Privacy Notice

May 2018

This website is operated by Smith Square Partners LLP (“SSP”), also referred to in this Privacy Notice as “we” or “us”. SSP is a is an independent corporate finance advisory firm authorised and regulated by The Financial Conduct Authority, and registered as a Limited Liability Partnership the United Kingdom at 8 Lord North Street, London, SW1P 3LA (registration no OC357682)

SSP is committed to protecting and respecting your privacy in our role as a “controller” of certain personal information you provide to us. As a controller, we decide the “why” and “how” of the processing of your personal data.

This notice describes how we will collect and use your information and the rights you have in relation to your information.
We may need to collect and use “personal information” about you when you use this website, request information from us or engage with our services, or as a result of your relationship with one or more of our clients. By “personal information” we simply mean any information about you from which you can be identified, such as your name or contact details.

By using any of our services, including this website, and by providing us with any personal information, you understand that we will use your personal information as set out in this notice. Please do not send us any personal information if you do not want that information to be used in this way.

WHEN WE WILL PROCESS YOUR PERSONAL INFORMATION
We will only handle your personal information where:
• you have given your consent to such processing (which you may withdraw at any time); and/or

• the processing is necessary to provide our services through this website, or under a contract with you or your employer; and/or

• the processing is necessary for compliance with our legal obligations; and/or

• the processing is necessary for our legitimate interests or those of any third party recipients that receive your personal data.

INFORMATION WE COLLECT
SSP may ask for and collect personal information from you at certain points via this website and though other communications with you.

Depending on the information and/or services you request, we may collect and handle the following types of information about you:
• your name, address, email address and other contact information (both business and personal);
• your role, position and/or job title within your employment;
• details of your visits to our premises
This data may be used to promote our services and SSP may combine this information with other personal information collected about you.

In certain circumstances it will be necessary for you to provide us with your personal information, to enable us to manage our operations, to provide services to you or your employer or to comply with our statutory obligations. In other circumstances, it will be at your discretion whether you provide us with personal information or not. However, failure to supply any of the personal information we request may mean that we are unable to maintain or provide services or products to you or your employer.

HOW WE COLLECT YOUR PERSONAL INFORMATION
We usually collect your personal information from the information you submit during the course of your, or your employer’s, relationship with us.

This will typically be through you sending us emails and other correspondence, business cards, or the information you provide to access any of our services either on your own behalf or on behalf of your employer.

HOW WE USE YOUR INFORMATION
At SSP we are committed to protecting and respecting your privacy and will only use your personal information:
• to provide our services to you;
• to market our services to you (where we have received your consent to do so, or we believe that you may be interested in the material as it relates to similar products or services you have previously acquired, or indicated your interest in acquiring, from us – see below for further information;
• to manage our relationship with you and our clients;
• to fulfil our legal obligations;
• to provide you with personalised content;
• to process and respond to inquiries;
• to alert you to new features, special events, and service offerings;
• for other legitimate business purposes;
• to compile anonymous statistics, for example, website usage statistics;
• to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
• to comply with court orders and exercise and/or defend our legal rights; and
• as otherwise permitted or required by any applicable law or regulation.

EMAIL MARKETING AND MARKETING MESSAGES
We periodically send marketing emails, used to inform you from time to time about products, services and/or news we supply/publish or to invite you to events. You can unsubscribe at any time by contacting us as set out below or by the method referred to in the footer of sent marketing messages. Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.

Please note that we may use your marketing and content preferences, and other information you provide to us (including details of your attendance at, or interest in, events) in order to build a profile for you. We may supplement this profile with information about how you review our content and interact with us. We use this profile to try and ensure that you only receive information that you are likely to find of interest.

HOW AND WHY WE SHARE YOUR INFORMATION
We do not and will not sell, rent out or trade your personal information. We will only disclose your personal information in the ways set out in this notice and, in particular, to the following recipients: to any group company of SSP;
• to third parties who process your personal information on our behalf (such as our systems providers including cloud providers);
• to third parties who process your personal information on their own behalf but through providing us or your employer with a service on our behalf (such as our suppliers);
• to companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such information is shared;
• to any third party to whom we assign or novate any of our rights or obligations;
• to any prospective buyer in the event we sell or reorganise any part of our business or assets (see below); and/or
• to any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request.
SSP may disclose your personally identifiable information:
• for purposes of outsourcing one or more of the functions described above;
• to confirm or update information provided by you;
• to inform you of events, information about our services, and other important information;
• for other purposes disclosed at or before the time the information is collected; and/or
• when legally required to do so.

If you tell us you wish to attend an event, your name and organisation may appear on a list which we provide to other delegates at the event.

CONFIDENTIALITY
We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except that we may share information with our service providers for the purposes set out in this Privacy Notice. We will maintain the confidentiality of and protect your information in accordance with our Privacy Notice and all applicable laws.

HOW WE PROTECT INFORMATION
SSP is committed to keeping your information safe and will protect it against accidental and unlawful loss, misuse and alteration.  SSP has implemented appropriate administrative, technical and physical measures to protect your personal information.

YOUR RIGHTS
If you wish to:
• update, modify, delete or obtain a copy of the personal information that we hold on you; or
• restrict or stop us from using any of the personal information which we hold on you, including by withdrawing any consent you have previously given to the processing of such data,

you can make a request by writing to us using the contact details below. We endeavour to respond to such requests within a month or less, although we reserve the right to extend this period for complex requests.

We may require further information from you in order to verify your identity before disclosing any personal information to you or carrying out your request.

TRANSFERRING INFORMATION WHEN THERE IS A CHANGE TO OUR BUSINESS
If in the future we re-organise or transfer all or part of our business we may need to transfer your information to new SSP entities or to third parties through which the business of SSP will be carried out.

INTERNATIONAL TRANSFERS OF PERSONAL DATA
The personal information we collect from you may be transferred to (including accessed in or stored in) a country or territory outside the European Economic Area (“EEA”), including to countries whose laws may not offer the same level of protection of Personal Data as are enjoyed within the EEA.

We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the GDPR.

IF YOU DO NOT WANT TO RECEIVE INFORMATION FROM US
If you receive marketing materials from us, you may withdraw your consent for us to send these to you at any time by writing to us at 80 Pall Mall, London SW1Y 5ES or sending an e-mail to jessica.palandri@smithsquarepartners.com.

HOW LONG WE WILL HOLD YOUR PERSONAL INFORMATION FOR
We will only retain your personal information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

CHANGES TO THIS NOTICE
From time to time, we may change this notice. Changes to this notice are effective as of the effective date set out at the beginning of this notice and indicates the last time this notice was revised or materially changed.  Your continued use of this website indicates your consent to the changes to this notice.

CONTACT INFORMATION
If you have any questions in relation to this Privacy Notice, or if you would like to contact us to exercise your rights as stated in this Privacy Notice, you may contact us at 80 Pall Mall, London SW1Y 5ES or jessica.palandri@smithsquarepartners.com.

SSP is registered with the UK Information Commissioner’s Office under the following ICO Registration Number: ZA255280.

HOW TO LODGE A COMPLAINT TO THE REGULATOR
You are entitled to lodge a complaint with our data protection regulator if you consider that we have breached your data protection rights. Our data protection regulator is the Information Commissioner’s Office, which can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.