Privacy Policy

BEECHBROOK CAPITAL LLP, BEECHBROOK UK SME CREDIT LTD AND BEECHBROOK CAPITAL GERMANY UG

PRIVACY NOTICE

1. About this notice

This notice (the “Privacy Notice”) provides information about how Beechbrook Capital LLP, Beechbrook UK SME Credit Ltd and Beechbrook Capital Germany UG (together, “we”, “us”, “our”) gather and use personal information through our website. If you are an investor in one of our funds, you should refer to the privacy notice provided in your subscription documents for information about how data is collected and processed in relation to the fund. We are committed to respecting the confidentiality of the personal information you supply to us and all data will be processed in accordance with applicable data privacy laws.

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Notice.

If you do not agree with our use of your personal data as set out in this Privacy Notice, you should not submit your personal information to us. However, if you do not wish to submit your personal information, or if you wish to exercise your rights to prevent us using your data, you should be aware that we may not be able to do business with you.

2. About us

We are:

Beechbrook Capital LLP (company number OC337678), registered at 2nd Floor 43-45 Dorset Street, London, W1U 7NA;
Beechbrook UK Credit SME Ltd (company number 09867215), registered at 2nd Floor 43-45 Dorset Street, London, W1U 7NA; and
Beechbrook Capital Germany UG (company number HRB 114578), registered at Zeil 127, 60313 Frankfurt am Main.

For the purposes of data privacy legislation, we will each be a ‘controller’.

3. Contacting us

Should you have any questions or concerns about this Privacy Notice or how we process your personal data:

For our customers who are in the UK please contact Alan Chu at:

By post:	First Floor, 38 St Martin’s Lane, London WC2N 4ER
By phone:	+44 (0)20 3551 5965
By email:	alan.chu@beechbrookcapital.com

For our customers who are within the EEA, please contact Peter Gottron at:

By post:	Zeil 127, 60313 Frankfurt am Main, Germany
By phone:	+44 (0)20 3551 5965
By email:	peter.gottron@beechbrookcapital.com

4. Your rights

You have certain rights in relation to your personal data.

4.1 Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see above).
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.

Please contact us using the details at section 3 if you want to exercise any of these rights. In most cases these rights are not absolute and are subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.

We will respond to your request within one month of receipt of your request. In some cases we may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.

4.2 Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

4.3 Fees

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.

4.4 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

4.5 Right to complain

If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, please contact us on the contact details contained in section 3.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/ or 0303 123 1113.

5. Information we collect

We collect your personal information from a variety of sources, as set out in this Privacy Notice. Where necessary we collect information directly from you or indirectly from third parties, through publicly available sources and through your use of our website (beechbrookcapital.com).

5.1 Information you provide to us

This section details the information we collect about you in the course of your use of our website and otherwise in your interaction and correspondence with us and our representatives. We will collect:

“Identity Data”	basic personal details such as your name and the name of your company.
“Contact Data”	email and postal addresses and telephone numbers.
“Technical Data”	technical information relating to your use of our website, such as your IP addresses, browser type, time zone setting and location.
“Usage Data”	information about how you use our website, such as how often you access it, how long you spend on it and how you navigate around it.
“Cookie Data”	in relation to your behavioural information (please refer to our Cookies Policy for further information.
“Due Diligence Data”	includes data we are required to collect in order to comply with KYC, AML or other regulatory or internal policy requirements (such as information in relation to politically exposed persons and sanctions checks, your assets and/or income and/or financial dealings). In limited circumstances, such data may include “Special Categories of Personal Data” (which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) and information about criminal convictions and offences.
“Record Data”	records of communications including recordings of phone calls (both mobile and landline) and electronic communications with our staff.

5.2 Failing to provide personal data

If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract 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. We will notify you if this is the case at the time.

6. How we use the information we collect

6.1 General uses of information

The information which we collect and what we use it for will depend on the nature of our business relationship with you. We will only use your personal data when have a lawful basis to do so. Most commonly, we will use your personal data in the following circumstances:

where we need it to perform the contract we are about to enter into or have entered into with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
where we need to comply with a legal obligation; and/or
where you have given us your consent to process the data for a particular purpose (for example to receive marketing communications (see section 6.2 below)).

6.2 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Type of data	Purpose/Activity	Lawful basis for processing including basis of legitimate interest
Identity Data Contact Data	To manage our relationship with you.	For the performance of a contract we have entered into with you. To comply with a legal obligation. For our legitimate interests in running our business and keeping our records updated.
Usage Data Cookie Data Technical Data	To administer, improve and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	For our legitimate interests in improving our business, keeping our website updated and relevant, and the administration of IT services and network security.
Cookie Data Technical Data	To improve our website or services or to customise the website according to your interests.	For our legitimate interests in keeping our website updated and relevant, to develop our business and to inform our marketing strategy.
Identity Data Contact Data	To send you promotional emails about educational events and other information which we think you may find interesting or to contact you for market research purposes.	For our legitimate interests in developing our products and services and growing our business. You having provided us with your consent to processing your data for this purpose.
Due Diligence Data	To carry out due diligence and background checks.	To comply with a legal obligation. For our legitimate interests in preventing fraud and promoting the integrity, reputation and values of our business. You having provided us with your consent to processing your data for this purpose.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for any other purpose than those already notified to you, we will notify you and we will explain the legal basis which allows us to do so.

6.3 Information for marketing purposes

We use your information to identify products, services and events that we think may be of interest to you.

We will only send you marketing messages where you have consented to such contact, or in the case of products and services, where these are similar to those that we have already provided to you.

You have the right to ask us not to not send you marketing messages by post, telephone or e-mail or any combination of these at any time. You can also let us know at any time that you wish to change your mind and to start receiving such messages.

You can do this:

by replying directly to the marketing message;
in case you wish to withdraw from all marketing communications, you can also unsubscribe from all marketing by clicking the appropriate link in any email you receive; or
at any time by contacting us (see section 3).

7. Sharing your information

We will not disclose your personal information to third parties except as detailed in this Privacy Notice:

Where necessary, we disclose your personal data to third parties that are specifically engaged by us to provide services. In which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us.
We may also disclose to law enforcement agencies and regulators, government departments or competent authorities of the UK or of other countries any personal data (including tax status, identity or residency or other personal and payment information, documents or self-certifications) where we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation, or if we reasonably consider that this is necessary to help prevent or detect fraud or other crime or to protect our rights, property, or safety, or that of our customers or others. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf;
if we are under a duty to disclose or share your information with HM Revenue & Customs (HMRC) or other tax authorities, who may transfer it to the government or the tax authorities in another country where you may be subject to tax. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf; and
if you have consented to any disclosure to a third party.

8. Where your information is processed

Your personal information may be processed by staff operating outside the UK who work for us or by our service providers (for example, those who supply support services to us), and the laws of some of these destination countries may not offer the same standard of protection for personal information as countries within the UK.

We will, however, put in place appropriate security procedures in order to protect your personal information. Where your information is transferred to any country outside the UK, we ensure that this is done using specific legally approved safeguards. You can request further details and a copy of these safeguards by contacting us (see section 3).

9. Keeping your information

We will keep your information only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal information are available in our retention policy which you can request by contacting us.

When determining the relevant retention periods, we will take into account factors including:

our contractual and business relationships with you;
legal obligations under applicable law to retain data for a certain period of time;
statute of limitations under applicable law(s);
(potential) disputes; and
guidelines issued by relevant supervisory authorities.

10. Security

We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

In addition, those employees, agents, contractors and other third parties who process your personal data will only do so on our instructions and they will be subject to a duty of confidentiality.

Although we will do our best to protect your personal data any transmission is at your own risk as we cannot guarantee the security of any data transmitted via the internet. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.

11. Links to other websites

Links on our website may take you to third party sites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy notices on those linked websites. We are not responsible for any linked websites.

12. Changes to this Privacy Notice

We reserve the right, at our discretion, to change, modify, add to, or remove portions from, our Privacy Notice. We will of course notify you of any changes where we are required to do so.

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