Privacy NOTICE

PRIVACY NOTICE

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. 

Using the Sites or using our services indicates your acceptance of this Privacy Notice (and any changes to it from time to time) and associated privacy policy. We aim to be why and how we process personal data.

​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:

• your name and contact information, including email address, telephone number, demographic information such as postcode and company details
• information to check and verify your identity, e.g. your date of birth
• your billing information, transaction and payment card information
• your professional online presence, e.g. LinkedIn profile
• information from accounts you link to us, e.g.  LinkedIn
• information to enable us to undertake credit or other financial checks on you
• information about how you use our website, IT, communication and other systems
• information when you for instance:

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.

Cookies

​Like many other websites, our Sites use cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our website). 

For more information on how we use cookies and how to reject, delete or disable them, please see our Cookies Notice.

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: 

• from publicly accessible sources, e.g. Companies House or HM Land Registry;
• directly from a third party, e.g.:
  • sanctions screening providers;
  • credit reference agencies;
  • customer due diligence providers;
  • from a third party with your consent, e.g., your bank or building society;
  • from cookies on our website - for more information on our use of cookies, please see our Cookies Notice. 
  • via our IT systems, e.g.: through automated monitoring of our Sites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

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.:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a  third party.

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

• Providing services to you
  • To perform our contract with you or to take steps at your request before entering into a contract.
• Preventing and detecting fraud against you or us
  • For our legitimate interests or those of a third party, i.e., to minimise fraud that could be damaging for you and/or us.
• Conducting checks to identify our customers and verify their identity.
  • To comply with laws or regulations that apply to our business, e.g., under health and safety law or rules issued by our professional regulator
• Screening for financial and other sanctions or embargoes.
  • To comply with laws or regulations that apply to our business, e.g., under health and safety law or rules issued by our professional regulator
• Other activities necessary to comply with professional, legal and regulatory obligations.
  • To comply with laws or regulations that apply to our business, e.g., under health and safety law or rules issued by our professional regulator
• Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies.
  • To comply with laws or regulations that apply to our business, e.g., under health and safety law or rules issued by our professional regulator
• Ensuring business policies are adhered to, e.g., policies covering security and internet use
  • For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you.
• Operational reasons, such as improving efficiency, training and quality control
  • For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you at the best price
• Ensuring the confidentiality of commercially sensitive information
  • For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information.
  • To comply with laws or regulations that apply to our business, e.g., under health and safety law or rules issued by our professional regulator
• Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, service range or other efficiency measures.
  • For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
• Preventing unauthorised access and modifications to systems.
  • For our legitimate interests or those of a third party, i.e. to prevent and detect criminal or fraudulent activity that could be damaging for you and/or us.
  • To comply with laws or regulations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator
• Updating and enhancing customer records
  • To perform our contract with you or to take steps at your request before entering into a contract.
  • To comply with laws or regulations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator
  • For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing services
• Statutory returns
  • To comply with laws or regulations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator
• Ensuring safe working practices, staff administration and assessments
  • For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
  • To comply with laws or regulations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator
• Marketing our services and those of selected third parties to:
  • existing and former customers;
  • third parties who have previously expressed an interest in our services;
  • third parties with whom we have had no previous dealings
  • For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
• Credit reference checks via external credit reference agencies
  • For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services
• External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts
  • For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
  • To comply with laws or regulations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:

• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.

MARKETING

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:

• contacting us at info@globalnortpartners.com 
• using the ‘unsubscribe’ link in emails

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 routinely share personal data with:
• third parties we use to help deliver our services to you, e.g. payment service providers or sub-contractors such as our legal consultants;
• other third parties we use to help us run our business, e.g. marketing agencies or website hosts, our professional advisors, our consultants, providers of our IT systems such as XERO;
• third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
  • credit reference agencies;
  • our insurers and brokers;
  • our bank;

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:

• share personal data with external auditors, e.g. in relation to ISO or other accreditation systems and the audit of our accounts;
• disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
• share some personal data with other  parties, such as potential buyers of some or all of our business or during  a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

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:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

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.

​Opt-in Consent

​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.

​Recruitment

​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.:

• with our offices located outside the UK;
• with your and our service providers located outside the UK/EEA;
• if you are based outside the UK/EEA;
• where there is a European and/or international dimension to the services we are providing to you.
• Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:
• the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or  international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law

These are explained below.

Adequacy decision

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.:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish,   exercise or defend legal claims

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.

Further information

If you would like further information about data transferred outside the UK/EEA, please contact us at privacy@globalnorthpartners.com. 

YOUR RIGHTS

You have the following rights which you can exercise free of charge:

• Access
  • The right to be provided with a copy of your personal data
• Rectification
  • The right to require us to correct any mistakes in your personal data
• Erasure (also known as the right to be forgotten)
  • The right to require us to delete your personal data—in certain situations
• Restriction of processing
  • The right to require us to restrict       processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
• Data Portability
  • The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
• The right to object
  • at any time to your personal data being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
• Not to be subject to automated individual decision making
  • The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

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:

• email, call or write to us (see below: ‘How to contact us); and provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you;
• let us know what right you want to exercise and the information to which your request relates.

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.

CHANGES TO THIS PRIVACY POLICY

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

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details: Global North Partners Ltd, 207 Regent Street, London W1B 3HH, United Kingdom

Email: privacy@globalnorthpartners.com