1. Our role as data controller
When we use personal data about you or others in connection with promoting and administering our business, providing our services, or recruitment, we do so as data controller.The data controller is Tropix Capital Management (UK) LLP, 8, Woodland Way, Surrey, CR8 2HU, United Kingdom, Tropix Capital Management LLC, Suite 229, 5 River Road, Wilton, CT, USA 06897, Tropical Research Services; (together "TRS/We/Our/Us"). TRS has overall responsibility for, and is the data controller of, personal data collected by TRS.
2. Your role in keeping your personal data up to date
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
3. Contact details of our Privacy Manager
We do not meet the criteria for a mandatory appointment of a Data Protection Officer under the General Data Protection Regulation. We have allocated informal responsibility to a person in our business who can deal with any data protection-related matters.
You can contact our Privacy Manager by post or by email at: email@example.com, marking the subject line, ‘For the attention of the Privacy Manager’.
4. Categories of personal data obtained
Personal data, or personal information, means any information about a living individual from which that person can be identified, directly or indirectly. We may collect different kinds of personal data about you when you interact with us, including via, email, telephone, post or in person. We may also receive this information from third parties (for example, a publicly available source or from someone who has recommended us to you and given us your contact details). We have grouped this information together as follows:
· Identity Data, such as your name.
· Contact Data, such as your email address, telephone/fax number, address and other contact details.
· Enquiry Data, such as your enquiries about engaging us for research services.
· Correspondence Data, such as any correspondence between us and you about an enquiry.
· Marketing and Communications Data, such as your communications preferences and how you have responded to our marketing communications.
· Unless we are required to do so to comply with a legal obligation, or as an integral part of providing relevant research services to you, we do not usually collect any personal data about you.
5. Use of personal data
Our core purposes for processing personal data are to promote and operate the business of being a research company, to provide research services to our clients, to maintain our client and business records and to comply with the law and regulations.
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 it is necessary for us in order to perform a contract which we are about to enter into, or have entered into, with you (for example, a contract between you and us for us to provide research services to 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 (for example, to monitor our IT systems and protect them).
· Where we need to comply with a legal or regulatory obligation (for example, the rules which require us to verify the identity of someone before they can become a client).
· Where we have your consent to do so (for example, if you are not a client and you ask us to sign you up for news and updates by email).
6. Sharing your personal data
We may allow our officers, employees and self-employed consultants (“colleagues”) to access your data where we believe this is necessary.
We may disclose personal data to regulators and other authorities who require reporting or disclosure of processing activities, or other personal data, in certain circumstances.
We may share your data with third parties to whom we have outsourced certain tasks, such as IT, business administration or marketing and analytics services.
We may share your personal data with our insurers, our professional advisors (lawyers, bankers, auditors, corporate financiers and brokers) in connection with services they provide to us.
We may also share data with 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
We require all third parties to respect the security of 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.
We will not otherwise share personal information with any third party except where we are permitted to under data protection laws or required to by law.
7. Advertising, marketing and your communications preferences
· We may use your Identity and Contact Data to form a picture of what we think may be of relevance to you. You can also unsubscribe at any time by emailing firstname.lastname@example.org
8. International transfers
We may hold copies of your personal data and other data on computers outside the European Economic Area (EEA). Sometimes we will share personal data with third parties outside the EEA. If we do this, we will comply with the rules in the General Data Protection Regulation.
9. Safeguarding personal data
We have put in place appropriate technical and organizational measures to safeguard your personal data.
10. Retaining personal data
We will only keep your personal data for as long as necessary to fulfil the purposes for which we collected it, 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 unauthorized 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. Unless you are still receiving our newsletter or updates, we will delete your data within two years of the date we receive it.
11. Your rights
We set out below a summary of the rights you may have under data protection laws in relation to your personal data.
· 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.
· Request correction of your personal data. 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 our 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 our legitimate interests (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 we were originally using with your consent or on account of our need to perform a contract with you. This may not be all the information we hold about 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please choose one of the following options:
· To unsubscribe from our newsletter and updates, please use the unsubscribe link in the newsletter or email@example.com
· To exercise any other rights, please contact the Privacy Manager.
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.
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.
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.