Elaghmore Advisor LLP (“Elaghmore”) Privacy Notice
For the purposes of applicable legislation and regulations including the GDPR and Data Protection Act 2018 (“Data Protection Laws”) Elaghmore is the controller of your personal information.
This privacy notice provides information on how Elaghmore collects and processes your personal data.
Personal information: business contacts
If you have interacted with Elaghmore, whether through email, meetings, or otherwise, we will have obtained and may process limited amounts of your personal information. This might include your name, job title, date of birth, employer organisation and/or contact details (including address). We do this for the purposes of:
- providing business updates (further described below);
- managing your relationship with us;
- maintaining a list of contacts;
- organising meetings; and
- Reviewing and exploring potential deals.
In accordance with the Data Protection Laws, our legal basis for collecting and storing such personal information is that such processing is necessary for our legitimate interests in connection with the operation and running of our business.
Personal information: actual or potential management teams
If you are involved in a transaction that Elaghmore enters into, or is contemplating, we may process certain limited amounts of your personal information.
This might include information relating to your financial status and dealings, your CV, details of your previous employment history and professional activities, your nationality (including copies of identity documents, such as your passport), references provided by third parties, and results of other reasonable and proportionate due diligence we may have conducted. We collect and store this information for the purposes of:
- evaluating potential transactions;
- keeping records of assets and investments;
- managing your relationship with us;
- assessing your suitability for involvement in a transaction;
- meeting with our regulatory/legal obligations;
- administering any transaction that we are involved with;
- safeguarding our own legal rights and interests;
- receiving advice from our professional advisors; and
- providing business updates (further described below).
As required under the Data Protection Laws, our legal basis for collecting and storing such personal information is that such processing is necessary for our legitimate interests in the running and operation of our business, in particular in order to properly review potential investments, and administering any and all transactions that we are party to. The length of time such personal information will be held will depend on why it was collected initially. The requirements of applicable laws or regulations will also affect this.
Keeping your information
We will only use and store your information for as long as it is required for the purposes it was collected for. How long it will be stored for depends on the information in question, what it is being used for and, sometimes, statutory legal requirements.
Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device.
Sensitive or special category personal data
Please be aware that different rules apply to data concerning certain sensitive categories, including 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. All such categories are deemed to be either sensitive or special category personal data. We kindly ask you not to send us such information. If such information is sent in error then it will be deleted on identification.
Disclosures of your personal data
We may from time to time share your personal data with third parties where it is reasonable and necessary for us to do so in connection with our dealings and interactions with you.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may use personal information that we hold to send you periodic updates about Elaghmore’s business, activities and opportunities, in particular, by email. You can opt out of receiving updates at any time by contacting us via the information tab on our website.
Accuracy and security
Elaghmore will take reasonable steps to maintain the accuracy of your personal information.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a genuine business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We do not transfer your personal data outside the European Economic Area (EEA).
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).
You can request that Elaghmore update or correct any information by contacting us via the information tab on our website.