Privacy Policy

Introduction

Welcome to the Working Capital Partners Website Privacy Notice.

Working Capital Partners (‘Working Capital Partners’, ‘We’, ‘Us’ or ‘Our’) take data protection very seriously and are committed to protecting and respecting your privacy. This Privacy Notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. We are the data controller and Our place of business is Buckingham House, 45 Vivian Avenue, London NW4 3XA.

Our principle guidelines are simple. This policy (together with Our Terms and Conditions of Use and any other documents referred to in either document) explains how We collect, use and handle any personal information We collect from you when you use Our website at www.workingcapitalpartners.com (our ‘Site’) We call Our ‘Services’ or Our Website.

PURPOSE OF THIS PRIVACY POLICY

The privacy notice aims to give you information on how Working Capital Partners collects and processes your personal data through your use of this website, including any data you may provide through this website when you submit your interest in our services.

This website is not intended for children and we do not knowingly collect data relating to children.

Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it. By visiting the Site or using Our Services you are accepting and consenting to the practices described in this policy.

COLLECTING YOUR PERSONAL INFORMATION

The prime purpose of collecting your data is to send out newsletters, updates on practice news, communications via email and telephone regarding projects - for those that are contracted to working on a project.

Information is being collected for the use of communications on projects. If you are contracted to work on a project with Us, we will need your information to ensure that all forms of communications are available to us. We will communicate via: post, email and telephone.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including:

Direct interactions. You may give us your identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • register an interest to work with Us via our website;
  • if you send Us an email, or correspond with Us by telephone in writing or otherwise;
  • if you report a problem to us;
  • request marketing to be sent to you;
  • from any of your activities in connection with your use of Our Services
  • if you report a problem to us or give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.

Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    1. analytics providers such as Google
    2. advertising networks and
    3. search information providers
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services
  • Identity and Contact Data from publicly availabe sources such as Companies House and the Electoral Register based inside the EU.

WHAT INFORMATION IS BEING COLLECTED?

We ask that you provide Us with certain personal information, which includes your first name, surname, address, company details, work phone number, occasionally work mobile, email and address.

Information We receive from other sources, including third parties, customers and partners may provide data to us. We may also receive information about you from social media platforms, for instance, when you interact with us on those platforms.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • to allow you to stay in touch, in communications and up to date with contacts, collaborators and clients.
  • to send you newsletters (possibly including adverts) which you may either elect to receive or may be interested in receiving, that keep you up-to-date with practice news.
  • to maintain our own accounts and records.
  • to send you invitations to any of our hospitality events that we think you as a client may enjoy.

Except as set out in this Privacy Policy or otherwise agreed by you, We will not share your personal information with third parties (such as marketing companies) or use your personal information other than for Our internal purposes as a business.

PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity

To register you as a new customer (client)

Type of Data

  1. Identity
  2. Contact

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

Purpose/Activity

Type of Data

Lawful basis for processing including basis of legitimate interest

Purpose/Activity

To process and deliver service to including:

  1. Manage payments, fees and charges
  2. Collect and recover money owed to us

Type of Data

  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications

Lawful basis for processing including basis of legitimate interest

  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)

Purpose/Activity

To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy
  2. Provide us with feedback

Type of Data

  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications

Lawful basis for processing including basis of legitimate interest

  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Purpose/Activity

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of Data

  1. Identity
  2. Contact
  3. Technical

Lawful basis for processing including basis of legitimate interest

  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  2. Necessary to comply with a legal obligation

Purpose/Activity

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of Data

  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of Data

  1. Technical
  2. Usage

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

HOW WE MAY SHARE YOUR INFORMATION

We may engage third parties to undertake some of Our Services or related advisory services. We may provide those third parties access to personal information for the sole purpose of them providing their services to us. We will use reasonable endeavors to ensure that those third parties only use your personal information for the specific purposes for which it is provided to them and consistently with this Privacy Policy.

We use others to help provide Our Services (e.g. maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on Our behalf and are obligated not to disclose or use it for other purposes.

We may also disclose your personal information to:

  • Our related companies;
  • to Our professional advisors;
  • to law enforcement authorities, if We suspect that an unlawful act is being committed or that such disclosure will prevent that unlawful act; or as otherwise required or authorised by law.

Other than the types of disclosures set out in this Privacy Policy or as otherwise agreed by you, We will not disclose your personal information to any third party.

ADVERTISING AND COOKIES

We use 'cookies' and similar technologies to identify information about your web browser session and personalisation data each time you visit Our Website. A 'cookie' is a small data file that will be stored by your web browser when you access Our Website. These cookies do not contain any of your personal information such as name or email, the information stored in the cookie will only identify you to Working Capital Partners. We may, for example, collect information about the type of device you use to access our websites, the operating system and version, your IP address, your general geographic location, as indicated by your IP address, your browser type, the webpages you view on our websites, whether you interact with content available on our websites and how.

You can set up your browser so that it does not accept Our cookies. You can also manually delete Our cookies from your browser.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

SECURITY OF YOUR PERSONAL INFORMATION

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor Our systems and Services for possible vulnerabilities and attacks. However, We cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of Our physical, technical, or managerial safeguards.

HOW LONG WILL YOU USE YOUR PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

THIRD PARTY WEBSITES

Please be aware that Our Services may contain links to third party websites. If you visit such websites, before providing your personal information on or in connection with those websites, We suggest you review the privacy policy and terms and conditions of use of the third party website. We do not control these third-party websites and are not responsible for their privacy statements. We you leave our website, we encourage you to read the privacy policy of every website you visit.

YOUR ACCESS TO YOUR PERSONAL INFORMATION

You are entitled to know what personal information We hold about you. You are also entitled to update or correct your personal information. If you would like to contact Us in relation to your personal information, please do so by email to support@wcpuk.co.uk. As of 25 May 2018, these rights will be replaced by their equivalents in the “GDPR” section immediately included below.

YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

This GDPR comes into force on 25 May 2018 and as of that date you will have the rights set out in this section. You may be able to exercise some of these rights directly through the functionality We provide on Our Services. Alternatively, or where that is not possible, or if you wish to ask a question about your rights, please contact Us on support@wcpuk.co.uk.

You shall have the right, in accordance with the GDPR, to obtain from Us the following:

  • Right of confirmation

    Confirmation as to whether or not personal data concerning you is being processed.

  • Right of access

    Free information about the personal data we store about you at any time and to receive a copy of it.

  • Right to rectification

    Rectification without undue delay of inaccurate personal data about you.

  • Right to erasure (Right to be forgotten)

    The erasure of personal data concerning you without undue delay, subject to our legal rights and obligations to retain the same.

  • Right of restriction of processing

    Restriction of processing where:

    • You contest the accuracy of the personal data, for a period while We verify its accuracy;
    • the processing is unlawful and you oppose the erasure of your personal data and request that it be restricted instead;
    • we no longer need your personal data for the purposes of the processing, but do require them for the establishment, exercise or defence of legal claims; and
    • you do not agree with Our assessment that the processing is permitted for Our “legitimate interests”, for a period while verification is carried out as to whether those interests override your own interests.
  • Right to data portability

    You shall have the right to have the personal data concerning you, which was provided to us, in a structured, commonly used and machine-readable format and to have it transmitted to another entity (to the extent that such data was processed by us on the basis of consent or because such processing was necessary for the performance of a contract).

Additionally, you will have the following rights:

  • Right to object

    • To object on grounds relating to your particular situation, at any time, to processing of personal data concerning you, which is based on our legitimate interests. This also applies to profiling based on these provisions;
    • to object to our processing of personal data for direct marketing purposes. This applies to profiling to the extent that it is related to such direct marketing;
    • Automated individual decision-making, including profiling
    • Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you.

CHANGES TO OUR PRIVACY POLICY

We may change the terms of Our Privacy Policy from time to time and at any time, and without actual notice to you. Please check this page from time to time to take notice of any changes We make, as these are binding on you.

HOW TO CONTACT US

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to support@wcpuk.co.uk.

FAQ

The following are basic questions you may have about our privacy statement. We recommend that you read the detailed statement above for additional details.

Why is Working Capital Partners updating its privacy statement?
We now meet the high standards required by the European Union's General Data Protection Regulation (GDPR) and have updated our privacy statement to reflect that. We also strive to simplify language and remove jargon, to make our privacy statement easier to read and comprehend.

What is the GDPR?
The GDPR is a regulation intended to strengthen and unify data protection for everyone within the European Union (EU). As we believe that all our customers can benefit from its mandates, we're implementing it globally. The GDPR requires greater openness and transparency from companies on how they collect, store and use personal data, while also imposing tighter limits on the use of personal data. You can learn more here.

How often do Working Capital Partners anticipate updating your Privacy Policy?

We may modify or update Our Privacy Policy when necessary, from time to time and at any time, and without actual notice to you. Please check this page from time to time to take notice of any changes We make, as these are binding on you.

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