Data Protection Notice
Stratton Street Capital LLP (“SSC”, “us”, “we” or “the Firm”), as a Data Controller, have an obligation under GDPR to inform individual Data Subjects of their rights in relation to data held about them.
(i) What information is being collected
For the purposes mentioned in the following paragraph “Why it is being collected” we collect the following categories of personal data:
- Name, work contact details such as email, telephone number and address or such other contact details you have supplied us with in order to receive our communications.
(i) Why it is being collected
All the data you provide to us will be processed subject to the restrictions and for the purposes pointed out in this notice, namely:
a. To advise you through e-mail or phone call, in the framework of ordinary commercial relationship, about other products or services similar to those related to your professional interests.
b. From time to time we would like to contact you about events or conferences or seminars organised/sponsored by us or about our new services/products reaching you by email or phone call.
The provision of data is discretionary however a lack of data can be an impediment to the exchange of information necessary for the above purposes.
(i) Who is collecting data
Data will be collected by SSC (the “Data Controller”), with business address 200 Aldersgate, London EC1A 4HD.
The Data Protection Department of our Firm can be contacted by the following methods:
a. Email: GDPR@strattonstreet.com
b. Telephone: 020 7788 0888 or
c. Post: at the address above
(i) How data is processed
Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and, in any case, in order to guarantee data security and data confidentiality in compliance with current regulations. Our Employees and Third Party service providers (such as our I.T service providers) can access your data. Our Employees and Third Party processors are appropriately designated and trained to process data only according to the instructions we provide them. All the data will be processed until the withdrawal of consent or at the end of a defined retention period.
(i) How data is stored and with whom it could be shared
Data is recorded on paper and IT systems. Basic personal data such as your name and contact details will be stored on our CRM system which is accessible to restricted list of staff for the above-mentioned purposes.
We may disclose your Personal Data with authorised service providers who perform services for us (including background checks and KYC, cloud services, data storage, payment processing, customer support and bill collection). Our contracts with our service providers include commitments that they agree to limit their use of Personal Data to our specific instructions and to comply with privacy and security standards.
Without prejudice to any communications made to comply with legal or contractual obligations, data may also be disclosed to external parties as required by laws or regulations (e.g. court, tribunal, Regulatory Authority or Governmental Entity).
When we share your information with other entities within our group or contracted Third Party companies we take all reasonable steps to ensure that your information and privacy are protected in line with the applicable legal obligations.
Data will be stored for a period of 5 years from the date of last successful contact or the end of the commercial relationship unless consent is withdrawn or an erasure request is made.
(i) Your rights and how to exercise them
You (natural persons to which the data refers) have the right to determine how we use your data and to oppose to the purposes of processing at any time. You have the right to withdraw your consent at any time, without affecting the lawful processing of data based on consent up to the point of its withdrawal.
We remind you that you have the right to request from us access to and rectification or erasure of personal data, or a restriction of processing, or to object to processing of data concerning you.
You also have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller without hindrance from us. In exercising your right to data portability, you have the right to have your personal data transmitted directly from a controller to another, where technically feasible.
You can contact us to exercise your rights at the contact details mentioned in the previous section no. (iii) above.
If you consider that the processing of your personal data infringes applicable data protection laws, as data subject you have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular, in the Member State of your habitual residence, place of work or place of the alleged infringement.
The Supervisory Authority for the Member State we are located in and where your data is processed in is the Information Commissioners Office (ICO) who can be contacted via their hotline 0303 123 1113 or through the Concerns section of their website, https://ico.org.uk/concerns/.