Website Privacy Policy

Last Updated: 25 June 2018

  1. Who are we?

    www.brocktoncapital.com is a website (referred to as the “Site”) of Brockton Capital LLP ("we" "us", "our" or “Brockton Capital”). We are the controller of the personal information collected on the Site.

  2. What is this document and what personal information do we collect from you?

    We process certain information about you when you visit the Site. Some of that information may enable you to be identifiable (“Personal Information”). This Website Privacy Policy explains how we process that Personal Information.

    We collect Personal Information relevant to the activity you choose to undertake on the Site. This includes:

    1. General correspondence

      If you correspond with us, we will process and store your name, contact information and e-mail address.

    2. Technical and statistical information

      We collect some technical and statistical information about your use of the Site, including:

      • the internet protocol address used to connect your computer or device to the internet.
      • your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform (as applicable to the device you are using).
      • information about your visit, including the website that referred you to the Site (if applicable), the path that you take through and from the Site (including date and time), pages that you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

      This technical and statistical information is typically anonymous but may identify you in certain circumstances (“Technical Data”). Where it does, we treat it as Personal Information.

      Our service provider Google Analytics also collects Technical Data from you in the course of providing anonymous information to us about the use of the Site. You can read more about how Google Analytics uses Technical Data here:
      https://support.google.com/analytics/answer/6004245?hl=en-GB

  3. How do we use information collected from you and the legal bases on which we process your information?

    Your Personal Information may be processed in the following ways:

    • to improve the Site to ensure that content is presented in the most effective manner;
    • to protect Brockton Capital against threats such as fraud or cyber-attacks; and
    • to create anonymous data for use in the course of our business, for example to see which parts of the Site are most popular. Once anonymised, this data will no longer identify you and so will cease to be Personal Information.

    The lawful bases we rely on to process your Personal Information are that it is:

    • necessary for our legitimate interests:
      • to improve and develop our business operations and performance of the Site; or
      • for running our business, provision of IT services, network security and to prevent fraud; and/or
    • necessary to comply with our legal obligations.
  4. Who do we share your personal information with?

    We may share your Personal Information with our service providers as part of the operation of our business (for example, to enhance the functionality of our services, to obtain information necessary to reply to your correspondence or to process enquiries) or to pursue our legitimate interests.

    We may also share your Personal Information with other organisations or individuals when we have a good-faith belief that it is reasonably necessary to:

    • meet any applicable law, regulation, legal process or enforceable governmental request;
    • enforce applicable legal terms and conditions or our other legal rights, including investigation of potential violations;
    • detect, prevent, or otherwise address fraud, security or technical issues; or
    • protect against or prevent harm to the rights, property or safety of Brockton Capital, our members and employees or the public as required or permitted by law.

    We require all third parties to respect the security of your Personal Information and to treat it in accordance with data protection legislation. We do not allow our third party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

  5. Where is your personal information stored and processed?

    We will process and store your Personal Information in our IT systems, which includes cloud hosted IT systems. We employ organisational and technical methods to protect your Personal Information, and require that our service providers do the same.

    We store your Personal Information in the United Kingdom, but in some circumstances, we may transfer Personal Information that we collect from you to third party data processors, vendors or hosting partners acting on our behalf located in countries outside of the EEA or to other entities in our group of companies in connection with the purposes set out above. Where we transfer Personal Information to a country which has not been deemed to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal information in accordance with this Website Privacy Policy.

  6. How long do we keep your personal information?

    We will keep your Personal Information for as long as reasonably necessary to fulfil the purposes described in this Website Privacy Policy or as we reasonably need to in order to meet our legal and governance obligations.

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

  7. Links to other websites

    This Website Privacy Policy does not cover any links within the Site linking to other websites. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy statements on the other websites you visit.

  8. Changes

    We revise this Website Privacy Policy from time to time and you are responsible for checking this Website Privacy Policy when you visit the Site. We will use information in accordance with the privacy policy under which the information was collected. Please check for any updates to this Website Privacy Policy when you access the Site again.

  9. Your rights

    Data protection legislation provides you with certain rights when it comes to the processing of your Personal Information, which are set out below:

    1. The right to be informed

      You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Information and your rights. This is why we are providing you with the information in this Website Privacy Policy.

    2. The right of access

      You have the right to obtain access to your Personal Information (if we are processing it), and other certain other information (similar to that provided in this Website Privacy Policy).

      This is so you are aware and can check that we are using your Personal Information in accordance with data protection law.

    3. The right to rectification

      You are entitled to have your Personal Information corrected if it is inaccurate or incomplete.

    4. The right to erasure

      This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

    5. The right to restrict processing

      You have rights to ‘block’ or suppress further use of your Personal Information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their Personal Information to be ‘blocked’ to make sure the restriction is respected in future.

    6. The right to data portability

      You have rights to obtain and reuse your Personal Information for your own purposes across different services.

    7. The right to object

      You have the right to object to certain types of processing, including processing for direct marketing (which we will do only with your consent).

    We are committed to protecting your privacy. However, if you are not happy with how we collect or process your Personal Information or want further information on your rights, you can contact us at the email address and postal address set out above.

    If you are not satisfied with our response to your complaint or believe our processing of your Personal Information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO).

  10. Contacting us

    You can contact us about this Website Privacy Policy at:

    Chief Operating Officer
    Brockton Capital LLP
    89 Wardour Street
    London W1F 0UB

    Email: compliance@brocktoncapital.com