Privacy Policy

 

PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THIS SITE  

 

This privacy notice (together with our website terms of use and any the cookie policy) aims to give you information on how Oxbow Partners Limited collects and processes your personal data through your use of this website or the provision of our services to you, including any data you may provide through this website. By visiting our website you are accepting and consenting to the practices described in this policy.

WHO WE ARE

www.oxbowpartners.com (“our website”) is a site operated by Oxbow Partners Limited (“we”, “us” or “our”). We are the controller and responsible for your personal data. We are registered in England and Wales under company number 09863607 and have our registered office at 15 Bishopsgate, London, EC2N 3AR. We are on the Information Commissioner’s Office’s register of data controllers under number: ZA155900.

Contact information

If you have any questions in relation to this policy, including any requests to exercise your legal rights, please contact us at: info@oxbowpartners.com or 15 Bishopsgate, London, EC2N 3AR.

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.

CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This policy may vary from time to time so please check it regularly.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THIRD PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

 

  • Identity Data includes first name, last name, title, job title.
  • Contact Data includes email address, postal address and telephone numbers.
  • Usage Data includes information about how you use our website.
  • Technical Data includes your internet protocol (IP) address together with the date, time and duration of your visit.
  • Marketing and Communications Data includes your preferences in receiving marketing from us.

 

HOW IS YOUR PERSONAL DATA COLLECTED?

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

 

  • Direct Interactions: You may give us your Identity and Contact Data by making a request to receive our newsletters by completing the form on our website “Blog Sign-Up”, by corresponding with us by phone, e-mail or otherwise or by giving us your business card.
  • Automated Technologies. When you visit our website we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Please see our cookie policy for further details.

How we use this information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform a contract we have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

 

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To send you our newsletter (a) Identity (first name, last name)

(b) Contact (email address)

(a) Consent

(b) Necessary for our legitimate interests in conducting and managing our business (to develop our business)

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy (a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our client records updated)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To make suggestions and recommendations to you about services or events that may be of interest to you (a) Identity

(b) Contact

Necessary for our legitimate interests (to develop our services and grow our business)
To use data analytics to improve our website, services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

MARKETING

We may use your Identity and Contact Data to form a view on what we think may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).

 

You may receive marketing communications from us if you have requested information from us, purchased services from us or if you provided us with your business card and, in each case, you have not opted out of receiving that marketing.

 

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

Disclosure of your information

We may have to share your personal data with third parties set out below for the purposes set out in the table above.

  • Service providers based in United Kingdom and the United States who provide IT, system administration, invoicing, client relationship management and automated marketing services.
  • Professional advisers including lawyers, accountants and insurers based in the United Kingdom.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

In relation to any other third parties we will only disclose your information where you have given your consent or where we are required to do so by law, or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights.

 

INTERNATIONAL TRANSFERS

Some of the third parties listed above are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Security

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. We have put in place appropriate security measures to prevent your personal data (once received by us) 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.

 

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.

Your rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

 

If you wish to exercise any of the rights set out above, please contact us at info@oxbowparters.com. You will not have to pay a fee. 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.

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