Where used in this Policy, “H&P” means H&P Advisory Ltd, or any of its subsidiaries or related companies. For the purposes of applicable legislation, including the Data Protection Act 2018 which is the UK’s implementation of the General Data Protection Regulation Regulation (GDPR), as amended or supplemented (the “Data Protection Laws”), the H&P company that you have dealings with is the controller of your personal information.
Personal information of business contacts
If you have had contact with H&P, for example through emailing us or meeting a H&P representative, we may store limited amounts of personal information relating to you, such as your name, job title, employer organisation and contact details. We will collect and store this personal information for the purposes of:
- maintaining a record of contacts
- providing periodic business updates as described below
- inviting you to presentations and events and organising meetings between you and H&P’s representatives.
The personal information we hold about business contacts may be shared with:
- companies who process personal information on H&P’s behalf, such as providers of cloud hosting solutions
- professional advisors, such as accountants, lawyers or other consultants
- other companies in the H&P group.
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.
Personal information of suppliers and professional advisors
If you are a supplier to H&P, or one of its professional advisors, we will store limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation and contact details. We will store this personal information for the purposes of:
- administering and maintaining records of services or advice we have received, and commissioning further services
- the personal information we hold about suppliers and professional advisors may be shared with:
- companies who process personal information on H&P’s behalf, such as providers of cloud hosting solutions;
- professional advisors, such as accountants, lawyers or other consultants; and
- other companies in the H&P group.
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.
Personal information of actual or potential management teams
If you are involved in a transaction that H&P acts as an adviser, we may store personal information relating to you – This might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, bank account details, tax identification numbers residential and nationality information (including copies of identity documents, such as a passport, and proof of address), references provided by third parties, and results of other due diligence carried out. We collect and store this information for the purposes of:
- assessing potential transactions;
- maintaining records of investments;
- administering any transaction that we enter into;
- assessing your suitability for involvement in a transaction;
- complying with our regulatory and legal obligations, such as comply with Anti-Maundering Regulations and performing Know Your Customer (KYC) checks;
- assessing and managing risk;
- safeguarding our legal rights and interests;
- seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
- providing periodic business updates, as described below.
Collecting personal information
Insofar as necessary to provide our services, we may collect personal information from you directly, persons authorised to act on your behalf, third party service providers, as well as any personal data that we may obtain from publicly accessible sources (e.g. HM Land Registry, Companies House, press, sanctions lists, internet).
The personal information we hold about actual or potential management teams may be shared with:
companies who process personal information on H&P’s behalf, such as providers of cloud hosting solutions and third party outsourced services providers;
- credit reference agencies;
- financial intermediaries;
- professional advisors, such as accountants, lawyers or other consultants;
- other persons who have an interest or involvement in, or who are considering an interest or involvement in, a transaction, including co-investors, other providers of finance and investors in a transaction; and
- other companies in the H&P group.
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running our business, in particular by considering potential investments, and administering transactions that we enter into. If we enter into a transaction that you are involved in, it will also be necessary for us to process your personal information for the purpose of performing that contract and to comply with our regulatory and legal obligations.
Mandatory provision of information
We will explain to you when the provision of particular information is mandatory, including the possible consequences of not providing particular information, for example, preventing us from proceeding with a transaction involving you. H&P will only process the personal information you provide to H&P for the purposes listed above.
Sensitive or special category personal data
Different rules apply to data concerning race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences – these are all called sensitive or special category personal data. Please do not send us sensitive personal data as generally we do not need it.
International transfers of personal information
H&P and its group companies are UK based entities. As such, the personal information that we hold for you will be stored on our UK servers. We are unlikely to transfer this information to other countries for processing, however, we may do so where this is required by law, where it is necessary to perform a contract with you, or where we have another legitimate interest in doing so.
Periodic business updates
We may use personal information that we hold to send you periodic updates about H&P’s business, activities and opportunities, in particular, by email and post. You can opt out of receiving updates at any time by contacting us (see “H&P Data Privacy Contacts” below), or by clicking the “Unsubscribe” link in any email that you receive.
Retention of personal information
The period for which H&P will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. We keep the personal data we obtain about you for the duration of our business relationship with you and for as long as we reasonably require it up to a maximum of 7 years after our relationship has ended, as permitted by law and in accordance with our internal data retention policy. In no circumstances will we retain personal data for longer than is necessary for the purpose for which it was collected, unless required to meet our legal or regulatory obligations.
In some circumstances your personal data may be anonymised so that it can no longer be associated with you, in which case it is no longer personal data.
Once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data in accordance with applicable laws and regulations.
Your rights
Individuals whose personal information we hold have the right to:
- Access: request access to their personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
- Rectification: request that any incorrect personal data be updated;
- Erasure: request the erasure of their personal data;
- Restriction of processing: stop or limit the processing of personal data;
- Data portability: request the transfer of their personal data to another party;
- Object: object to the processing of their personal data;
Any such request should be submitted in writing to the Compliance Officer (compliance@hannam.partners). We may need to verify your identity when we receive a request, to ensure that we only act on legitimate requests made by you, or someone you have authorised to act on your behalf.
Individuals also have the right to complain about the use of their personal information to the Supervisory Authority, which in the UK is the Information Commissioner’s Office (www.ico.org.uk).
Accuracy and security
H&P will take all reasonable steps to keep your personal information accurate and, where necessary, up to date. If you believe that any of the information that H&P holds about you is incorrect please notify H&P (see “H&P Data Privacy Contacts” below).
H&P will take all reasonable steps to protect the confidentiality and security of your personal information, but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information online over the Internet and will not hold H&P responsible for any breach of security unless this is due to H&P’s negligence or wilful default.
H&P’s websites may contain hypertext links to external websites. H&P is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.
H&P Data Privacy Contacts
For all enquiries, please email compliance@hannam.partners.
Changes to H&P’s Privacy Policy
Any changes to this Privacy Policy will be posted here, so please check H&P’s Privacy Policy on a regular basis when you visit this website.
Further Information
This Privacy Notice was written with brevity and ease of understanding and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please do not hesitate to contact us at compliance@hannam.partners.
Cookie Policy
What are cookies and how do we use them?
A “cookie” is a bite-sized piece of data that is stored on your computer, mobile phone or tablet hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.
Cookies are typically classified as either “session” cookies or “persistent” cookies.
Session cookies do not remain on your computer after you close your browser.
Persistent cookies remain on your computer or other device until you delete them or they expire.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
If you want to find out more about cookies, including how we use them and what choices are available, please click https://www.aboutcookies.org/ or http://www.cookiecentral.com.
You will also find details on how to delete cookies from your computer as well as more general information about cookies.
How to reject cookies
If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings
Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
For more information generally on cookies, including how to disable them, please refer to https://www.aboutcookies.org/. You will also find details on how to delete cookies from your computer.
