Regulatory Information, Disclaimer and Privacy

Authorised and regulated by the Financial Conduct Authority, Company Number 09456416

i) Document disclosure

© LBC. All rights reserved. Any unauthorised use or distribution is strictly prohibited.

This document is produced by LBC solely for the purposes of marketing, illustration or discussion with a specific exiting or prospective client and its circulation is restricted to LBC’s clients and their respective advisers. The contents may not be reproduced, distributed or published by you for any purpose except with LBC’s express written permission.

The information and opinions set out in this document are LBC’s or have been obtained or derived from sources that LBC believe to be reliable and accurate, but no warranty of accuracy is given and no liability in respect of any errors or omissions (including any third party liability) is accepted by LBC or any partner, officer or employee of LBC. All opinions expressed herein are subject to market conditions and specific circumstances and are subject to change without notice.

This document is issued by LBC for private circulation to Eligible Counterparties and Professional Clients (as defined in the Markets in Financial Instruments Directive 2004/39/EC) and professional advisers. This document is not prepared for or issued to private or retail clients. It is not for release, publication or distribution, directly or indirectly, in or into the United States of America.

This document does not constitute the distribution of any information or the making of any offer or solicitation by anyone in any jurisdiction in which such distribution or offer is not authorised or to any person to whom it is unlawful to distribute such a document or make such an offer or solicitation.

ii) Investment disclaimer

In respect of any advice and/or recommendation that may be made in respect of investments and/or investment transactions, whether such advice is verbal or written, the following matters are brought to your attention:

The value of investments and any income from them may fall as well as rise. Past performance is not a reliable indicator of future results and investors may not get back the full amount invested. No indication or guarantee, whether express or implied, is made in respect of future performance. In the case of investments likely to yield a high income, the income from such investments may fluctuate in value in money terms. Where an investment involves exposure to a foreign currency, then the value of that investment may rise or fall as a result of a change in the rates of exchange. In the case of higher volatility investments, any loss on realisation may be very high (including total loss of investment), as the value of such an investment may fall suddenly and substantially. Where an investment is made in investments that are not readily realisable, it may be difficult for the investor to deal in that investment or to obtain reliable information about its value or the extent of the risks to which it is exposed.

LBC does not advise on the tax or accounting consequences of borrowings or investments and as such, you should seek independent professional advice regarding such matters.

iii) Terms and Privacy

DISCLAIMER

This World Wide Website (the “site”) is operated by London Bridge Capital Limited (“LBC”). These conditions of use are governed by the laws of England and Wales and you agree that the English courts shall have exclusive jurisdiction in any dispute.

INTELLECTUAL PROPERTY

The copyright notice which is displayed in this site indicates that all materials within the site are the intellectual property of LBC. Such materials may not be copied save to the extent necessary to view them online. However, you may print complete pages of the site as hard copies for your own personal use.

ACCURACY OF INFORMATION

Whilst LBC uses reasonable endeavours to ensure that the contents of this site are accurate and up to date, it does not accept any liability for any information which may not be accurate. LBC is reliant upon third parties for much of the information provided (see below) and reserves the right to change data, references and product specifications at any time.
The contents of this site are for general information and public relations purposes only and do not purport to provide advice, make any offer or otherwise create or lead to the creation of any legally enforceable relationship between LBC and you. No reliance should be placed on any statements made on the site, whether for investment purposes or otherwise. LBC excludes to the fullest extent permitted by law all liability resulting from your access to the site including (without limitation) any loss (financial or otherwise) or damage resulting directly or indirectly from any such reliance.

Certain hypertext links contained in this site will direct you to websites which are not under the control of LBC. Such links are included for your convenience and do not constitute an endorsement by LBC of third-party products or services. Selection of a link will take you out of this site to other websites which LBC has no control over. LBC accepts no liability or responsibility whatsoever for any other websites which may be accessed through the LBC site.

WHO TO CONTACT

If you have submitted personal data through the site and would like that information deleted from our records, please contact us at: info@londonbridgecapital.com

iv) Privacy

INTRODUCTION

London Bridge Capital Limited (“we”, “us”, or “our”) are committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, Companies House).

Where we receive personal data that relates to an individual from a third party, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

SECURITY

We take the security of all the data we hold seriously.

We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal 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.

DATA THAT WE HOLD

We provide services to individuals as well as businesses, and other organisations. The exact data held will depend on the services to be provided.
Where we engage with clients for professional services, we may collect and process personal data in order to satisfy a contractual obligation. We request that clients only provide the personal data that is required for us to fulfil our contractual obligation.

Why do we process data?

Where data is collected for professional services, it is used for a number of purposes, as follows;

  • Providing services to clients. Data is processed in accordance with our letter of engagement between our clients and us, and may sometimes be further clarified in written documentation supplied before any data processing may occur. We provide a range of professional services to our clients, which includes;
  • Client management. When communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the collection of services are provided to our clients are appropriate.
  • Administration. In order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, administering client facing applications, and maintaining internal operating processes.
  • Regulatory. In order to undertake professional services, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include (but is not limited to) the verification of identity of individuals.

What data is processed?

The data that is processed is dependent on the service that is being provided and on the recipient of this service.

  • Services to businesses and other organisations. We process the personal data of individuals associated with our clients. Personal data may include any relevant financial or non-financial information necessary for us to provide our services. As an example, this may include contact details, payroll data, employee information (including details about dismissal), lists of shareholders, customers and suppliers and any other specifically relevant data.
  • Services to individuals. Personal data may include contact details and tax identifiers, information about business activities, investments, and other financial interests, payroll and other income, and any other specifically relevant data.

How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer in order to establish, exercise, or defend our legal rights and the legal rights of our clients.
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

BUSINESS CONTACTS

Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees, are held in our customer relationship management tool (CRM tool).
We will rely on the appropriate condition for processing data.

Why do we process data?

Where personal data on business contacts is held, it is used for a number of purposes, as follows;

  • Promote and develop our offerings.
  • Communication of technical updates.
  • Hosting and facilitating of events.
  • Relationship management.
  • Administration and management.

What data do we hold?

Personal data that may be stored in the CRM tool includes, but is not limited to, name, email address, physical address, job title, and details of the initial meeting.
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected.

OUR PEOPLE

We collect personal data for our people as part of the administration, management and promotion of our business activities.

Applicants

Where an individual is applying to work for London Bridge Capital, personal data is collected through the application process. Data can be collected through forms on the website, details of which can be found in the section describing people who use our website. Data collected via the website will be used for the purposes detailed below.
There are a number of purposes that personal data for applicants are collected.

  • Employment. We process an applicant’s personal data in order to assess their potential employment at London Bridge Capital.
  • Administration and management. We may also use this personal data in order to make informed management decisions and for administration purposes.

Personal data collected for applicants is held for as long as necessary in order to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.

SUPPLIERS

We collect and process personal data about our suppliers, subcontractors, and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.

Why do we process data?

  • Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.
  • Providing services to our clients. Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.
  • Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:
    • managing our relationship with suppliers;
    • developing our businesses and services (such as identifying client needs and improvements in service delivery);
    • maintaining and using IT systems;
    • hosting or facilitating the hosting of events; and
    • administering and managing our website and systems and applications.
  • Security, quality and risk management activities. We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers.  We collect and hold personal data as part of our supplier contracting procedures.  We monitor the services provided for quality purposes, which may involve processing personal data.
  • Promoting our services. We may use business contact details to provide information that we think will be of interest about us and our services.  For example, industry updates and insights, other services that may be relevant and invites to events.
  • Complying with any requirement of law, regulation or a professional body of which we are a member. We are subject to legal, regulatory and professional obligations.  We need to keep certain records to show we comply with those obligations and those records may contain personal data.

What data do we hold?

We will hold supplier’s names, contacts names, and contact details of suppliers.

How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).  Data may be held for longer periods where required by law or regulation and in order to establish, exercise or defend our legal rights.

DATA SUBJECTS WHO USE OUR WEBSITE AND MOBILE APPS

When data subjects visit our website, personal data is collected both through automated tracking and interacting with various forms on the website or apps (collectively referred to as the websites).
Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribe to our service, make an enquiry, comment on publications, apply to work for a London Bridge Capital business and report a problem with our websites.
When individuals visit our websites, certain personal data may be automatically collected. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.

Why do we process data?

There are a number of reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include;

  • Administration. In to administer our site and to improve internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. For example, we use this data to ensure that the website is presented well for individuals and is optimised appropriately.
  • Functionality. In order to allow individuals to use some functionality of our website, certain personal data must be entered in order for features to work as intended.
  • Security. In order to keep our site safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to vouch an individual’s identity.
  • Promote and develop our offerings. Some personal data may be used in order to measure or understand the effectiveness of advertising we serve to individuals, and to ensure that only relevant advertising appears.

What data do we hold?

The data that we hold depends on what data was entered and for what purpose.

Where data was entered in order to engage with functionality of our website, that personal data may include their name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.

Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

SHARING PERSONAL DATA

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
Personal data held by us may be transferred to:

  • Third party organisations that provide applications/functionality, data processing or IT services to us. We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
  • Third party organisations that otherwise assist us in providing goods, services or information.
  • Auditors and other professional advisers.
  • Law enforcement or regulatory agencies or those required by law or regulations.

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

LOCATIONS OF PROCESSING

Where possible, personal data resides within the UK territory but 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 for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.
We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully.  Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

INDIVIDUAL’S RIGHTS

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

  • Individuals may request access to their personal data held by us as a data controller.
  • Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
  • Individuals may request that we erase their personal data
  • Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
  • Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
  • Individuals may request information about, or human intervention into, any automated data processing that we may undertake.

If you wish to exercise any of these rights, please send an email to richard.saint@londonbridgecapital.com

COMPLAINTS

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to richard.saint@londonbridgecapital.com. We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

DATA CONTROLLER AND CONTACT INFORMATION

London Bridge Capital Limited is registered in England under registration no. 09456416 and with its registered address at 6th Floor, Charlotte Building, 17 Gresse Street, London W1T 1QL
If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

London Bridge Capital Limited
6th Floor, Charlotte Building, 17 Gresse Street, London W1T 1QL
The date controller is contactable at this same location.

CHANGES TO OUR PRIVACY STATEMENT

Updates to this privacy statement will appear on this website.  This privacy statement was last updated on 10th April 2018.