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/.

     

    Please read this important information before proceeding. It contains legal and regulatory notices relevant to the information on this site.

    This website provides information about Stratton Street Capital LLP ("Stratton Street"). Stratton Street is authorised and regulated by the UK's Financial Conduct Authority. The content of this website has been prepared by Stratton Street from its records and is believed to be accurate but we do not accept any liability or responsibility in respect of the information of any views expressed herein. The information, material and content provided in the pages of this website may be changed at any time by us. Information on this website may be out of date and may not be updated or removed.

    The website is provided for the main purpose of providing generic information on Stratton Street and on our investment philosophy for the use of financial professionals in the United Kingdom that qualify as Professional Clients or Eligible Counterparties under the rules of the United Kingdom Financial Conduct Authority (the "FCA"). The information in this website is not intended for the use of and should not be relied on by any person who would qualify as a Retail Client. Products and services referred to on this website are offered only at times when, and in jurisdictions where, they may be lawfully offered. The information on this website is not directed to any person in the United States. The provision of the information on this website does not constitute an offer to purchase securities to any person in the United States (other than a professional fiduciary acting for the account of a non-U.S person) or to any U.S. person as such term is defined under the Securities Act of 1933, as amended.

    The website is not intended to offer investors the opportunity to invest in any Alternative Investment Fund ("AIF") product. The AIFs managed by Stratton Street are not being marketed in the European Economic Area ("EEA") and any eligible potential investor from the EEA who wishes to obtain information on the AIFs will only be provided with materials upon receipt by Stratton Street of an appropriate reverse solicitation request in accordance with the requirements of the EU Alternative Investment Fund Managers Directive ("AIFMD") and national law in their home jurisdiction. By proceeding you confirm that you are not accessing this website in the context of a potential investment by an EEA investor in the AIFs managed by Stratton Street and that you have read, understood and agree to these terms.

    No information contained in this website should be deemed to constitute the provision of financial, investment or other professional advice in any way. The website should not be relied upon as including sufficient information to support any investment decision. If you are in doubt as to the appropriate course of action we recommend that you consult your own independent financial adviser, stockbroker, solicitor, accountant or other professional adviser. Past performance is not necessarily a guide to the future. The value of investments and the income from them may go down as well as up. An application for any investment or service referred to on this site may only be made on the basis of the offer document, key features, prospectus or other applicable terms relating to the specific investment or service.

    Where we provide hypertext links to other locations on the Internet, we do so for information purposes only. We are not responsible for the content of any other websites or pages linked to or linking to this website. We have not verified the content of any such websites. Such websites may contain products and services that are not authorised in your jurisdiction. Following links to any other websites or pages shall be at your own risk and we shall not be responsible or liable for any damages or in other way in connection with linking.

    By using this site, you should be aware that we may disclose any information that we hold about you to any regulatory authority to which we are subject, or to any person legally empowered to require such information.

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