For the purposes of the Data Protection Act 2018 the data controller is Adelpha Capital Ltd of 27 Old Gloucester Street, London, WC1N 3AX, UK. We are registered with the Information Commissioner’s Office (ICO) to process your personal data and our registration number is ZA328152.
2. What Personal Data we collect
When we refer to “personal data" we mean information about an individual from which that person can be identified. This does not include data where the individual’s identity has been removed.
We may collect, use, store and transfer the following types of data:
Contact Data: Full name, postal address, email address and contact telephone numbers;
ID Verification Data: Details of and/or copies of your passport, drivers licence, firearms licence, utility bill, home phone bill, bank statement, credit card statement and signature;
Transaction Data: The payments you make to us, details of the bank account they were sent from, your account balance, interest and workings, the products you purchased from us and estimated net worth;
Account Data: Your username and password and your security questions and answers;
Marketing and Communications Data: Your preferences in receiving marketing as well as your preferred form of communication;
Technical Data: Information about how you use our site (e.g. URL), your internet protocol (IP) address, operating system and platform, browser type and version, time zone setting, location data, information on how long you visit each page, cookie data and other identifying information required for your device to communicate with our site.
We will not necessarily collect all of the above data about you. For example, if you are merely visiting our site then we will usually just collect Technical Data about you and your device. If you decide to sign up for newsletters and offers then we will collect Contact, Marketing and Communications data from you. Where you decide to become an investor then we would need to collect the above as well as ID Verification, Transaction and Account data.
The above data may not always be considered personal data. For example, much of the Technical data we collect is aggregated data, and it is not usually classified as personal data because it does not reveal your identity to us. If we link aggregated data to your personal information, it will be treated as personal data in line with this policy.
We do not process any “special categories" of personal data about you (i.e. information about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
We try to be sure that the personal data we hold about you is accurate, and so please get in touch with us if your personal data changes so we can update our records. You can contact us using the details at the beginning of this policy.
3. How we collect your data
We collect personal data about you from a number of different sources depending on who you are and what personal data it is. For example, we collect personal data:
From you directly: when you submit an application form to us; purchase products or services from us; and correspond with us by post, phone, email, through social media, or otherwise;
From third parties: we work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them;
From publicly available sources: such as Companies House, the Land Registry, Bankruptcy Register and the Electoral Register; and
From your device: when you access our site.
4. How we use your Personal Data
We will only use your information where we have a lawful basis to do so. We set out below how we plan to use your personal data and the lawful basis that we rely on:
To contact you;
To verify your identity, prevent/detect money laundering and fraud;
To register you as a new customer;
To manage our relationship with you including any account you have with us, dealing with any questions or complaints you may have;
To provide you with information about other products / services that we believe may be of interest to you;
To operate our site (e.g. troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
To improve the products we offer and to carry out internal training; and
To comply with our legal and regulatory obligations and internal corporate governance rules.
5. Disclosure of your information
We may share your personal data with the following third parties for the purposes set out in the table above:
Services providers including identity verification providers, anti-money laundering providers, data storage and shredding services providers;
Financial or payment processors where you are trying to arrange a payment to or from us;
Contractors who help us to provide you with services, such as IT, cloud, telecommunications, security, client relationship management and system administration services;
Marketing, communications, advertising and public relations suppliers;
Professional advisers, such as auditors, accountants and solicitors;
Our Group Companies and ultimate shareholders;
Your professional advisers (if you have requested and authorised us to do so);
HM Revenue & Customs, National Crime Agency, local authorities, law enforcement agencies, regulators and other authorities (both inside the UK and outside of the UK);
The Financial Conduct Authority, Bank of England, and the Financial Ombudsman Service in relation to our regulatory obligations as a financial institution; and
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this policy.
6. Where we store your Personal Data
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. Retention Period
We store your personal data for different periods of time depending upon the purposes for which we collected it and we do not store your personal data for longer than is necessary to fulfil these purposes. We retain your personal data throughout our relationship with you, and usually for up to 7 years after your final investment with us has finished or you have closed your account.
Please be aware that as a financial institution, we may need to retain your personal data for longer in order to comply with our legal, regulatory and accounting obligations.
In order to determine how long we store your personal data for, we take into consideration why we need to continue to store your personal data, whether we can achieve the same result without having access to your data, and what the potential risk is if there is a data breach that affects your data.
Occasionally we may anonymise data which means that it is no longer associated with you. We do this for statistical or research purposes, so we can improve the services we offer to you. We can use anonymous data indefinitely without further notice to you.
8. Your rights
You have the following rights over your personal data:
To ask us for details of the personal data we hold and process about you (this is usually called a subject access request);
To ask that any inaccurate information we hold about you is corrected;
To ask that we delete personal data we hold about you;
To ask that we stop using your personal data for certain purposes;.
To ask that we do not make decisions about you using completely automated means;
To withdraw your consent; and
To ask that we give you the personal data we hold about you, or (where technically feasible) that we give this personal data to a third party chosen by you, in a commonly-used machine-readable format;
These rights are not available to everyone all the time. Some are subject to exemptions, and so we may not always be able, or required, to comply with your request to exercise these rights. Further details about your rights can be found on the ICO’s website:
To exercise any of the above rights, please contact us and provide us with as much information as you can so we can respond as soon as we can. We may ask you to provide proof of identity (for example, your passport or driving licence) before we fully respond as we have to be sure we are giving the correct personal data to the correct individual.
We can be contacted at:
FAO: Information Officer
Adelpha Capital Ltd
27 Old Gloucester Street
We usually respond to data subject requests within one month, but it can take longer if your request is particularly complex or if you have made a number of requests. You will not usually have to pay a fee, but we reserve the right to charge a fee if your request if clearly unfounded, repetitive or excessive; alternatively we may refuse to comply with your request.
You also have the right to complain to the ICO, the UK supervisory authority for data protection issues. Before exercising this right, we encourage you to contact us first to resolve any complaint you may have, although this is not legally required. More details can be found here: www.ico.org.uk.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
8. Policy updates
We reserve the right to update this policy to reflect any changes to the way in which we collect, process or share your personal data, or to reflect any legal requirements. When we make any changes, we will upload the new version to our site. The new version will take effect as soon as it is uploaded.
This policy was last amended on January 22nd, 2020 and supersedes any earlier versions.