1.       Introduction

Your privacy is protected by law. Fiduciary Co-investment Partners LLP (“FCP”) has committed to compliance with all relevant UK and EU laws in respect of personal data, and to protecting the “rights and freedoms” of individuals whose information FCP collects in accordance with the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018). We are committed to protecting any information from which you can be identified ("personal information") that you share with us.

This policy explains how we use your data and how we protect you. It also tells you about your privacy rights and how the law protects you.

This control applies to all systems, people and processes that constitute the organisation’s information systems, including partners, employees, advisers, suppliers and other third parties who have access to FCP’s systems.

2.       Your Personal Data

2.1 Collecting Your Personal Data

The primary lawful basis we rely on for processing your data is that we have a legitimate interest in doing so as we are communicating with you in a professional capacity for a legitimate business or commercial reason which is not outweighed by your rights and freedoms. In some instances we may require sensitive personal data from you, including for example, dietary or accessibility requirements to attend an event, in which case we rely on the need to protect your vital interests and/or your explicit consent for such processing.

We may collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications or services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, your IP address, your browsing history and your web log information). We may do this using cookies or similar technologies.

We may collect personal information about you from your organisation’s website or other professional websites.

We may receive information from third parties who collect personal information from you and pass it on to us.

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

2.2 Accessing and updating your personal information

Under the UK GDPR, you have certain rights regarding the personal information that we hold on you and these are:

1.       The right to be informed about the data we hold on you

2.       The right of access to the data we hold on you

3.       The right to have your personal information rectified if it is inaccurate or incomplete

4.       The right to have your personal information erased

5.       The right to request the restriction of the processing of your personal information in certain circumstances

6.       The right to obtain and reuse the personal information we hold relating to you in a portable format in certain circumstances

7.       The right to object to certain forms of processing of your data by us

8.       Rights in relation to automated decision making and profiling of your data by us and our 3rd party data processors. 

You can manage your privacy settings within your browser or you can contact us at csiniscalco@fc-partners.com if you want to exercise any of the above rights. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner's Office regarding such issues. You may choose not to give personal information but we may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us the required personal information, it may delay or prevent us from meeting our obligations. It may also mean that we will not be able to perform activities needed to run services for you. It could also mean that we cancel a service you have with us. Any data collection that is optional will be made clear at the point of collection.

3.       Our commitment to privacy of your data

It is FCP’s policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant Data Protection Authority (DPA) will be informed within 72 hours.

The following actions are undertaken to ensure that FCP complies at all times with the accountability principle of the GDPR:

The legal basis for processing personal data is clear and unambiguous

  • All staff involved in handling personal data understand their responsibilities for following good data protection practice

  • Training in data protection has been provided to all staff

  • Rules regarding consent are followed

  • Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively

  • Regular reviews of procedures involving personal data are carried out

  • Privacy by design is adopted for all new or changed systems and processes

  • We will only send your data outside of the UK to:

    • Follow your instructions;

    • Comply with a legal duty; or

    • Obtain services from an employee, advisor or supplier based outside the UK or obtain advice from an advisor based outside the UK.

 If we do transfer information to our suppliers, agents or advisers outside of the UK, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and applicable data protection laws when it is processed in, or other accessed from, a location outside the UK. This means that we will only transfer your personal information to third parties outside the UK if that third party (a) is situated in a country that has been deemed to provide an adequate level of protection for personal data, or (b) has agreed (by way of written contract) to provide all protections to your personal information as required by applicable data protection laws.

We may change our Privacy Policy from time to time. However we will not reduce your rights under this Privacy Policy. We will always update this Privacy Notice on our website, so please try to read it when you visit the website.

Fiduciary Co-investment Partners LLP (FRN: 800704) is an appointed representative of Access Equity Management Limited (FRN: 207801) which is Authorised and regulated by the Financial Conduct Authority.