Headway Capital Partners LLP is committed to protecting and respecting your privacy. This webpage sets out when and how we use your personal information that you or others provide to us, including through this website (the “Website”). Your privacy is of the utmost importance to us. We want to make sure you fully understand the terms and conditions surrounding the capture and use of that information. This Privacy Notice describes what information we collect about you, how we use it, and the rights you have in relation to that collection and usage.
Whenever you provide Personal Information, we are legally obliged to use it in accordance with the laws concerning the protection of Personal Information.
WHO WE ARE
Headway Capital Partners LLP a limited liability partnership and registered in England and Wales with company number OC306661 whose registered office is at 90 Whitfield Street, 1st Floor, London, England, W1T 4EZ. HCP Service Company Ltd is a private company incorporated and registered in England and Wales with company number 05018590 whose registered office at the above address (together “Headway” or “We”).
For the purposes of the General Data Protection Regulations and any other applicable data protection and privacy laws and regulations, including the UK GDPR and Data Protection Act 2018 (“Data Protection Legislation”), Headway Capital Partners LLP will be the ‘data controller’ for all Personal Information we determine the means and purpose of processing for our suppliers and investors, and has registered with the Information Commissioners Office (ICO) under registration number ZA384327.
HCP Service Company Limited will be the ‘data controller’ for all of our employee data we determine the means and purpose of processing.
By “Personal Information” we refer to data collected or held by Headway, that identifies and relates to you as an individual.
INFORMATION WE MAY COLLECT
We may collect Personal Information about you in the following circumstances to enable us to provide you with the investment services we offer.
Prior to or during your engagement with Headway, we may collect Personal Information including:
- Your name;
- Date of Birth;
- Residential address;
- Financial information (this may include your financial history, National Insurance number and tax numbers);
- Bank Details;
- Information collected from a personal utility bill and a passport;
- Information regarding the investment services you request;
- Supplementary information you provide us about yourself when contacting us;
- Email address; and
- Telephone numbers (including mobile).
We collect the above information to allow us to operate our services effectively and to service the requests you make to Headway. Some of the information listed above is required to enable us to fulfil our due diligence obligations required under law.
We may also collect technical information about you when you visit the Website. This information may include:
- The Internet protocol (IP) address used to connect your computer to the Internet;
- Your browser type and version;
- Time zone setting, operating system and platform;
- Browser plug-in types and version;
- The full URL clickstream to, through and from the Website;
- Page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs); and
- Methods used to browse away from the page.
The collected information is used to provide an overview of how people are accessing and using the Website.
We may also receive details about you from third parties who have provided us with your information under an appropriate legal ground for sharing, notably AML service providers, fund administration service providers and placement agents. We will always inform you of how we received your information when we contact you.
If you become an employee, worker or contractor for Headway, we may collect Personal Information including:
- Your name;
- Date of Birth;
- Residential/postal address;
- Contact details (work or personal);
- Information collected from a personal utility bill and a passport;
- CV and career professional history including qualifications relating to your suitability for any role;
- Information relating to your eligibility to work within Headway;
- Information relating to your personal directorships;
- Any stock you hold and trade personally
- Next of kin information for employees of Headway;
- Bank or invoice details for payment purposes;
- National insurance number or tax numbers; and
- HR details and information relating to the contract you hold with Headway.
Under the terms of your engagement with Headway, we may be required to collect potentially sensitive Personal Information about you relating to:
- Your health, including sickness records, absence and medical conditions; and
- Information about any criminal convictions or the outcomes of your DBS applications.
If you fail to provide us with Personal Information: You always reserve the right to withhold your Personal Information but this may affect how we provide our services to you.
Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.
WHAT WE DO WITH THE INFORMATION WE COLLECT
We will only ever use your Personal Information when allowed to by law and always under a documented lawful basis for processing.
We will use Personal Information provided to us by investors or individuals related to the investments held by funds we advise for a number of purposes including:
- To initiate and process the investment services you request;
- To ensure our records are complete and accurate;
- To provide the specific services agreed by you;
- To undertake performance analysis and management of the business;
- To give you information that you request from us and to improve our services;
- To notify you about changes to our services;
- To allow us to operate the Website efficiently;
- Any relevant troubleshooting, testing or statistical analysis as appropriate; and
- To keep the Website secure.
To perform our obligations under Anti-money laundering and due diligence laws, we use the Worldcheck AML service to screen our investors and transaction counterparties/stakeholders (for more information here: https://risk.thomsonreuters.com/en/products/world-check-know-your-customer.html) We remain the controller of your data.
We will inform you of the outcome of such profiling (automated decision making) and you reserve the right to object to this processing by contacting GDPR@Headwaycap.com.
Based on our legitimate interest and reasonable assumption that you would find such information useful, we may also use the information collected to:
- Provide you with information about our services that we offer via promotional communications; and
- Keep you up to date with features on the Website,
however, you can opt-out of any of these data uses at any time by clicking the ‘unsubscribe’ button at the bottom of our electronic communications or by emailing GDPR@Headwaycap.com. We will only keep your information for as long as reasonably required or as stated in the contract you have with us.
We will use Personal Information provided to us by employees, workers or contractors to perform the relevant contract between us in the following ways:
- Making decisions regarding your recruitment or appointment;
- Checking your eligibility to work for or with Headway;
- Remunerating you for your services and paying any taxes due under those services;
- Administering the terms of the agreement between us;
- Managing any legal or internal disciplinary procedures that may arise;
- To prevent fraud;
- To ensure the safety and security of all of our internal networks and assets; and
- To monitor your use of our information and communication systems to ensure compliance with all of our internal policies.
We may process special categories of Personal Information collected from Personnel in the following circumstances:
- In limited circumstances, with your explicit written consent;
- Where we need to carry out our legal obligations or exercise rights in connection with employment; and
- Where it is needed in the public interest, such as for equal opportunities monitoring.
We use Experian to screen our Personnel’s credit status (for more information: https://www.experian.co.uk/) We will inform you of the outcomes of such profiling (automated decision making) and you reserve the right to object to this processing by contacting GDPR@Headwaycap.com.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We do not need your consent if we use special categories of your Personal Information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law.
In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You may withdraw your consent for this form of processing at any time by emailing GDPR@Headwaycap.com or following the process outlined in ‘Your rights under data protection law’ below. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us
LAWFUL BASIS OF PROCESSING
We always ensure that a lawful basis exists for all off the Personal Information we process at Headway, notably, performance of a contract, legal obligations and legitimate interests.
We will only process your information for as long as we have a relevant lawful basis to do so. All of the information collected and detailed in the sections above is processed to provide you with the contractual services you have requested from Headway unless stated otherwise in the ‘Information we may collect’ section, or if you have provided us with adequate consent to process your information for other purposes.
If we choose to process your information under the lawful basis of legitimate interests, we will always inform you of our legitimate business interest and your right to object. The legitimate interests serve the purpose of our business advancement and protection.
If you choose to access your Personal Information under the rights afforded to you by Data Protection legislation, we will always inform you of the lawful basis under which we process your information.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
PROTECTING YOUR INFORMATION
We take our security obligations very seriously and constantly monitor for breaches and potential weaknesses.
We are committed to ensuring that your information is secure, and we have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect online.
All the Personal Information collected by us and stored electronically is held on secure, encrypted servers in the EEA, unless stated below. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, all electronic communications to and from our cloud based service providers are made under SSL encryption, and we authorise access to Personal Information only for those employees who require it to fulfil their job responsibilities.
However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.
TRANSFER OF DATA OUTSIDE OF THE EU AND THE UK
We shall not transfer any Personal Information to any country outside of the European Economic Area and the UK unless we ensure that such Personal Information is subject to an adequate level of protection and appropriate legal safeguards in accordance with Data Protection Legislation. Please note that after Brexit, the European Commission decided that the UK had adequate data protection standards and personal data can flow freely between the UK and the EEA and vice versa.
The cloud based service provider and internal messaging system are both USA database centres, and we ensure that appropriate safeguards are implemented in accordance with the Data Protection Regulations.
If you wish to access your Personal Information, we will inform you of the transfers we make (if any) and the legal safeguards we have employed to ensure the ongoing security and protection of your data.
SHARING YOUR INFORMATION WITH OTHERS
If and when we share your data, we always do so under a written agreement governing how your data must be protected.
- We may use carefully selected sub-processors to help us collect, store or manage your information. This will always be managed under the terms of a written data processing agreement;
- Analytics and search engine providers that assist us in the improvement and optimisation of the Website; and
- If Headway is acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets. We process your Personal Information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your Personal Information in this way, the relevant seller or buyer of our business may not be able to provide services to you.
YOUR RIGHT TO OBJECT UNDER DATA PROTECTION LAWS
You have the right to object to us handling your Personal Information when:
- We are handling your Personal Information based on our legitimate interests. If you ask us to stop handling your Personal Information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your Personal Information should continue. This may be to protect ourselves against any potential legal actions that may arise or to continue conducting our business in a fair and profitable fashion. Our use of legitimate interests will always be balanced against your right to privacy under Data Protection Legislation and we will conduct a data protection impact assessment wherever necessary; or
- We are using your Personal Information for marketing purposes. If you ask us to stop handling your Personal Information on this basis, we will stop.
YOUR RIGHTS UNDER DATA PROTECTION LAW
You can exercise the following rights to your data by contacting us at GDPR@Headwaycap.com. We will only take instructions from you or your legal representative to effect or to alter a policy and we will protect your privacy when you contact us by asking specific and relevant questions to make sure we are speaking to you or your legal representative and not to an unauthorised person.
Right of access
You are entitled to receive confirmation as to whether your Personal Information is being processed by us, as well as various other information relating to our use of your Personal Information. You also have the right to a copy of the Personal Information which we are handling regarding you.
Right to rectification
You have the right to require us to rectify any inaccurate Personal Information we hold about you. You also have the right to have incomplete Personal Information we hold about you completed, by providing a supplementary statement to us.
Right to restriction
You can restrict our processing of your Personal Information where:
- You think we hold inaccurate Personal Information about you;
- Our handling of your Personal Information breaks the law, but you do not want us to delete it;
- We no longer need to process your Personal Information, but you want us to keep it for legal reasons; or
- We are handling your Personal Information because we have a legitimate interest you and are in the process of objecting to this use of your Personal Information
Where you exercise your right to restrict us from using your Personal Information, we will then only process your Personal Information when you agree, except for storage purposes and to handle legal claims.
Right to data portability
You have the right to receive the Personal Information we hold about you in a structured, standard machine readable format and to send this to another organisation controlling your Personal Information.
Right to erasure
You have the right to require us to erase your Personal Information which we are handling in the following circumstances:
- We no longer need to use your Personal Information for the reasons we told you we collected it for;
- Where we needed your consent to use your Personal Information and you have withdrawn your consent;
- You object to our use of your Personal Information and we have no compelling reason to carry on handling your Personal Information;
- Our handling of your Personal Information has broken the law; or
- We must erase your Personal Information to comply with a law we are subject to.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact GDPR@Headwaycap.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Right to complain
You have the right to issue a complaint directly with the Information Commissioners Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/).
A cookie is a small data file that certain websites write to your hard drive when you visit them. The only personal information a cookie can obtain is information supplied by the user. A cookie cannot read data from your hard disk or read cookie files created by other sites.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We may change this Privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Information.
Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Information handling practices. We will endeavour to notify all of our current clients of any material updates to this notice via email and we will post the relevant announcement on our website homepage.
We recommend that you print a copy of this page for your reference.
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Headway Capital Partners LLP
90 Whitfield Street, 1st Floor
London — W1T 4EZ
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