Privacy Policy

Corran Capital LLP (“Corran“, “we“, “our“) is committed to protecting the privacy of individuals whose data it processes (“you” or “your“).

1. IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy aims to give you information on how Corran collects and processes your personal data as a controller, through your use of the Corran website. In addition, it outlines your data protection rights under the UK General Data Protection Regulation. This website is not intended for children under the age of 16 and we do not knowingly collect data relating to children under 16.

Corran is the controller of the personal data that you provide or which is provided to or collected by us. Please contact us at 10a Wester Coates Gardens, Edinburgh, EH12 5LT or at enquiries@corrancapital.com if you have any queries in relation to the processing of your personal data under this policy.

We may update this policy from time to time. Please refer back to this page regularly to see any changes or updates to this policy.

2. CATEGORIES OF DATA SUBJECT

VISITORS TO OUR WEBSITE

The following section of this policy sets out how Corran may process personal data (as a controller) about visitors to its website and Platforms operated on its behalf to collate data.

THE TYPES OF DATA WE MAY HOLD

We may collect, use, store and transfer different kinds of personal data about you which you provide to us though our website and other platforms operated on our behalf and which we have grouped together as follows:

Identity data may include your name, title, and date of birth;
Contact data may include addresses, personal email addresses, and telephone numbers; and
Technical data may include internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website, and usage data (including information about how you use our website).

We do not collect any sensitive personal data or special categories of personal data about you through our website (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.

HOW WE COLLECT DATA

We use different methods to collect data from and about you including through:

Direct interactions with you, including by filling in forms. This includes personal data you may provide when making any information requests via our enquiries contact email address.
Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions, location and patterns. We collect this personal data by using cookies and other similar technologies.
Technical data (on an anonymised basis) from analytics providers, such as Google based outside the UK.

THE REASONS AND LEGAL BASES ON WHICH WE COLLECT DATA

Your personal data may be processed by Corran or its processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes and on the following legal bases:

Purpose / Activity	Type of data	Legal basis for processing
To respond to queries from you	Identity data Contact data	Performance of (or taking steps prior to entering into) a contract
To improve our website, marketing, customer experiences	Technical data Contact data	Our legitimate interests of pursuing and developing our business
To monitor emails sent to us (including attachments) for viruses or malicious software	Technical data Contact data	Our legitimate interests to protect and maintain the security of our systems
To protect and manage email traffic Technical data	Contact data	Our legitimate interests to protect and maintain the security of our systems
Generally to manage the activities of the company, including by monitoring and recording electronic communications (including telephone calls and emails)	Technical data Contact data	Our legitimate interests of pursuing and developing our business

If we consider it necessary, we will obtain your consent prior to the use of your personal data, we will contact you to request this consent. In such circumstances, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. If you decide to provide your consent, you have the right to withdraw your consent at any time, although that will not affect the lawfulness of processes based on consent before its withdrawal. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

AUTOMATED DECISION-MAKING

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, 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 unauthorised 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.

Where our website, or websites operated on our behalf by third parties, provides links to other websites, we are not responsible for the data protection/privacy/cookie usage policies of those other websites, and you should check these policies on such other websites if you have any concerns about them. If you use one of these links to leave our website, you should note that we do not have any control over that other website.

3. DISCLOSURES OF YOUR PERSONAL DATA

We will not disclose personal information we hold about you to any third party except as set out below.

We may disclose your personal data to other members of our group, to third parties who are providing services to us (including payroll, pension and IT service providers), and backup and disaster recovery service providers.

We may also disclose personal data we hold to third parties:

(a) in the event that we sell any business or assets, in which case we may disclose personal data we hold about you to the prospective and actual buyer of such business or assets; and/or

(b) if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party.

4. DATA SECURITY

Corran has put in place measures to ensure the security of the personal data it collects and stores about you. It will use its reasonable endeavours to protect your personal data from unauthorised disclosure and/or access, including through the use of network and database security measures, but it cannot guarantee the security of any data it collects and stores. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

5. YOUR LEGAL RIGHTS

In certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
Withdraw your consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw such consent at any time. Withdrawing your consent will not affect the lawfulness of processes based on consent before its withdrawal. To withdraw your consent, please contact us at enquiries@corrancapital.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you wish to exercise any of the rights set out above, please contact us at enquiries@corrancapital.com.

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 and keep you updated.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

6. CHANGES

We reserve the right in our sole discretion to amend and/or delete this privacy and cookie policy at any time without providing prior notice to you. We will post the current version of this privacy and cookie policy on the website.

7. CONTACT DETAILS

If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please contact us at enquiries@corrancapital.com.