Privacy and Cookies Policy

Effective date of current Privacy and Cookies Policy: 24 September 2020

This Privacy and Cookies Policy describes the policies and procedures followed by Queen’s Park Equity LLP and its affiliates (“Company”, “we”, “us” or “our”) regarding the collection, use and disclosure of your personal data when you visit the website https://www.qpequity.com/ (“Site”), or otherwise interact with us. For the purposes of European and United Kingdom (“UK”) data protection laws, the Company is the controller of your personal data (i.e., information that directly or indirectly identifies you) (“Personal Data”).

We respect the privacy of our visitors to the Site. By accessing the Site and our services, you agree to our collection, use and disclosure of your Personal Data as described in this Privacy and Cookies Policy and our Terms and Conditions.

Collection of Personal Data

We may collect the following Personal Data about you:

Information that you give to us – You may give us Personal Data including your first name and last name, telephone number(s), and email address when you contact us. You are not under any obligation to provide any of this information. However, if you withhold requested information, we may not be able to provide you with certain services, or respond to your communications more generally.

Information that we collect about you – We automatically collect basic technical information from all visitors to the Site through our automatic data collection tools, which may include cookies and other commonly used technologies (see section on Cookies below). These tools collect certain standard information that your browser sends to the Site such as your browser type and language, device type, operating system, access times, domain name and the address of the site from which you came to the Site. They may also collect information about your IP address, or click stream data within our Site (i.e. the actions taken in connection with the Site). This information helps us improve the functionality of the Site.

Use of your Personal Data

We may use the Personal Data you give us to carry out the following purposes:

Purpose	Lawful Basis
To contact you and to respond to your requests and enquiries when you contact us	We have a legitimate interest to respond to your requests and enquiries for ongoing business administration
To manage and maintain our relationships with you and for ongoing customer service	To manage and perform our contract with you. We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient as we can be
To deliver services to you
To personalise your visit to the Site and to assist you while you use the Site	We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient as we can be
To improve the operation of the Site by helping us understand who uses the Site	We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient as we can be
For business administration, including statistical analysis	We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient
To share data with policy, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation, including screening transactions, reporting suspicious activity and complying with production or court orders	We have a legitimate interest to manage our business including for legal, personnel, administrative and management purposes and for the prevention and detection of crime provided our interests are not overridden by your interests. To comply with our legal or regulatory obligations.
To investigate and resolve complaints and manage regulatory matters, investigations and litigation
To monitor electronic communications for investigation and fraud prevention purposes, crime detection and prevention and investigation
To comply with any of our applicable legal or regulatory obligations. For example, if you are a business customer, we need to process your information to verify your identity and undertake necessary due diligence checks
To contact you to tell you about products and services offered by us as well as other promotions which we believe may interest you unless you advise us that you do not wish to receive marketing or market research communications from us	If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing or market research communications from us you can unsubscribe via the link at the bottom of the relevant marketing email or contact us using the contact details below. We have a legitimate interest to carry out direct marketing.

Please note that you have a right to object to processing of your Personal Data where that processing is carried out for our legitimate interest or for direct marketing.

Consequences of Not Providing your Personal Data

Where we require your Personal Data to comply with our legal or contractual requirements, failure to provide this information means we may not be able to provide services to you. We will tell you when we ask for your Personal Data whether it is a statutory or contractual requirement to give us the Personal Data and the consequences of not providing such Personal Data.

Sharing your Personal Data

We may use selected third parties to provide us with services or technical support for the Site who may have access to your Personal Data. The Company may share or otherwise provide third party vendors with access to your Personal Data to enable these vendors to provide services to us, which may include IT services in relation to the Site.

Similarly, we may share your Personal Data: (i) to third parties (including regulators and courts) to comply with legal or regulatory obligations or in response to valid legal requests, including to the extent required by law, regulation, subpoena or court order or otherwise in connection with a judicial, administrative or governmental proceeding or as requested by any governmental agency or regulatory authority; (ii) to detect and protect against fraud or any technical or security vulnerabilities; (iii) to respond to an emergency or otherwise to protect the rights, property, safety, or security of our business, third parties, or the public; or (iv) as part of any merger, acquisition, or sale of company assets.

International Transfer

When you are based in the European Economic Area (“EEA”) or the UK, Personal Data collected from you, including via the Site, may be transferred to certain recipients located outside the EEA or the UK which do not provide a similar or adequate level of protection to that provided by countries in the EEA or the UK. You hereby consent to the transfer of your Personal Data to recipients as described in this Privacy and Cookies Policy which are located outside of the EEA or the UK. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Security

We take reasonable steps, consistent with generally accepted industry standards, including technical, organisational and physical safeguards to protect the Personal Data submitted to us from loss, misuse and unauthorised access, disclosure, alteration and destruction. While these methods are considered to be effective, we do not guarantee the protection of your Personal Data as no data transmission over the Internet can be guaranteed to be completely confidential or 100% secure. You should always use caution when transmitting Personal Data over the Internet.

Retention

The Company retains your Personal Data for as long as it needs for a legitimate business purpose. The criteria used to determine the retention periods include: (i) how long the Personal Data is needed to provide our products and services; (ii) the type of Personal Data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

Rights of Individuals

Where you are located in the EEA, the UK or Switzerland, you may have certain data privacy rights which may be subject to limitations and/or restrictions. These rights include the right to:

Request access to Personal Data we hold about you;
The correction of your Personal Data when incorrect, out-of-date or incomplete;
Request that we erase your Personal Data;
Opt-out of any marketing communications that we may send you and to object to us using/holding your Personal Data;
Request that we restrict the processing of your Personal Data (i.e., we would need to secure and retain the data for your benefit but not otherwise use it);
Withdraw your consent at any time (e.g., for direct marketing); and
The portability of your Personal Data (i.e., ask for a copy of your Personal Data to be provided to you, or a third party in a digital format).

We will respond to your request in writing or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, we may extend this period by two months and provide you with reasons. We may request proof of identification to verify your request.

You also have the right to lodge a complaint about the processing of your Personal Data with your local data protection authority. For more details in relation to your rights including how to exercise them, please feel free to contact contact@qpequity.com.

Cookies

As noted above, the Site use a technology called “cookies”. A cookie is a tiny element of data that our Site can send to your browser, which may then be stored on your hard drive so we can recognise you when you return. The data identifies you as a unique user and facilitates your ongoing access to and use of this website. Cookies also help us diagnose problems with our server and the website.

If you don't want us to use cookies when you use this Site, you can adjust your Web browser settings not to accept cookies. Your Web browser's help function should tell you how to do this. Alternatively, to find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit the Site: http://www.allaboutcookies.org. This Site will also explain how you can delete cookies which are already stored on your device. However, without these identifier files you may not have access to many features that may make your browsing of our Site smoother, and some of our services may not function properly.

Marketing

Where you have requested it, we may contact you by email to provide information regarding products, services and content that may be of interest to you, unless you advise us that you do not wish to receive marketing communications from us. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing communications from us, or would like to stop processing your Personal Data in any other way, you can contact us as described below to let us know what types of communications you wish to stop receiving.

Modification to Privacy and Cookies Policy

We reserve the right to change this Privacy and Cookies Policy, along with any related provisions, at any time. If we make any change to this Privacy and Cookies Policy we will notify you by means of a prominent notice on the Site prior to the change becoming effective. We will also post an updated version on our Site. Any changes to this Privacy and Cookies Policy will be effective immediately.

Be sure to review the Privacy and Cookies Policy periodically to ensure familiarity with its most current version. You can easily confirm whether any revisions have been posted since your last visit by checking the date on which the Privacy and Cookies Policy was last revised, which is set forth at the top of this Privacy and Cookies Policy. If you disagree with the changes to our Privacy and Cookies Policy, however, please do not use the Site after the posting of such changes online. By using the Site following the posting of changes to this Privacy and Cookies Policy, you agree to all such changes.

Third-Party Websites

Our Site may contain links to other third-party websites, which may have Privacy Policies/Statements that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy/statement posted on any website that you may access through our Site.

Questions, Comments or to Contact Us

If you have any questions or comments about this Privacy and Cookies Policy, or you wish to exercise any of your data subject rights, please contact contact@qpequity.com.