Introduction
Welcome to the Beech Tree PE LLP (“Beech Tree” or the “Firm”) privacy notice.
Beech Tree respects your privacy and is committed to protecting your personal data. This privacy notice will provide you with information as to how we look after your personal data, tell you about your privacy rights and how the law protects you.
This privacy notice is intended to assist you in making informed decisions when using our website and our services and/or to understand how your personal information may be processed by us as a result of providing our services to third parties. Please take a moment to read and understand it.
This privacy notice is provided in a layered format to enable you to click through to the specific areas set out below. Please also use the Glossary to establish the meaning of some of the terms used in this privacy notice.
- Important information and who we are
2. The data we collect about you
3. How your personal data is collected
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary
Important information and who we are
Purpose of this privacy notice
This privacy notice applies to the personal data of our website users, recipient of our services, potential or prospective clients, suppliers and other people who may contact us either:
- i) through use of this website, including any data provided through this website when you request access to the portal; or
ii) by electronic means or otherwise to request information from us,
and aims to give you information on how Beech Tree collects and processes your personal data.
This website and our services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide you with on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Beech Tree is the controller and responsible for your personal data.
Given the size, nature and setup of the Firm and its use of personal data it is not required to appoint a DPO. Instead it has appointed a data protection manager with responsibility for data protection compliance. The data protection manager is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection officer using the details set out below.
Simon Hemley
simon.hemley@beechtreepe.com
Beech Tree PE LLP, First Floor, Suite 3 Building Two, The Colony, Altrincham Road, Wilmslow, Cheshire, SK9 4LY
You are entitled to make a complaint, at any time, to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Our primary goal in collecting personal information from you is to help us:-
- verify your identity
- deliver our services
- improve, develop and market new services
- carry out requests made by you on our website or in relation to our services
- investigate or settle inquiries or disputes
- comply with any applicable law, court order, other judicial process, or the requirements of a regulator
- enforce our agreements with you
- protect the rights, property or safety of us or third parties, including our other clients and users of our website or our services
- use as otherwise required or permitted by law.
Accordingly, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
If you are a visitor to our website or contact us through the website:
- Identity Data includes first name, last name, username or similar identifier and title.
- Contact Data includes address, email address and telephone numbers and the company you work for.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password and preferences.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
If you are a recipient of our services or a prospective client:
- Identity Data includes first name, last name, username or similar identifier and title.
- Contact Data includes address, email address, telephone numbers and the company you work for.
- Information that you provide to us as part of us providing our services to you, which depends on the nature of your relationship with the Firm.
- Relevant information as required by Know Your Client and/or Anti-Money Laundering regulations and as part of our intake procedures. This may possibly include evidence of source of funds, at the outset of and possibly from time to time throughout our relationship with clients, which we may request and/or obtain from third party sources. The sources for such verification may comprise documentation which we request from you or through the use of online sources or both.
- Information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs.
- Other information relevant to provision of our services.
If you are an individual whose personal information is processed by us as a result of providing our services to others (including individual clients and corporate clients) we will process a variety of different personal information depending on the services provided.
This may include personal information relating, without limitation, to any of our corporate clients’ or prospective clients’ officers or personnel, any opponent or vendor or purchaser of personal information including personal information relating to their legal advisors, other advisors or personnel as relevant or similar.
We might also need to process personal information in relation to other third parties instructed either by our own clients or other persons or companies involved with us providing our services to our client (for instance law firms, accountancy firms etc.).
This is a non-exhaustive list which is reflective of the varied nature of the personal information processed as part of the activities carried out by the Firm.
If you are a client or prospect, we also collect information to enable us to market our services which may be of interest to you. For this purpose we collect:
- Name and contact details.
- Other business information such as job title and the company you work for.
- Areas or topics that interest you.
- Additional information may be collected such as events you attend and if you provide it to us.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) nor do we collect any information about criminal convictions and offences.
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 is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our website;
- receive our service or subscribe to our publications;
- request marketing to be sent to you; 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.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from analytics providers, such as Google, based outside the EU.
- Identity and Contact Data from data brokers or aggregators based inside OR outside the EU.
- Identity and Contact Data from publicly available sources such as Companies House inside the EU.
- Identify and Contract Data from our clients or our portfolio companies.
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.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
See Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other where necessary to permit us to send third party direct marketing communications to you via email. You have the right to ask us to stop sending you marketing materials at any time by contacting us at the address above.
Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list below.
- To register you as a new customer
Type of data:(a) identity, (b) contact
Lawful basis: performance of a contract with you - To manage our relationship with you, including notifying you about changes to our terms or privacy policy
Type of data:(a) identity, (b) contact, (c) profile, (d) marketing and communications
Lawful basis:(a) performance of a contract with you, (b) necessary to comply with a legal obligation, (c) necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) - 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:(a) identity, (b) contact, (c) technical
Lawful basis:(a) 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), (b) necessary to comply with a legal obligation - To provide our services to our clients
Type of data:(a) identity, (b) contact
Lawful basis:It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you. It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others. - To send you marketing information and other details about our services in which you might be interested
Type of data: (a) identity, (b) contact, (c) profile, (d) marketing and communications
Lawful basis: It is in our legitimate interest to use your personal information for marketing purposes. We will only send you marketing communications where you have consented to receive such marketing communications, or where we have a lawful right to do so.
Opting out
You can ask us to stop sending you marketing messages, at any time, by contacting us.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible and/or not function properly. For more information about the cookies we use, please view our cookie policy.
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 required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes listed above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International Transfers
We do not transfer your personal data outside the European Economic Area (EEA).
Data Security
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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
How long will you use my 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contact us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Not applicable
External Third Parties
- Service providers acting as processors based in the EEA who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request 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, though we may need to verify the accuracy of the new data you provide to us.
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.
Object to 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 and freedoms.
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.
Request the transfer of your personal data to you or to a third party. 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.
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.
