Privacy notice - non-profit activities

This Privacy Notice (Notice) explains how Patron Capital Advisers LLP (Patron Capital, we, our, us) processes the personal data of investors (you, your) in relation to its charitable activities, and your rights in relation to the personal data we hold.

Patron Capital is the data controller of your personal data and is subject to the Data Protection Act 1998 (DPA) and, once in force, EU General Data Protection Regulation 2016/679 (GDPR).

Patron Capital is registered as a data controller with the UK Information Commissioner's Office under registration number Z2745781.

This Notice was updated on 25th May 2018 and supersedes any previous privacy notice or similar terms provided by, or on behalf of, Patron Capital in relation to charitable and non-profit activities. For the avoidance of doubt, it does not supersede any privacy notice or similar terms in relation to investor activity.

If you have any questions about your rights or how your personal data is used by Patron Capital, you should contact the Data Protection Representative using the details below:

Post - Kendall Langford
One Vine Street
London
W1J 0AH
Email - legal@patroncapital.com
Telephone - +44 (0)207 629 9417

How your personal data is collected

We collect your personal data in the following ways:

From meetings, correspondence or other communications you have with us;
From the website (www.patroncapital.com) (for example when you log into the Investor Portal). For further information see our Privacy and Cookie policy for the website (http://patroncapital.com/privacy-and-cookie-policy);
From publicly available sources or from other third parties (most commonly where we need to conduct background checks about you).

The categories of personal data collected

The following categories of personal data about you are collected by us in relation to our charitable activities:

Name, and contact information (such as residential address, email address and telephone number); and
Information about your background including occupation, educational information and interests.

The basis for processing your personal data, how that data is used and whom it is shared with

(i) Legitimate Interests
We may process your personal data because it is necessary for our legitimate interests. Our "legitimate interests" include our charitable activities to provide information on and raise awareness in respect of a number charities and non-profit initiatives.

In this respect, personal data will be used by us for marketing purposes. Please see the separate section on Marketing below;
In this respect your personal data may be shared with the following:
- Charities, individuals and initiatives that Patron Capital supports; and
- Third parties who assist us with our charitable activities.
- Our advisers (such as lawyers and accountants) where it is necessary to obtain their advice or assistance.
We may film, photograph or otherwise record events and publish such content on our website, social media accounts and other formats where it would not be necessary, appropriate or practicable to obtain your specific consent (for example, we may seek specific consent for prominent or impactful issues, but typically not for group shots, background inclusion or internal use).

Marketing

We will send you information about our charitable activities, initiatives, seminars and lectures.

If you object to receiving marketing in relation to such activities from us at any time, you should contact us using the details below:

Post - Kendall Langford
One Vine Street
London
W1J 0AH
Email - legal@patroncapital.com
Telephone - +44 (0)207 629 9417

International transfers of data

When sharing your personal data with third parties as set out in this Notice, some of those third parties may be located outside the European Economic Area (EEA). In these circumstances, your personal data will only be transferred on one of the following bases:

The transfer is to a recipient that has entered into European Commission standard contractual clauses with us;
The transfer is subject to an Adequacy Decision made by the European Commission; or
You have explicitly consented to the transfer.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of any standard contractual clauses which Patron Capital has entered into with recipients of your personal information) by contacting the Data Protection Representative using the details set out above.

Retention of your data

We will retain your personal data for a period of seven years following the date on which you cease to be involved or interested in our charitable activities, unless that personal data is required to be retained for a longer period by reference to an applicable law or regulation.

However, where there is a relationship between you and us after that time, we will retain such of your personal data as is necessary, and for such reasonable additional period, in order to maintain that relationship.

Your rights

Prior to 25 May 2018, you have the following rights:

To obtain access to, and copies of, the personal data we hold about you;
To require that we cease processing your personal data if the processing is causing you damage or distress;
To require us not to send you marketing communications;

Once GDPR comes into force, from 25 May 2018 you will also have the following additional rights:

To require us to erase your personal data;
To require us to restrict our data processing activities in relation to your personal data;
To receive from us the personal data we hold about you, which you have provided to us, in a reasonable format specified by you, including for the purpose of transmitting that personal data to another data controller; and
To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and requests may be refused where exceptions apply.

If you are not satisfied with how your personal data is used by us you can make a complaint to the Information Commissioner (www.ico.org.uk).