This Privacy Statement explains how Puma Investment Management Limited uses the personal information that we collect or generate both in relation to this website and the products and services we provide.
The EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and other related laws protecting personal data (the “Law”) regulate the way in which Personal Data (i.e. information which directly or indirectly identifies you and defined in more detail at section 2) must be processed including but not limited to the way in which it is collected, handled, stored, disclosed and otherwise “processed” to meet the required data protection standards and to comply with the Law.
For the purposes of the Law, Puma Investment Management Limited (“Puma Investments”, “we”, “us” or “our”) with its registered office at Bond Street House, 14 Clifford Street, London, W1S 4JU is the data controller. This means we are primarily responsible for making determinations about how and why we process your personal data which is described in more detail in sections 5 and 6 below.
Puma Investments is committed to protecting the privacy and security of your Personal Data. This Privacy Statement provides information on how your Personal Data is processed by us in the course of carrying on our contractual, regulatory and commercial activities.
2. What is Personal Data?
“Personal Data” is data which by itself or with other data available to us can be used to identify you. As set out in the Law, this means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Puma Investments (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Puma Investments or any other person in respect of an individual.
“Sensitive Personal Data” means any personal data relating to your racial or ethnic origin; your political opinions; your religious (or similar) beliefs; your physical or mental health condition; details of criminal offences or criminal convictions (including the commission or alleged commission of any offence, any proceedings for any offence committed or alleged to have been committed and the disposal of such proceedings or the sentence of any court in such proceedings) and your genetic and biometric data.
3. Products and services provided
This Privacy Statement concerns the following categories of information that we collect about you when providing the following products and services or during the application to provide such products or services:
- information we received about you when you are an investor, or applicant investor, in any of the products and/or services provided, managed or advised by Puma Investments (in such circumstances you being an “Investor”);
- information which we received about you where you are a director, beneficial owner, trustee or otherwise exercise control over a company (or its group or affiliate(s)) or any other vehicle to which Puma Investments provides or potentially provides advice or financing, including but not limited to, equity or debt financing (in such circumstances you being an “Investee”);
- information we have received from you in your professional capacity or which has been obtained from publicly available sourced (in such circumstances you being a “Business Contact”); and/or
- information we receive through our website www.pumainvestments.co.uk (the “Website”).
4. Types of Personal Data collected
Many of the products and services offered by Puma Investments require us to obtain Personal Data about you in order to provide the products and/or services we have been engaged to provide. In relation to each of the services described at paragraph 3 above, we will collect and process the following Personal Data about you:
We may collect certain Personal Data, including, without limitation and where necessary according to the nature of your relationship with us, the following:
- your name and contact details such as address, telephone number(s) and email address(es);
- your nationality and national identity number(s);
- your tax status and tax identification number (such as National Insurance Number);
- your history of employment;
- any directorships or officer roles held or previously held;
- your bank account details;
- information on income and personal wealth;
- information on investigations, litigation, court proceedings, civil liabilities or criminal convictions against you;
- Personal Data about other individuals, such as joint applicants or where you have been granted Power of Attorney for or otherwise exercise discretion on behalf of an Investor. You must have their authority to provide their Personal Data to us and share this Privacy Statement with them beforehand together with details of what you have agreed on their behalf;
- information on how and when you use our websites and links to them; and
- where permitted, information received from credit reference agencies, fraud prevention agencies and from other public sources such as Companies House.
We may monitor and/or record your telephone calls and electronic transactions.
We will only collect and process your Sensitive Personal Data with your explicit consent or where the processing is specifically authorised by a regulatory body or required by law.
4.2 Anonymised data
In addition to the categories of Personal Data described above, Puma Investments will also process further anonymised information, which may be derived from your Personal Data, but which makes no reference to a specific individual. This is generally for the purposes of producing statistical research and reports.
5. How we use your Personal Data
Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- to assess your application as an Investor or Investee and where applicable in the provision of products and/or services requested by you;
- making credit decisions (where applicable in relation to you being an Investee);
- detecting and preventing financial crime including fraud and/or money laundering;
- statistical analysis and assessment;
- to communicate with you and in order to provide you with services or information about Puma Investments the products and services we provide;
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; and/or
- for the administration and maintenance of databases storing Personal Data.
6. The legal basis for processing your Personal Data
The Law sets out a number of different bases pursuant to which we may collect and process your Personal Data, including:
6.1 Where you have provided your consent
In specific situations, we can collect and process your data with your consent. For example, when you request us to disclose your Personal Data to other people or organisations when we process Sensitive Personal Data about you at your request or where required as part of the product or service applicable to your relationship with us.
You are free at any time to change your mind and withdraw your consent in accordance with paragraph 10. The consequence might be that we are unable to provide certain products and services to you.
6.2 Contractual obligations
We will use your personal data to comply with various contractual obligations, including processing your application as an Investor, to manage and perform our obligations under a contract, to assist you and answer your requests, to update our records where your Personal Data changes and you notify us of such changes or to contact you about the product(s) you have or service(s) we provide you as an Investor or Investee.
6.3 Legal and regulatory obligations
We use your personal data to comply with various legal and regulatory obligations, including when you exercise your rights under the Law and for compliance with legal and regulatory requirements and related disclosures such as verifying your identity, making credit checks and to perform ‘know-your-customer’ checks. We are obliged to take all necessary steps in order to prevent and detect financial crime including money-laundering and financing of terrorism and in order to comply with legislation relating to sanctions and embargoes. We also record and may monitor phone calls and electronic communications made or sent to or by us in order to comply with our regulatory obligations.
6.4 Our legitimate interests
In specific situations, we may use your Personal Data to pursue our legitimate interests in a way which you might reasonably expect and which does not materially impact your rights, freedom or interests. For example, we will use the information to understand your needs and interests, to communicate with you in order to provide you with information about Puma Investments and for maintaining compliance with internal policies and procedures. As a Business Contact, we will also use your contact details to send you direct marketing information informing you about events, products and services that we think might interest you. If you wish to stop receiving marketing communications from us please email email@example.com or click the unsubscribe link in the relevant communication.
In addition to any recording of electronic communications that is either legally authorised or imposed or to which you have consented, we may record electronic communications with you for the purpose of ensuring the training and supervision of employees, improving the quality of the service and/or providing evidence of commercial transactions or communications that took place through these electronic communications including the content of these communications.
However we use Personal Data we make sure that the usage complies with the Law. Further, we shall ensure that your Personal Data is accessed only by employees of Puma Investments that have a need to do so for the purposes described in this Privacy Statement.
7. Sharing your information with third parties
We may share your Personal Data with our affiliates within the Shore Capital Group. We may also share your Personal Data outside of the Shore Capital Group for the following purposes:
- with our business partners, such as your IFA or Intermediary or the relevant registrar and/or receiving agent where you are an Investor. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
- with third party agents, contractors or other service providers for the purposes of providing services to us and/or you (for example, Puma Investments’ accountants, professional advisors, IT and communications providers and debt collectors, you Financial Adviser and data analytics providers). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Statement;
- to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;
- if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
- if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer in order that they may continue to provide you with the relevant product or service.
8. International Transfers
In certain circumstances, we may transfer your data to another country. In case of international transfers originating from the European Economic Area (EEA), to a non-EEA country, where the European Commission has recognised a non-EEA country as providing an adequate level of data protection, your personal data will be transferred on this basis.
For transfers to non-EEA countries where the level of protection has not been recognised as adequate by the European Commission, we will either rely on a derogation applicable to the specific situation (e.g. if the transfer is necessary to perform our contract with you such as when making an international payment) or implement standard contractual clauses approved by the European Commission to ensure the protection of your personal data.
9. Security and data retention
As a condition of employment, Puma Investments employees are required to follow all applicable laws and regulations, including in relation to the Law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by a Puma Investments employee is prohibited and may result in disciplinary measures.
When you contact a Puma Investments employee regarding the product or service we provide to you, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your records held by us.
How long we will hold your Personal Data for will vary and will be determined by the following criteria:
- the purpose for which we are using it – Puma Investments 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 we have to keep your Personal Data.
10. Your rights
In all the above cases in which we collect, use or store your Personal Data, you have the following rights under the Law:
- the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
- the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
- the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
- the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled or obligated to retain it;
- the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled or obligated to refuse that request; and
- the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details listed in paragraph 13 below.
11. Marketing Communications
We may contact you periodically to provide information regarding events, products, services and content which are relevant to the products and/or services which you receive from Puma Investments and which are considered to be part of the service which we offer you. If the Law requires that we receive your consent before doing so, we will only send you such marketing communications after receiving your consent.
In accordance with paragraph 10, you have the right at any time to stop receiving marketing communications. You can do so by clicking the unsubscribe link in the relevant marketing communication or contact Puma Investments’ Privacy Officer as described below.
12. Changes to this Privacy Statement
We keep the Privacy Statement under regular review. We reserve the right to update this Privacy Statement at any time and we will advise you when any material changes to it are made.
13. Contact Information
If you have any questions or concerns about the processing of your Personal Data, or about this Privacy Statement, please contact Puma Investments’ Privacy Officer by emailing firstname.lastname@example.org or in writing to Puma Investments, Bond Street House, 14 Clifford Street, London W1S 4JU.
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Puma investments will provide you with the contact information for that regulator.