Privacy Notice – how we process your personal data

Acorn Capital Advisers Limited (we, us or our) are committed to protecting your personal data and respecting your right to privacy. This Privacy Notice (Notice) explains who we are, what personal data we may process, how we may use or share your personal data and how you can exercise your rights in relation to your personal data.

This Notice applies to the processing of personal data by us in the course of our business, including when you visit or interact with our website (www.acorncapitaladvisers.com), submit correspondence to us or receive correspondence from us or otherwise engage with us, whether as a client, prospective client, supplier or otherwise. This Notice also applies to the personal data of representatives of other companies with whom we interact. 

If you have any questions or concerns about our use of your personal data, then please contact us using the details provided at the bottom of this Notice. 

1. WHO WE ARE

Acorn Capital Advisers Limited is a private limited company registered in England and Wales under company number 10220193 and has its registered office at Richmond House, Walkern Road, Stevenage, Hertfordshire SG1 3QP. For the purposes of the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (GDPR) we are the data controller of the personal data we process about you and we are registered with the Information Commissioner’s Office (ICO) with registration number ZA678477. 

2. INFORMATION WE MAY COLLECT ABOUT YOU

The personal data we may collect depends on the context of your interactions and engagement with us. We may collect and process the following personal data:

Information you provide to us 

You may provide us with personal data when corresponding with us by phone, letter or email or from general interactions with the Website. We will also collect personal data when we enter into contracts or negotiations to either receive or provide products and services. We may collect further personal data during the administration of such contracts. 

The personal data we process may include, but is not limited to:

• Identity information: such as name, title and proof of identification

• Contact information: such as address, email address and phone number

• Personal information: such as age, gender, employment information and details of family members

• Financial information: such as existing investments, bank details and other financial records

• Client-specific information: such as risk appetite, lifestyle information and investment goals

• Transaction information: such as details of past orders, transactions or interactions

• Miscellaneous information: such as the content of communications and information created in the course of our dealings with you [(this may include any CCTV footage if you visit our offices)]

You are not obliged to provide us with any personal data. However, there may be cases where we need certain information in order to enter into a contract or administer the terms of such contract. In such cases, if you fail to provide certain information, we may not be able to enter into a contract with you or the entity you represent, or may be prevented from performing aspects of it.

Where you provide us with information about any third parties (such as family members or other dependants) we will process their personal data in accordance with this Notice. It is your responsibility to ensure that you have directed any third parties to this Notice before you provide us with their personal data. 

Information we automatically collect about you

When you use or interact with our Website, we may automatically collect the following information from your device:

• Technical information: including the IP address used to connect your computer to the internet

• Information about your visit: including the date and time of your visit, page response times, 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

This information enables us to provide the Website, better understand the visitors to the Website, maintain the security and functionality of the Website and improve performance and user experience of the Website. 

Some of this information may be collected using cookies and similar tracking technologies, as explained further in our Cookie Notice [linked here]. 

3. HOW WE USE YOUR PERSONAL DATA 

We use your personal in the following ways:

• Website functionality and improvement

  • to administer our Website and for internal operations, including troubleshooting, data analysis and testing

  • to improve our Website to ensure that content is presented in the most effective manner for you and for your computer

• Entering into and administering relationships with our clients

  • to onboard new clients and undertake necessary checks

  • to provide clients with the requested services during our relationship with them and comply with our obligations under agreements with clients

  • to enforce our rights under any contracts with clients

  • to communicate with clients and update them as required

  • [to send marketing communications with relevant products and services we can offer]

• Entering into and administering relationships with suppliers and other third parties

  • to contract with suppliers, service providers and others

  • to perform our duties and enforce our rights under any agreements

  • to correspond with suppliers, service providers and others about our agreements with them

• Compliance with our legal obligations

We do not use your personal data for the purposes of automated decision making or profiling. 

4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

The list above outlines how we process your personal data. Our legal basis for the processing activities described above will depend on the personal data concerned and the specific context in which we process it. The most common legal bases that we may rely on are set out in the table below. 

We may also process a limited amount of special category personal data (that is personal data relating to: racial or ethnic origin; political opinions; religious or philosophical belief; trade union membership; data concerning health or sexual orientation). We will only process such personal data where you elect to provide us with it, thereby giving your explicit consent for the processing. An example of where this may occur is if your investment strategy or risk appetite is driven by a health condition that you make us aware of or if you refer to a spousal relationship (which may involve us processing personal data relating to sexual orientation). Any special category personal data included in any correspondence that is sent to us will be processed on the basis that your sending of such correspondence signifies your consent. 

If the provision of personal data is necessary to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you of the possible consequences if you do not provide your personal data. 

If you would like further information concerning the legal basis on which we collect and use your personal data, please contact us using the details provided under the Contact Us heading below.

5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may share your personal data to the following categories of recipients: 

• businesses who we refer you to and other members of our collective where you wish to engage them to provide services to you

• legal and other advisers where necessary in order to obtain advice in connection with the operation of our business

• suppliers and subcontractors who provide data processing services to us (for example to support delivery and functionality of the Website and who provide us with IT or other operational services)

• actual or potential buyers and advisers in connection with any actual or proposed purchase, merger or acquisition of any part of our business or any corporate restructuring

• competent law enforcement body, regulatory, government agency, court or other party where we are under a duty to disclose or share your personal data to: comply with any legal obligation; enforce or apply our terms and conditions; exercise, establish or defend our legal rights in accordance with our legitimate interests; or protect your vital interests or those of any other person

• any other person where we have your consent or an alternative legal basis

6. SECURITY

We take the security of your personal data seriously. We have put in place appropriate technical and organisational measures to safeguard and secure the information we process and to protect your personal data from being accidentally lost, altered, disclosed or used or accessed in an unauthorised way. We limit access to your personal data to those who have a business need to access it.

If we experience any intrusion of our information systems or otherwise suffer a breach of our data security, we have in place specific procedures designed to deal with such a breach, including protecting the personal data within our control and, where we are legally obliged or we think it appropriate to do so, notifying you and any applicable regulatory authority in a timely fashion.

Please note that, despite our best efforts, we cannot guarantee the security of information being exchanged over the internet and, where the Website contains links to other sites, clicking on those links may allow third parties to collect or share data about you. When you leave our Website, we strongly advise you to review the privacy notice of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

7. INTERNATIONAL DATA TRANSFERS

Your personal data may in certain limited circumstances be transferred to, and processed in, countries outside the EEA. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

We have taken appropriate safeguards to ensure that your personal data will remain protected in the recipient jurisdiction. In particular, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection, where there are specific contractual clauses in place to protect the transfer of your personal data or we may otherwise do so lawfully. For more information about the particular protections in place for specific transfers of personal data, please contact us using the details provided under the heading Contact Us below. 

8. RETENTION AND DELETION

We retain personal data that we process about you were we have an ongoing legitimate business need to do so (for example, to continue to provide you with our services, maintain appropriate records or comply with applicable legal, tax or accounting requirements). 

When we no longer have a legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data until deletion is possible. 

9. YOUR DATA PROTECTION RIGHTS

You have the following general data protection rights in respect of the personal data we control about you, although please note that not all rights are absolute: 

• Right to access, correct, update and delete your personal data at any time

• Right to object to processing of your personal data or ask us to restrict processing of your personal data

• Right to request portability of your personal data

• [Right to opt out of marketing communications from us by following the unsubscribe link in the emails]

If you wish to exercise any of the rights set out above, then please contact us using the details provided at the bottom of this Notice. 

If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

You have the right to complain at any time to the relevant supervisory authority for data protection matters. In the UK, this is the Information Commissioner’s Office (ICO). We would always appreciate the opportunity to deal with any complaints in the first instance but you can contact the ICO at any time by calling 0303 123 1113 or visiting https://ico.org.uk/. 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. 

10. CHANGES TO OUR PRIVACY NOTICE

We will update you about any changes to this Notice by updating this webpage. You can see when this Notice was last updated by checking the “last updated” date displayed at the bottom of this Notice.

11. CONTACT US

To contact us with your questions or comments regarding this Notice or our data processing practices please email us at contact@acorncapitaladvisers.com.

Last Updated January 2021