Ely Place Partners Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Ely Place Partners Limited is a Limited company registered in England and Wales under company number 11427265
Registered address: 111 Camden Street, NW1 0HX, London, UK
Ely Place Partners Limited is an appointed representative of Resolution Compliance Limited, which is authorised and regulated by the Financial Conduct Authority (FCA reference 574048).
What does this notice cover?
This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
We may revise this Notice at any time by updating this page. You should check this page from time to time to ensure you are happy with any changes.
What Is personal data?
Personal data is defined by the General Data Protection Regulation (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
What are your rights relating to your personal data?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
What personal data do we collect and use?
Ely Place Partners Limited will collect certain personal data about you in connection with its business dealings (including potential business opportunities). Examples of personal data we collect include, but is not limited to, your name, position, e-mail address, business address and telephone number. Where we are legally required to carry out customer due diligence checks for KYC (Know Your Customer) or other purposes, we will request documents that confirm your identity. These are documents that show your name, a photograph, residential address and date of birth. These checks may involve collecting and holding documents such as (but not limited to) copies of passports, utility bills, bank statements and other official documents.
We will not collect any personal data from you that we do not need.
What are the grounds for collecting and using your personal data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data.
Ely Place Partners Limited relies on the following legal grounds to collect and hold your personal data, namely:
- Consent – we may or may not need your consent to use your personal data. You can withdraw your consent at any time by contacting us.
- Performance of a contract – we may need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you.
- Legitimate interest – we may use your personal data for our legitimate business interests (see paragraph 7 for further details)
- Compliance with law or regulation – we may collect and use your personal data in order to comply with applicable law or regulation.
How do we use your personal data?
Ely Place Partners Limited will collect and hold personal data for use in connection with:
our legitimate business interests; conducting our financial services business and performing internal business processes; providing the services you (or another individual on your behalf) have requested and providing you with information relating to the provision of such services; recruitment; continually improving the services that we provide, and complying with our legal obligations.
We will not use or disclose your personal data for any purpose other than those described above without your consent unless required or authorised by law.
We do not envisage that any decision will be taken about you using automated means.
Where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone or post (to your business address) with information and news relating to our services. This does not apply where your personal data (e.g address) is collected solely for KYC purposes, which will be held and shared if needed with our Principal, Resolution Compliance Limited. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How long will we keep your personal data?
We will not keep your personal data any longer than is necessary in light of the reason(s) for which it was first collected. When we no longer need it, we will securely delete or anonymise your personal data unless we are required to retain a copy under applicable law, including any regulations imposed from time to time by the Financial Conduct Authority. To determine the appropriate retention period for your data, we consider the amount, nature, and sensitivity of your data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal requirements. In relation to personal data collected as part of our due diligence/KYC checks, we are legally required to keep this personal data for a period of 5 years from the date our business relationship with you ends.
Who do we share your personal data with?
We may share your personal data with selected third parties where we have your explicit consent or it is necessary for, (i) the performance or provision of the services you have requested; (ii) us to comply with our legal obligations; or (iii) our legitimate business interests.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
- Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) include notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
How can you access your personal data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email address shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Daniel Roddick.
Email address: firstname.lastname@example.org