Threadmark Partners Limited (together with its affiliates, Threadmark LLP in London and Threadmark LP in New York) is a financial advisory firm headquartered in London. Threadmark Partners Limited and Threadmark LLP are authorised and regulated by the Financial Conduct Authority. Threadmark LP is a member of FINRA / SIPC. Contact details for our offices can be found on our website www.threadmark.com.
PURPOSE OF THIS NOTICE
Threadmark Partners Limited and its affiliates (“Threadmark”, “we”, “us”, “our” and “ours”) act as controllers in respect of your personal information. This notice explains how Threadmark may collect, use and disclose information about you, and describes the rights you may have in respect of your personal information in accordance with the provisions of European data protection laws. Please read it carefully.
This notice applies to you if you are based in the European Economic Area (the “EEA”), except if solely for travel purposes.
INFORMATION WE COLLECT ABOUT YOU
We may obtain personal information about you in connection with our business dealings.
For example, we may collect:
- Information you provide to us, such as when you use the “Contact Us” form on our website or when we meet in person, including your name, email address, phone number, employer name and job title, and details of your investments and dealings with us;
- Details of the correspondence and communications we have had with you in relation to our business activities;
- Website and communication usage, namely certain information that we collect through cookies and other tracking technology when you visit our website, including but not limited to your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communications that you access;
- Marketing preference information, namely details of your marketing preferences (e.g. communication preferences) and information relevant to selecting appropriate products, services and communications to offer you;
- Information from third party sources, such as information that we collect from publically available sources, including LinkedIn, Preqin, your company website and Companies House.
Such personal information is held solely for the purpose of conducting our business activities. We will not sell your personal information to third parties.
When you visit our website, we may collect certain information (including IP addresses) through automated means, such as cookies. Cookies are files created by a website that may be temporarily or permanently transferred to your device. Cookies provide a way for the website to recognize you and keep track of your preferences. Our website will issue cookies when you log onto it unless you choose to disable cookies on your internet browser.
We may use third-party web analytics services on our website, such as Google Analytics, which help us analyse how visitors use the website. The information obtained for this purpose will be collected directly by such service providers.
HOW WE USE THE INFORMATION WE OBTAIN
When we collect your personal information, we can use or disclose it for the following purposes. Below each purpose we note the “legal ground” that allows for that use of your personal information, which we are required to inform you of under European data protection law. The legal grounds that we typically rely on for these purposes are:
Consent: where you have consented to our use of your information (you will have been presented with consent language in relation to any such use and may withdraw your consent by contacting us as set out in the “Contact Us” section).
Contract performance: where your information is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
- To provide and manage products and services you have requested. To administer our services, including carrying out our obligations arising from any agreements entered into between you and us and making relevant introductions in connection with our placement activities.
Legal ground: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to your or notify you about changes to our service)
- To provide you with information, products or services which may be of interest to you. To provide you with details of investment opportunities or provide you with information about products and services that we offer that we think may be of interest to you. Where required by applicable law, we will ask you for your consent for such communications. You will have the right to withdraw your consent by contacting us as set out in the “Contact Us” section.
Legal ground: legitimate interests (to keep you updated with news in relation to our products and services), consent
- To communicate effectively with you. To communicate with you, including to respond to your enquiries or to notify you about changes to our services and products.
Legal ground: contract performance, legitimate interests (to enable us to notify you about changes to our service and communicate with you)
- To comply with legal or regulatory requirements. We may process your personal information to comply with our regulatory requirements or dialogue with our regulators or to defend or prosecute claims, as applicable. As a regulated firm, this will include undertaking certain fraud and background checks in relation to our clients. If false or inaccurate information is provided and/or fraud is identified or suspected, then details may be passed to fraud prevention agencies and recorded by us or them.
Legal ground: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities), substantial public interests
- To reorganise or make changes to our business. In the event that we are subject to negotiations for the sale of our business or part thereof to a third party, sold to a third party or undergo a reorganisation, we may need to transfer some or all of your personal information to the relevant third party (or their advisers) for the purposes of due diligence or otherwise in connection with the sale.
Legal ground: legitimate interests (to allow us to change our business)
In some cases, if you do not provide your information, we may not be able to provide services or products to you. We will notify you should it be necessary to use your personal data for a purpose other than for our current business activities as set out above.
In addition to those parties mentioned above, we may share your personal information with third parties for the purposes, and on legal grounds, set out above. Such third parties include:
- Threadmark affiliates. We may share your personal information within the Threadmark group, including to locations outside of the EEA where we do business.
- Companies we introduce you to. We may share your personal information with third parties that we connect you with in connection with our placement activities.
- Law enforcement agencies. We may provide personal information to third parties, including anti-fraud organizations, legal, regulatory, or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities, or to comply with a court order.
- Sub-contractors and agents. We may use other companies on our behalf to process your personal information, such as for account administration, fraud prevention and detection and marketing. Many of these third parties process your personal information on our behalf.
DATA RETENTION & STORAGE
We will retain your personal information for as long as it is needed to fulfil the purposes for which it is collected, and any other permissible, related purposes. For example, we may retain certain data to comply with regulatory requirements regarding the retention of data.
The information we store about you will be made available to our staff in the United Kingdom and the United States. We may also transmit your information to third parties in a destination outside of the EEA. Where this is the case, we may be required to take reasonable steps to ensure that your data is protected in the same way as if it was being used in the EEA. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals, we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses or other legal grounds permitted by applicable legal requirements.
Please contact us using the details in the “Contact Us” section. If you would like to see a copy of the specific safeguards applied to the export of your personal information.
We have put in place commercially reasonable and appropriate technical and physical security measures to protect your personal information from accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure and use.
We have agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.
Under European data protection law, you may have the following rights in relation to your personal information. In particular, under certain conditions, you may have the right to:
- require us to provide you with further details on the use we make of your information;
- require us to provide you with a copy of information that you have provided to us;
- require us to update any inaccuracies in the personal information we hold;
- require us to transmit the personal information that you provided to us to a third party electronically;
- require us to delete any personal information that we no longer have a lawful ground to use;
- where processing is based on consent, withdraw your consent so that we stop that particular processing;
- object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
- object to direct marketing (including profiling related to marketing); and
- restrict how we use your information whilst a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you want to exercise your rights, or wish to make a complaint on how we have used your personal information please do so by contacting our Compliance Officer either in writing to Threadmark Partners Limited, 24 Grosvenor Street, London W1K 4QN or via [email protected].
You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues at www.ico.org.uk/concerns or contact their helpline on 0303 123 1113.
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