1 INTRODUCTION & DEFINITIONS
1.1 This Privacy Information Notice describes how Broadstone Capital Advisors Limited (“Broadstone”) will collect, use and protect your personal information
1.2.1 “Data Controller” means the person (or business) who determines the purposes and means of processing personal information
1.2.2 “Data Processor” means the person (or business) responsible for processing personal data on behalf of a Data Controller
1.2.3 “EEA” means the European Economic Area which is made up of EU countries plus Norway, Iceland and Liechtenstein
1.2.4 “Broadstone / we / us / our” means Broadstone, who’s registered address is 71-75, Shelton Street, London, Greater London, WC2H 9JQ, United Kingdom.
1.2.5 “Information” means your personal information
1.3 Who is performing what role:
1.3.1 Broadstone is both the Data Controller and the Data Processor
1.3.2 The Data Protection Officer for Broadstone is Laura Peleteiro who’s contact details are
2 WHY WE NEED TO COLLECT YOUR INFORMATION
2.1 We collect Information from you in order to perform our legal and regulatory obligations prior to our commencement of an applicable mandate that you are involved in
2.2 When we need to collect, use and process Information we will obtain your express consent at that specific time
3.1 We will collect Information that allows us to confirm the following two characteristics about you:
3.1.1 Your identity, in the form of an official document that includes your name and your photograph; and
3.1.2 Your address, in the form of an official document that includes your name and your home address.
3.4 Find out more about cookies here.
3.5 Broadstone use Google Analytics (like many other websites) which is a service provided by Google. They gather anonymous data of how people are using this site and then provide us with visitor statistics, details of page views etc etc. You can opt-out of being tracked by Google Analytics here.
3.6 You can also disable and delete cookies via your Browser settings. Find out more here.
3.7 Remember the Risks Whenever You Use The Internet
3.8 While we do our best to protect your personal information, we cannot guarantee the security of any information that you transmit to Broadstone and you are solely responsible for maintaining the secrecy of any passwords or other account information. In addition, other Internet sites or services that may be accessible through Broadstone have separate data and privacy practices independent of us, and therefore we disclaim any responsibility or liability for their policies or actions.
3.9 Please contact those vendors and others directly if you have any questions about their privacy policies.
3.10 For any other information please contact Broadstone at
4 HOW WE USE YOUR INFORMATION
4.1 To comply with our legal or regulatory requirements
4.2 For the detection, prevention and investigation of illegal or prohibited criminal activities and in the protection of our legal rights (including liaison with regulators and law enforcement agencies)
5 HOW WE COLLECT INFORMATION
5.1 You may give us Information by correspondence with us:
5.1.1 In a meeting;
5.1.2 By email;
5.1.3 By post; or
5.1.4 By any other electronic means.
5.2 We may also receive Information from third parties who we believe (acting reasonably) have your authority to release Information to us (examples of such third parties includes: your business partners; staff members of businesses in which you are involved in; notaries, lawyers or other such professional providers who have certified copies of your personal information; and postal delivery companies)
6 DISCLOSURE OF INFORMATION
6.1 We may share your Information (including storage and transfer of data) with:
6.1.1 Any staff member of Broadstone;
6.1.2 Parties selected by you and for whom you have given prior consent for us to share your Information;
6.1.3 Any third party in order for us to meet our legal and regulatory obligations, including statutory or regulatory bodies, and law enforcement agencies; and
6.1.4 Any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully.
7 DATA RETENTION
7.1 We will retain Information about you for as long as is necessary for us to meet any legal, regulatory or fraud prevention requirements
7.2 We will regularly review our records to ensure that we only retain your Information for as long as is necessary for the purposes set out in this Privacy Information Notice
8 AUTOMATED DECISIONS
8.1 We may use your Information to undertake both automated and manual online identity checks and in the detection, prevention and investigation of illegal or prohibited criminal activities
9 TRANSFERS OUTSIDE OF THE EEA
9.1 The Information we collect from you may be transferred and stored at a destination outside of the EEA. It may also be processed by us outside of the EEA
9.2 We take steps to ensure that, in the event your Information is transferred outside of the EEA appropriate measures are in place to protect that Information in accordance with applicable data protection laws and regulations in the UK
10 SECURITY AND STORAGE OF INFORMATION
10.1 The storage and security of your Information is very important to us and is stored securely
10.2 Information provided by you in a physical format will be copied by us to create an electronic version. The physical documents will then be stored securely by us through the use of physical access controls
10.3 Information provided by you, or created by us (in accordance with clause 10.2), in an electronic format will be stored by us on a secure server, protected through a combination of physical and electronic access controls. Wherever possible we will ensure that stored electronic Information is encrypted using secure technology
10.4 Although we use market standard security software to protect your Information, we cannot guarantee the security of your Information as it is being transmitted by you (or by parties acting on your behalf) to us. Any such transmission is at your risk
11 YOUR INFORMATION AND YOUR RIGHTS
11.1 You have the following rights (noting our requirement to always comply with legal or regulatory requirements):
11.1.1 To be informed about how we obtain and use your Information;
11.1.2 To ask for a copy of the Information that we hold about you;
11.1.3 To have your Information rectified;
11.1.4 To request to have your Information erased;
11.1.5 To have Information you provided to us returned to you;
11.1.6 To lodge a complaint with the Information Commissioner’s Office (ICO), the supervisory authority responsible for data protection matters.
11.2 If you would like to use any of your rights please contact our Data Protection Officer at