- For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR")), the entity responsible for your personal data is SilverStreet Capital LLP at Coveham House, Downside Bridge Road, Cobham, Surrey, KT11 3EP, United Kingdom.
The following principles are complied with when processing personal data:
- Data is processed fairly and lawfully
- Data is processed only for specified and lawful purposes
- Processed data is adequate, relevant and not excessive
- Processed data is accurate and, where necessary, kept up to date
- Data is not kept longer than necessary
- Data is processed in accordance with an individual’s consent and rights
- Data is kept secure
- Data is not transferred to countries outside of the European Economic Area (EEA) without adequate protection
Lawful Basis of Processing Data
The lawful basis of processing of data will always be determined prior to any data being processed. The applicable laws for processing personal data under the GDPR are as follows:
- Consent – the individual has given their Consent to the processing of their personal data
- Contractual – processing of personal data is necessary for the performance of a contract to which the individual is a party with SilverStreet
- Legal Obligation – processing of personal data is necessary for compliance with a legal or regulatory obligation to which SilverStreet is subject
- Legitimate Interests – processing of personal data is necessary under the Legitimate Interests of SilverStreet or a Third Party, unless these interests are overridden by the individual’s interest or fundamental rights
- Public Task – processing of personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority
- Vital Interests – processing of personal data is necessary to protect the vital interests of the individual or another individual
SilverStreet processes personal data under one, or more, of the following Lawful Bases:
- Legal Obligation
- Legitimate Interest
Type of Personal Data Being Processed
The type of personal data being processed will typically include:
- Email Address
- Job Title
- Telephone Number
- Business Name
How Personal Data is Collected
Personal data is obtained from one or more of the following:
- Parties entering into agreements with SilverStreet or the funds that it advises
- Parties approaching SilverStreet to enquire about potentially investing into the funds that it advises or other opportunities
- Requests for information about products and services offered by SilverStreet and
- Employment enquiries either at SilverStreet itself or any of its affiliated companies including portfolio businesses
Why Personal Data is Collected
Personal data is collected to provide legitimate business services which include:
- For Marketing purposes, for example fund raising
- For Business purposes, for example investor reporting and fund administration
- To meet statutory monitoring and reporting responsibilities
- To improve SilverStreet’s services and product offering
Where indicated, however, some of the information is optional and you can choose not to complete.
How Personal Data is Used
Personal data may be used to:
- Process requests for further information, to maintain records and to provide ongoing service levels to investors and other stakeholders
- Carry out our obligations arising from any contracts entered into by you and us
- Comply with legal requirements including anti-money laundering checks
- We may need to pass the information we collect to other companies within our Group for administrative purposes
- We may use third parties to carry out certain activities, such as processing and sorting data, monitoring how customers use our site and issuing our emails for us
- Notify you of changes to our services
- Send you communications which you have requested or that may be of interest to you. These may include information about fund offerings and updates, newsletters and events
- To inform you of various services that may be of interest to you. You may be contacted by post, email, telephone, SMS or such other means with carefully selected marketing communications we deem relevant to send to you in the legitimate interests of SilverStreet. Each marketing communication sent to you by SilverStreet will provide you with the option to unsubscribe and manage your data profile and communication preferences from SilverStreet at any time
- Process a job application
Where Personal Data is Stored
Information collected is stored on the Company’s CRM system or on the Company’s server.
As part of any services offered by SilverStreet, information provided may be transferred to countries outside the European Economic Area (‘EEA’) i.e. our servers, or third-party servers that are used to provide SilverStreet services located in a country outside the EEA. By submitting your data, you consent to the transfer, storage and/or processing of your data wherever it be stored. However, if your data is transferred outside the EEA, steps will be taken to ensure appropriate security measures are in place to ensure your privacy rights continue to be protected as outlined in this Policy.
SilverStreet does not collect information about specific users of its website. It does however use Google analytics cookies which collect information in an anonymous form, including the number of visitors to the site, the IP address of the visitor, time zone, where visitors have come to the site from and the pages they visited. As with many websites, this information can be used to compile statistic reports of our users’ browsing patterns so that we can improve our website and enhance user experience of it. If you change your user settings so that Cookies are switched off then your previous browsing history will no longer be available to SilverStreet.
How long Personal Data is Stored
We review our retention periods for personal data periodically. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold personal data on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.
Who has Access to Personal Data
Only SilverStreet employees are granted access to customer information. This is ensured by the use of strict operational processes and procedures.
Staff are trained on security systems and relevant processes and procedures which are reviewed regularly for ongoing effectiveness and suitability for purpose. All employees are kept up-to-date on the SilverStreet security and privacy practices. Employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure that customer information is protected.
Non-sensitive details (your email address and other requested information) are transmitted normally over the Internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
We will not sell or rent your information to third parties.
Third-Party Service Providers working on our behalf:
We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure.
Third-Party Product Providers we work in association with:
We may also further transfer data if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to law enforcement. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
Different rules apply depending on the type of Lawful Processing being undertaken. Many of the following individuals’ rights apply, however, whatever the basis of processing:
- The right to be informed how personal data is processed
- The right of access to their personal data
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
Links to other websites/from other websites
Like many websites, this website uses “cookies”. A cookie is a piece of data stored on a user’s device containing information about the user’s visit to a website (including this website).
This website uses the Google analytics cookies which collect information in an anonymous form, including the number of visitors to the site, the IP address of the visitor, time zone, where visitors have come to the site from and the pages they visited. As with many websites, we use this information to compile statistic reports of our users’ browsing patterns so that we can improve our website and enhance user experience of it.
You can change your user settings in your browser to prevent us storing cookies on your device. You can find out how to do this, and find more information on cookies, at: www.allaboutcookies.org. Your browser’s help function should also provide information on how to change your cookie settings. Please note that if you adjust your internet browser settings to refuse the setting of cookies, you may be unable to access or fully use certain parts or functionality of the website.
By using this website, you consent to us storing and accessing the above cookies on your device.
We may revise this policy at any time. We suggest you review the policy periodically for changes.
25 May 2018