Independent Franchise Partners, LLP (“we” or “us”) is committed to protecting and respecting your privacy. This notice (together with 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 as a data controller.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation (Regulation (EU 2016/679)), the Data Protection Act 2018 or any other applicable data protection legislation (together, the “Act”), the data controller under this Notice is Independent Franchise Partners, LLP of Level 1, 10 Portman Square, London, W1H 6AZ, United Kingdom.
We may collect and process the following data about you:
We may collect and process your personal data if you are an individual who accesses the website www.abetterkirin.com (“the Website”). Use of the Website does not require you to submit your personal data to us, but if you submit a query via the Contact form, we will also collect your name and contact details, including where relevant your job title, business contact details and details of any organisations that you represent, and any personal data contained in free text boxes that you fill in, including any enquiries or comments that you submit via the Website.
You may give us information (including personal data) about you by filling in forms on the Website, when meeting with us in person or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, title, e-mail address, phone number, as well as any other personal information you choose to give us.
Use of the Website does not require you to submit your personal data to us, but if you submit a query via the Contact form, we will also collect your name and contact details, including where relevant your job title, business contact details and details of any organisations that you represent, and any personal data contained in free text boxes that you fill in, including any enquiries or comments that you submit via the Website.
With regard to each of your visits to our Website we may automatically collect the following information:
technical information, including the IP address used to connect your computer or device to the internet, your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
information about your visit to the Website, including the full URL clickstream to, through and from the Website (including date and time); pages you 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.
We may collect any phone number used to call us.
Where you are a visitor to our Website, we use information held about you for the following purposes:
to improve the Website and ensure that content from the Website is presented in the most effective manner for you and for your device;
to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to allow you to participate in interactive features of the Website, when you choose to do so;
as part of our efforts to keep the Website and related IT architecture safe and secure, including for the investigation of any alleged security breaches, and
to identify you when you contact us.
We use this information for the purposes set out only where this is necessary for our legitimate interests or those of a third party, and where such legitimate interests are not overridden by your interests, fundamental rights or freedoms.
Accordingly, you understand that we may use your personal data for these purposes, provided that we act in a fair, transparent and accountable manner and take appropriate steps to prevent such activity having any unwarranted impact on you and also noting your right to object to such use, as discussed below.
Given the specific purposes for which we envisage using your personal data, we do not anticipate being required to obtain your consent to do so. Should we wish to use your personal data for other specific purposes that require your consent, we will contact you to request this.
We will not transfer, disclose, sell or distribute your personal data to third parties other than as set out in this notice, unless we have your permission or are otherwise required or permitted to do so by law.
We may disclose your personal data:
to analytics and search engine providers that assist us in the improvement and optimisation of the Website;
to competent authorities (including tax authorities), courts and bodies as required by law or where requested; or to protect the rights, property, or safety of Independent Franchise Partners, LLP, its customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction;
if Independent Franchise Partners, LLP or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
The personal data that we collect from you 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 service providers. Such staff may be engaged in, among other things, the provision of support services. Where your personal data is transferred outside the EEA, in particular to any jurisdiction which is not deemed to offer equivalent protection to your personal data as provided for under the Act, we will always ensure that such transfers and any subsequent processing of your personal data will be carried out in full compliance with the Act. This may include us entering into the EU Standard Contractual Clauses for the transfer of data from controllers to processors, the template text of which is available here: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1401799946706&uri=CELEX:32010D0087.
The Website may, from time to time, contain links to and from the websites of our business partners, affiliates and other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
It is within your rights under applicable law, in certain cases, to request access to your personal data that we process, to request details about such personal data, including the purposes and potential recipients of this data, to have such personal data rectified or deleted, to restrict or object to the processing of your personal data, as well as to request a copy of your personal data in a standardised format so that it can be provided to another vendor.
Please note that the right for your data to be erased (the "right to be forgotten") that applies in some contexts under the Act is not likely to be applicable to most, if not all, of the personal data you provide to us, given the specific nature of the purposes for which we use that data, as described above.
If you live or work in an EU Member State, you may also have the right to lodge a complaint with your national or local data protection authority or that of the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by us infringes the Act.
Further rights are covered in the EU Standard Contractual Clauses referenced above.
Where you have provided (and we have relied upon) your consent to process your personal data, you may withdraw your consent at any time by contacting us at the address stated below and (where no other legal basis exists upon which we can process your data) we will apply your preferences going forward. However this will not affect the lawfulness of any processing carried out before you withdrew your consent. In some circumstances, withdrawing your consent or objecting to the processing of your personal data, or requesting its deletion, will mean that you cannot take advantage of certain Services or investment opportunities, and we may need to suspend or terminate your access to the Services or to the Website.
Where we require your personal data to comply with AML or other legal requirements, failure to provide this information means we may not be able to accept an investment.
If you wish to exercise any of your legal rights set out above, please contact email@example.com or write to The General Counsel, Independent Franchise Partners LLP, Level 1, 10 Portman Square, London W1H 6AZ, UK.
As we must be able to identify the person making the request, we may require you to confirm your request by different means, by contacting us at the address stated above. Due to technological constraints and/or information security considerations, it may be inappropriate to use social media to supply information in response to any request by you for access to information, and so please provide an alternative delivery address for our response.
We will retain your personal data for as long as the Website remains available, to deal with subsequent enquiries or disputes, or longer where additional legal/regulatory obligations require us to do so.
Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
As we do not process personal data on a large scale, we are not required to designate a data protection officer. However, questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org or The General Counsel, Independent Franchise Partners LLP, Level 1, 10 Portman Square, London W1H 6AZ, UK.
Issued by Independent Franchise Partners, LLP, authorised and regulated by the Financial Conduct Authority in the United Kingdom. Independent Franchise Partners, LLP is registered with the United States Securities and Exchange Commission. The information displayed on this website is for eligible counterparties and professional clients only and is not for retail clients. The services described may not be available to you, or suitable for you. Nothing in this document constitutes investment advice nor does it represent any offer to provide services to buy or sell securities of any kind. Investments in the portfolios managed by Independent Franchise Partners, LLP may fall as well as rise and investors may not be able to recover their invested capital.© Independent Franchise Partners, LLP, All Rights Reserved. Registered in England and Wales, Partnership No. OC344319.