This EU and UK Privacy Notice Supplement supplements the information contained in the Privacy Policy above and applies solely to the processing of personal data which is subject to EU & UK Data Protection Laws. For the purposes of this EU & UK Privacy Notice Supplement, the “EU & UK Data Protection Laws” mean all applicable laws and regulations relating to privacy, protection or processing of personal data in the EEA, EU and UK, including (without limitation): the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union Withdrawal Act 2018 (“UK GDPR”), and including in respect of the foregoing any implementing or successor legislation and any amendments or re-enactments. The terms “controller”, “data subject”, “personal data”, “process” and “processing” shall be interpreted in accordance with the applicable EU & UK Data Protection Laws.
To the extent that EU & UK Data Protection Laws apply to our processing of your personal data, we are a “controller” of your personal data. In simple terms, when applicable, this means we: (i) “control” the personal data that we collect from you or other sources; and (ii) make certain decisions on how to use and protect such personal data.
INFORMATION WE COLLECT
The types of personal data that we collect are set forth in the Information We Collect section of the Privacy Policy. Please note that 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.
PURPOSES AND LEGAL BASES
We rely on various legal bases under the EU & UK Privacy Laws in order to process your personal data. Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data. These purposes are set out in the How We Use Your Information section of the Privacy Policy, which in general are to operate our business, conduct business with you and perform essential or legitimate business operations.
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 we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations).
No solely automated decision making, including profiling, is used when processing your personal data.
DISCLOSURE OF PERSONAL DATA
We may disclose and transfer your personal data to third parties, which may involve the transfer of your personal data outside of the EEA, EU or UK. We will only transfer your personal data in accordance with applicable laws (including the EU & UK Data Protection Laws). Furthermore, we may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfill the purposes described in the Privacy Policy and in accordance with applicable laws. For information on the safeguards applied to such transfers, please contact us at admin@fcpartners.com.
For the purposes of this Privacy Policy, “Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA or EU; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the UK (as applicable) in accordance with the applicable EU & UK Data Protection Laws to ensure an adequate level of protection for personal data.
DATA SUBJECT RIGHTS
To the extent set forth in EU & UK Data Protection Laws, you may have certain rights relating to the collection and use of your personal data, including, as applicable, the right to (i) request a copy of the personal data we retain; (ii) to correct any inaccurate information contained within the personal data we retain; (iii) delete any personal data we retain; (iv) restrict the processing of personal data we retain, including the purposes for which personal data is processed by or on our behalf; (v) object to the processing of personal data undertaken by us; (vi) direct the transfer of your personal data to a third party designated by you; (vii) withdraw your consent to our processing of your personal data at any time; and (viii) not be subject to solely automated decision making. Individuals located in the UK, EU or EEA may also “opt out” or unsubscribe from any marketing communications from us. An individual may contact us at admin@fcpartners.com if they wish to exercise any of the rights set forth herein. Furthermore, you have a right to lodge a complaint with the local supervisory authority. These rights are not absolute and in certain circumstances their exercise may not be possible including when personal data must be maintained to comply with applicable laws.
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.
To the extent EU & UK Data Protection Laws apply, should you have any questions or wish to contact us in relation to this EU & UK Privacy Notice Supplement and the Privacy Policy, please contact us at admin@fcpartners.com.