OUR PRIVACY NOTICE

This is Bluetower Associates LLP’s (“Bluetower”) Client Privacy Notice. If you are an employee of or candidate for employment with us, you should refer to the Data Protection Officer for our “Employee Privacy Notice”.


Why you should read this privacy notice

In order to provide services to you as our client, Bluetower will need to collect, store and use personal data about you. We are committed to the highest privacy standards. However you choose to interact with us, we will only collect data that is necessary for us to deliver the best possible service or to enable us to comply with our regulatory obligations.

This Privacy Notice explains what personal data we will collect from you, what we do with that information, how we securely protect it and the rights you have in respect of the personal data we collect and hold about you.


About Bluetower

For the purpose of this Privacy Notice, Bluetower of Unicorn House, 221-222 Shoreditch High Street, London E1 6PJ (UK registered company number OC372068) is the Data Controller. Bluetower is registered with the Information Commissioner’s Office (Registration number ZB264151).

Bluetower processes personal data in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UKGDPR).


Data protection officer

Bluetower has appointed a Data Protection Officer who is responsible for overseeing questions in relation to our Privacy Notice, including any requests to exercise your legal rights. Our partner providers have also appointed Data Protection Officers, or similar.


Contacting us about your personal data

To contact our Data Protection Officer, please write to or email us at:

Bluetower Associates LLP
Unicorn House
221-222 Shoreditch High Street
London E1 6PJ
[email protected]

 

We will respond to your query within 30 days.


Why we collect and use your personal data

 

We will only ever use your personal data for lawful purposes. Most commonly we will use your personal data to ensure we are able to communicate effectively and efficiently with you. We use your information to contact you with appropriate products and services and to respond to queries from you. We will never sell your data.

 


The information we collect and how we use it

Information you provide to us

You will need to provide us with some personal data during the course of becoming our client. This information could include identity data such as and not limited to your name, date of birth, copies of personal identification documents such as your passport or driving license, which may also indicate ID numbers, nationality and sex, photographs or other descriptions of your likeness.

It may also include information on your private equity preferences.

Communications between us and you

We may also store copies of your communications with us to manage our relationship with you.

Our policy on storage, processing and retention of you data

To provide and manage our services, your data is stored and processed by Salesforce.com Inc within their facilities located in Paris and Frankfurt that are certified to ISO2701.

Information about security and privacy-related audits and certifications received by Salesforce.com Inc, including information on ISO certifications, is available on their website (www.salesforce.com).

We also use Dropbox, which stores data within their facilities located in the USA that are also certified to ISO2701. Information about security and privacy-related audits and certifications received by Dropbox, Inc, including information on ISO certifications, is available on their website (www.dropbox.com).

Any third-party company is only permitted to process your data for the specified purposes and in accordance with our instructions. We retain your information for as long as reasonably necessary to provide our products and services and to maintain records to satisfy tax, regulatory and legal requirements.

How we protect your personal information

Salesforce offers strong protections for your Personal Information including: preventing unauthorised access from outside our organisation; controlling permissions and privileges for individual users based on their roles within our organisation; CAPTCHAs after multiple failed logins by users, account lockout and session timeouts; logins from a new device requiring receipt of an email upon first login.

Dropbox also offers multiple layers of protection, including two-step verification, passwords and data encryption technology. Since 2013 we have worked with Forge Dynamic Ltd. (www.forgedynamic.co.uk) to ensure our security procedures are state of the art.

 

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 and may therefore be unable to provide you with one or more of our products or services.

Special category personal data

We do not collect any special categories of personal data about you. This includes details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health or your biometric or genetic information.

Links to other websites

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 information to these websites.

How and when we may share your personal information

Where necessary we may disclose your information to external agencies and organisations, including financial regulators and the police, for the prevention and detection of fraud and criminal activity.

Where we disclose your personal data to third parties, we require that they have the appropriate technical and organisational measures in place to protect your personal data. However, in some instances we may be compelled by law to disclose your personal data to a third party and have limited control over how it is protected by that third party.

 

Your rights with repesct to the personal information we hold

You are entitled to access the personal information that we hold on you. Any such request should be made using our contact details below. If any data we hold is inaccurate, this will be corrected promptly on request. In certain circumstances you can request that we erase your data which we will do where this does not prevent us meeting our legal and regulatory obligations.

You have a number of rights in respect of the personal data we hold about you:

Access to your personal data

You have the right to request access to your personal data (commonly known as a data subject access request).

Correction of your personal data

You have the right to request a correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

Erasure of your personal data

You have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Objection to processing of your personal data

You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.

Restriction of processing your personal data

You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Transfer of your personal data

You have the right to request the transfer of your personal data to you or to a third party. Subject to the rules and regulations that govern the products and services we provide, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdrawing consent

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Withdrawing consent to marketing

We will not disclose your information to any third party for marketing purposes, without your further consent. You have the right, at any time, to ask us not to process your personal information for marketing purposes. You can do so by unsubscribing from the marketing communication or contacting the Data Protection Officer.

Exercising your rights

If you wish to exercise any of the above rights, please contact us using the details provided above.

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights listed below); however we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We aim to respond to all legitimate requests within one month, but occasionally this may take longer if your request is particularly complex or you have made a number of requests (we will notify you and keep you updated).

 


Updading your communication preferences

You may ask that we do not send you communications using any of the contact details we hold on our records, this may include your email, SMS, telephone and postal information. Your personal preferences can be changed at any time by using our contact details below.


Use of cookies

A cookie is a small text file containing information that a web site transfers to your computer’s hard disk for record-keeping purposes. A cookie cannot give us access to your computer or to your personal information. Most web browsers automatically accept cookies; consult your browser’s manual or online help if you want information on restricting or disabling the browser’s handling of cookies. If you disable cookies, you can still view the information on our web site, but the functionality of certain areas may be reduced.


Complaints

If you are concerned about how we are collecting, storing or using your personal data, you can contact our Data Protection Officer in the first instance (see above).

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate)


Privacy Notice Updates

We reserve the right to make any changes and updates to this Privacy Notice without giving you notice as and when we need to. Our most up to date Privacy Notice is always available on our website.