Circuitus Capital LLP

A Limited Liability Partnership

Registered Office: 154 Brompton Road, London, SW3 1HX

Registered in England and Wales

Registration Number: OC393936

Regulated by the Financial Conduct Authority

Firm Registration Number: 657543

 

PRIVACY POLICY

Circuitus Capital LLP (“we”, “us”, “our”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting http://www.circuitus.com (“our site”) you are accepting and consenting to the practices described in this policy. You can withdraw such consent at any time.

This website is hosted by register.com in the United States.

For the purpose of the Data Protection Act 1998 (“the Act”) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“the General Data Protection Regulation” or “GDPR”), the data processor and controller is Circuitus Capital LLP of 154 Brompton Road, London, SW3 1HX.

As used in this policy, the term “Regulations” shall include, together, the Act and the General Data Protection Regulation, each of them, as from time to time applicable, amended, restated or supplemented.

 

  1. INFORMATION WE MAY COLLECT FROM YOU


We may collect and process the following data about you (including without limitation):

  • Information that you give us

You may give us information about you by filling in forms on our site or by corresponding with us by phone, eMail or otherwise. This includes information you provide when you register to use our site, become a member, post material, participate in discussion boards or other social media functions on our site, request further services, and when you report a problem on our site. If you contact us, we may keep a record of that correspondence. The information you give us may include your name, address, eMail address and telephone number.

1.2   Information we collect about you

With regard to each of your visits to our site, we may automatically collect technical information such as the internet protocol (IP) address used to connect your computer to the internet, your time zone setting and the pages you visited.
 

  1. USES MADE AND PROCESSING OF THE INFORMATION


We may use information held about you (i.e. information that you give us or which we collect about you) in the following ways:

2.1   Information you give to us

We may process information that you give to us to provide you with the information that you requested from us.

2.2   Information we collect about you

We may process information that we collect about you to administer our site and for internal data analysis and research.

The legal basis for this processing is our legitimate interests and business, and at your request to provide further details. Your information will not be used for direct marketing purposes.

2.3   Information of third parties

You will not supply to us, and we will not accept, any other person’s personal data.

 

  1. WHERE WE STORE YOUR PERSONAL DATA


The data that we collect from you is hosted and stored in Europe and the United States.

Your data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA, who work for us or one of our suppliers. By submitting your data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and in compliance with the Regulations.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

  1. DISCLOSURE OF YOUR INFORMATION


We may share your information with any member of our group, which means our Partners.

We may also share your information with selected third parties for the purposes set out in this policy. These selected third parties may include analytics and search engine providers that assist us in the improvement and optimization of our site.

If Circuitus Capital or substantially all of its assets are acquired by a third party, then personal data held by us may be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; and/ or to protect the rights, property or safety of Circuitus Capital or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

 

  1. RETENTION AND DELETION OF PERSONAL DATA


We will not retain and store any personal data for longer than it is necessary for the purposes of compliance with our legal obligations under the Regulations.

We will retain your personal data for a minimum period of two (2) years, or as any other longer period that may be imposed to us by law or by the Regulations (the “Data Retention Period”).

Upon expiry of the Data Retention Period, all your personal data stored and retained by Circuitus Capital will be deleted from its files and records.

 

  1. YOUR RIGHTS


Your rights under the Regulations are:

6.1  Information

You have the right to be informed of your rights and how your personal data will be stored, treated, deleted and controlled, as set out in this policy.

6.2  Access to Information

You have the right to access your personal data, so that you are aware of and can verify the lawfulness of the processing. The Regulations give you the right to access information held about you. Your right of access can be exercised in accordance therewith. Any access request is free of charge.

If any such requests are denied, you would have the right to complain to the supervisory authority (the Information Commissioner’s Office).

6.3  Rectification

You have the right to rectification of any data that is incorrect and, taking into account the purposes of the processing, you have the right to request that any incomplete information is completed.

6.4  Erasure

You can request that any data is erased where:

  • the personal data is no longer necessary in relation to the purpose for which it was originally collected/ processed;
  • when your personal data has been unlawfully processed in breach of the Regulations;
  • when your personal data has to be erased in order to comply with a legal obligation.

6.5  Restriction

Processing of your personal data will be restricted when processing is unlawful, and you oppose erasure and request restriction instead. It will also be restricted if Circuitus Capital no longer needs your personal data, but you require the data to establish, exercise or defend a legal claim.

6.6  Data Access Portability

You may also, free of charge, request to view, access and use your personal and transaction data in a way that is generally portable.

6.7  Objection

You may express an objection on grounds relating to your particular situation to processing for purposes of historical research and statistics.

6.8  Automated Decision-making and Profiling

You may object to be subject to any automated data processing decisions, unless such automatic processing is necessary for entering into or performance of a contract between you and Circuitus Capital.

 

  1. LINKS TO THIRD PARTY WEBSITES


Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability fore these policies. Please check these policies before you submit any personal data to these websites.

 

  1. DATA ACCURACY


Whilst we accept responsibility for maintaining the personal information entrusted to us on our site, we are not responsible for its accuracy over time or at the point of entry. If you identify any inaccuracy in your personal information, you can request any necessary changes as required and as provided in this policy.

 

  1. CHANGES TO OUR PRIVACY POLICY


Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by eMail. Please check back frequently to see any updates or changes to our privacy policy and to ensure that you are happy with any such changes.

 

  1. CONTACT


Questions, comments and requests regarding this privacy policy are welcomed. You can contact Circuitus Capital by eMail at info@circuituscapital.com, by post at our registered address or by telephone using the contact number published on our website from time to time.

 

  1. DATA PROTECTION OFFICER


For the purposes of the Regulations, Circuitus Capital has appointed Mr Paul Hatter as its Data Protection Officer, who can be contacted as noted in paragraph 10 above.

 

  1. FILING OF COMPLAINTS


If you have any complaints or concerns about the contents of this policy or your personal data stored, processed and/ or controlled by Circuitus Capital, you can address these to the supervisory authority, the Information Commissioner’s Office.