access to Information
We are dedicated to providing reasonable access to visitors who wish to review the personal information retained, if any. In all cases we will treat requests to access information or change information in accordance with applicable legal requirements and a charge may be levied to cover the administration costs of such requests. Please contact info@totalcapital.co.uk should you wish to access your personal information.
Your rights in respect of your personal information
Under certain circumstances, by law, you have the right to:-
i. Request access to your personal information as stated above;
ii. Request correction of any personal information that we hold about you. We have an obligation to ensure that the information we hold about you is complete and accurate;
iii. Right to deletion – you have a right to ask us to delete or remove personal information where there is no good reason for us to continue to hold/process it;
iv. Object to processing – you can object to the processing of your personal information (where we are relying on a legitimate interest or those of a third party) and remove your right to consent in certain circumstances;
v. Request for transfer – you may request for your data to be transferred to another party and/or put in place a restriction on the processing of such data;
vi. Withdrawal to consent – where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose you have the right to withdraw your consent for that specific processing. To withdraw your consent please email info@totalcapital.co.uk and put in the subject line “withdrawal of consent” and state in the body of the email the nature of the processing to which you wish your consent to be withdrawn.
Information Security
We have in place reasonable commercial standards of technology and operational security to protect all information provided by visitors from loss, misuse, alteration or destruction.
Changes to our Privacy Policy
Total Capital Partners LLP reserves the right to modify or amend this privacy statement at any time and for any reason. Nothing contained herein creates or is intended to create a contract or agreement between Total Capital Partners LLP and any user visiting the website or providing identifying information of any kind.
Complaints
If you have any concerns over how we have used or are using your data then please contact info@totalcapital.co.uk in the first instance.
If you are still not satisfied that we have addressed your concerns adequately you have a right to lodge your complaint with the Information Commissioners Office, the details of which are available at www.ico.org.uk