This privacy notice explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure (the “Privacy Notice”).
We take privacy seriously and we are committed to protecting and respecting the data you provide to us through Global North Partners website (the “Sites”) or collected by us in the course of providing our services to you.
Global North Partners
The website www.globalnorthpartners.com is provided by Global North Partners Ltd, a company incorporated in the UK with company number 13285167 and registered offices at 207 Regent Street, London W1B 3HH, United Kingdom acting as an Appointed Representative (FRN:950668) of Privium Fund Management (UK) Limited (FRN: 471186) authorised and regulated by the Financial Conduct Authority.
Other names used Globalnorth.
Global North Partners Ltd is the controller of your personal data when you engage it to provide services to you. Consequently, this means that Global North Partners Ltd decides why and how your personal data is processed.
We are registered with the Information Commissioner’s Office and our reference number is ZB040181.
Some key privacy terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our: Global North Partners Ltd, a company incorporated in the United Kingdom, with company number 13285167 and registered offices at 207 Regent Street, London W1B 3HH, United Kingdom, acting as an appointed representative (FRN:950668) of Privium Fund Management (UK) Limited (FRN: 471186) authorised and regulated by the Financial Conduct Authority.
Personal data: Any information relating to an identified or identifiable individual.
Data subject: The individual who the personal data relates to.
PERSONAL DATA WE COLLECT ABOUT YOU
Information given by you voluntarily
We may collect and use the following personal data about you:
o enquire about a job vacancy advertised on the recruitment section
o receive free downloads from www.globalnorthpartners.com;
o complete an enquiry or contact form on our Site contact-us Drop us a line!
o chat on WhatsApp on our Site WhatsApp
o receive our services; and/or
o refresh or update your marketing preferences when responding to a request from us to do so.
We may also ask you for information when you report a problem with our Site.
Information collected from you automatically
We may also automatically collect information about you which we may observe, detect or create without directly asking you to provide the information to us. In common with most other businesses, this will mainly include information gathered automatically through your use of our website or services, such as your IP address, telephone number or the pages of our website that you have visited.
HOW YOUR PERSONAL DATA IS COLLECTED
We collect most of this personal data directly from you — in person, by telephone, text or email and/or via our Sites. However, we may also collect information:
HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
WHAT WE USE YOUR PERSONAL DATA FOR AND WHY
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:
We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations outside to a third party for marketing purposes.
WHO WE SHARE YOUR PERSONAL DATA WITH
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
WHERE YOUR PERSONAL DATA IS HELD
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will keep your personal data while we are providing services to you. Thereafter, we will keep your personal data for as long as is necessary:
We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data.
When it is no longer necessary to keep your personal data, we will delete or anonymise it.
If we collect your personal data, the length of time for which we retain it, is determined by a number of factors including the type of data, the purpose for which we use that data and our regulatory and legal obligations attached to the use of your personal data. We do not retain personal data in an identifiable format for longer than is necessary.
We do not rely on your consent to receive centralised communications, such as newsletters or client updates. You will receive an email from us at intervals of no less than 2 years where you will be asked to re-confirm your consent and preferences for legal topics and disciplines to ensure that the data we hold about your preferences, and your contact details, are current and accurate.
If you apply for a job vacancy advertised on our website, we will keep the fact of your application and your contact information confidential. We will retain this information for no longer than 12 months. Candidates are informed that their CVs will be held for this period for future vacancy opportunities. Application forms give applicants the opportunity to object to their details being retained.
TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA, e.g.:
These are explained below.
We may transfer your personal data to certain countries, on the basis of an adequacy decision. These are set out here.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally-approved standard data protection contract clauses.
To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards please contact us (see ‘How to contact us’ below).
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.:
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
If you would like further information about data transferred outside the UK/EEA, please contact us at email@example.com.
You have the following rights which you can exercise free of charge:
For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
HOW TO COMPLAIN
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
This privacy notice was published and last updated in September 2021.
We may change this privacy notice from time to time - when we do we will inform you via our website or other means of contact such as email.
HOW TO CONTACT US
Our contact details: Global North Partners Ltd, 207 Regent Street, London W1B 3HH, United Kingdom