Website privacy notice
We at Stephenson Harwood LLP ("SH", "we", "us", "our") operate our website, www.shlegal-privatecapitalfunds.com, (the "Site"). "SH Group" means Stephenson Harwood LLP and other partnerships, corporations and undertakings which are authorised to carry the name "Stephenson Harwood"; and a "member of the SH Group" has a corresponding meaning.
It is important to us that we protect the privacy of personal information and for you to know what type of information we collect and how we treat information we may receive from you. We detail below how we collect personal information about you from your use of the Site.
This Privacy Notice should be read alongside our Website Terms and Conditions and the definitions in the Website Terms and Conditions also apply to this Privacy Notice.
Purposes of processing and use of your personal information
We may collect and store certain types of personal information about you when you use the Site. This includes information you provide when subscribing to receive data protection updates via the Site. We may also automatically collect information by using cookies, server logs and other similar technologies. The information given to us, or collected by us, may include the categories of personal data set out below.
|Purpose||Categories of personal data||Legal basis for processing|
|To provide you with a safe, smooth, efficient and customised user experience||Our processing of your personal data is on the basis of your consent; as is necessary for compliance with a legal obligation to which we are subject; or as is necessary for the purposes of legitimate interests pursued by us, which are to ensure the proper and complaint operation of our Site|
|To make sure you receive updated information on SH's business activities / subscribe you to our newsletters or updates||Our processing of your personal data is on the basis of your consent or as is necessary for the purposes of legitimate interests pursued by us, which are to promote our business, activities and updates|
|To ensure that the content on the Site is presented in the most effective manner for you and your device||Our processing of your personal data is on the basis of your consent|
|To allow you to participate in any features on the Site when you choose to do so||Our processing of your personal data is on the basis of your consent|
|For our own research to understand our users and how they use the Site||Our processing of your personal data is on the basis of your consent|
Where we are processing your personal data on the basis of consent, you may withdraw your consent at any time, as detailed in the Privacy Notice. Withdrawing your consent will not affect the lawfulness of the processing conducted before withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
Disclosure of personal information
Except as expressly set out in this Privacy Notice we do not share, sell, or lease personal information about you to any third parties for their marketing use.
We may disclose personal information to provide our services, respond to legal requirements, enforce our policies and protect our rights and property. The personal information you provide to us may also be shared with the SH Group if this is necessary to provide you with our services or for any other related purposes.
We may also provide third party service providers access to information where they support or provide services to us. We will ensure that if we share information with, or provide access to, third party service providers, any such disclosure or access is at all times in compliance with data protection legislation.
We may also share your personal information with:
- the SH Group;
- third parties who support our information technology or handle mailings or events on our behalf;
- law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site, our technology assets or the rights, property or personal safety of any person); and
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
You have a number of rights concerning the way that we use your information. At any time, you have the right to:
- request access to or a copy of any personal data we hold about you;
- request the rectification of your personal data, if you consider that it is inaccurate;
- request the erasure of your personal data, if you consider that we do not have the right to hold it;
- object to your personal data being processed for a particular purpose or to request that we stop using your information;
- request not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data;
- ask us to transfer a copy of your personal data to you or to another service provider or third party where technically feasible; and
- ask us to stop or start sending you marketing messages at any time by using the below contact details.
Any request for access to or a copy of your personal data may be made orally or in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with applicable data protection legislation.
Security and storage of your information
Although we maintain physical, electronic, and administrative safeguards to protect your personal information from unauthorised or inappropriate access, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to us or provided though the Site.
Personal information that you submit may be sent to, and stored on, secure servers owned by or operated for us. If we collect personal information about you through the use of the Site we will only retain that information for as long as is reasonably necessary to fulfil the activity requested, or as may be required by law.
Your personal information may be transferred to, and stored at, a destination outside the UK or European Economic Area ("EEA") and may also be processed by staff operating outside the UK or EEA who work for us, the SH Group, or for one of our service providers.
When we, or our permitted third parties, transfer your information outside the UK or EEA, we or they will impose contractual obligations on the recipients of that data to protect your information to the standard required in the UK or EEA (as applicable). We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer your information where: (i) the transfer is to a country deemed by the UK Secretary of State or European Commission to provide adequate protection of your information; (ii) where you have consented to the transfer (to the extent permitted by applicable data protection legislation); or (iii) where such transfer is otherwise permissible under data protection legislation.
You also have the option of "unsubscribing" from our mailing list for updates at any time, thereby disabling any further such email communication from being sent to you. To unsubscribe just send an email to email@example.com with the word 'remove' in the subject line and the email address that you wish to be removed within the email. In addition, each electronic mailing we send you will contain details of how you can unsubscribe.
Please note that it may take up to one month to action your request.
We do not carry out automated decision-making or profiling in relation to your personal information.
What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a site. Cookies are then sent back to the originating site during your browsing session or on each subsequent visit, or to another site that recognises that cookie. The cookies we set do lots of different jobs, such as to help us to improve the Site and deliver a better and more personalised service, remember your preferences, and generally improve the user experience. You can find more information about cookies at http://www.allaboutcookies.org/.
The cookies we use on this Site can be categorised in accordance with the categories found in the ICC UK cookie guide, as set out below:
- Strictly necessary cookies – enable core functionality such as security, network management, and accessibility. They also make our Site easier to use by accelerating its display through load balancing. You can disable these by changing your browser settings, but this may affect how the Site functions. You cannot disable these using our cookies tool.
We use the following strictly necessary cookies:
Name Source Purpose Expiry CookieControl Civic This cookie is set in order to remember the user's preferences in regards to cookies. Persistent - expires after 90 days.
- Performance cookies – these cookies are set to provide enhanced functionality and make our Site easier to use, by remembering your preferences, including the preferences you have indicated on our cookies tool.
We use the following performance cookies:
Name Source Purpose Expiry _gid Google Analytics This cookie name is associated with Google Universal Analytics. It stores and updates a unique value for each page visited. Persistent - expires after 24 hours. _ga Google Analytics This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the Site's analytics reports. Persistent - expires after 2 years. _gat Google Analytics This cookie name is associated with Google Universal Analytics, according to documentation it is used to throttle the request rate - limiting the collection of data on high traffic sites. Persistent - expires after 1 minute.
Cookies can also be categorised in accordance with how long they are saved on your device: "session cookies" are short-term cookies that are only saved on the device's memory for the duration of a user's visit to the Site, whereas "persistent cookies" remain saved in the device's memory for a set period of time, even after the browser session has ended. The expiry period for each cookie is set out above.
Refusing or restricting cookies
You may refuse to accept, or withdraw your previous consent to, cookies in two ways:
- Our cookies tool, which you can access at the bottom left hand corner of our Site. Our cookies tool will record when you have consented to non-essential cookies. Essential cookies cannot be disabled using the tool because they are necessary to make the Site function. You may change your mind about the cookies you have selected through our cookies tool by updating your choices in our tool at any time. Please be aware that our cookies tool cannot be used to block cookies on third party websites linked to from our Site. In order to remove these cookies you will need to visit the relevant third party site and follow the instructions in their cookie notices. Alternatively, follow the instructions below to turn off these cookies using your browser settings.
- Your browser settings may allow you to refuse the setting of certain cookies. The "Help" or "Internet Settings" functions within your browser should tell you how. For information on how to manage cookies on popular browsers please see the following links:
Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
To opt out of being tracked by Google Analytics across all websites, you may be able to use the tool provided by Google available at: http://tools.google.com/dlpage/gaoptout.
Please be aware that if you select to refuse or restrict cookies, the full functionality of the Site may no longer be available.
If you have any questions about this Privacy Notice, please contact us at firstname.lastname@example.org, on +44 20 7329 4422 or alternatively at 1 Finsbury Circus, London EC2M 7SH.
If you have any concerns about our use of your information, you also have the right to make a complaint to your local data protection supervisory authority. In the United Kingdom, this is the Information Commissioner's Office https://ico.org.uk/global/contact-us/.
Changes to this Notice
We may amend this Privacy Notice at any time by posting the amended terms on the Site. All amended terms will automatically take effect immediately on posting. Please check this Privacy Notice periodically to inform yourself of any changes. If you do not accept the changes made to this Privacy Notice you should immediately stop using the Site.
Version: October 2021