Privacy Policy (clients, contacts and suppliers)

  1. Introduction
    1. We are Yoo Capital Investment Management LLP (referred to as Yoo Capital, we, us and our in this Privacy Policy), a limited liability partnership incorporated in England with company registration number OC426827 and registered office address at 2 Bentinck Street, London, W1U 2FA.
    2. The information set out in this Privacy Policy is provided to individuals whose personal data we process (you or your) as data controller, in compliance with our obligations under Articles 13 and 14 of the General Data Protection Regulation 2016/679 (GDPR).  This policy covers:
      Schedule 1 Data about our clients, and all individuals in respect of whom we have acquired personal information in connection with any services offered by us
      Schedule 2 Data about our directors and staff, and former directors and other staff
  2. Data controller details
    1. We are the data controller in relation to the processing of the personal information that you provide to us. Our contact details are as follows:
      1. Address: 2 Bentinck Street, London, W1U 2FA. Telephone: +44 (0)20 009 0250
      2. Email address: waz@yoo.com(please include “Personal Data Request” in your subject heading).
  3. How we collect your information
    1. Generally, the information we hold about you comes from the way you engage with us, for example by doing any of the following:
      1. providing us, or one of our partners, with information in the course of using our services or providing your services;
      2. providing us, or one of our partners, with information in the course of any marketing event; or
      3. contacting us offline, for example by telephone, SMS, email or by post.
  4. International transfers

    We will not transfer personal data relating to you to a country which is outside the European Economic Area (EEA) unless:

    1. the country or recipient is covered by an adequacy decision of the Commission under GDPR Article 45;
    2. appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 (for example using the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA); or
    3. one of the derogations for specific situations under GDPR Article 49 is applicable to the transfer.  These include (in summary):
      1. the transfer is necessary to perform a contract to which we are a party with you; or with a third party where the contract is in your interests;
      2. the transfer is necessary for the establishment, exercise or defence of legal claims;
      3. you have provided your explicit consent to the transfer; or
      4. the transfer is of a limited nature, and is necessary for the purpose of our compelling legitimate interests.
  5. Retention of personal data

    Unless we are required or permitted by law to hold on to your information for a specific retention period, we may retain your information as follows (as applicable):

    1. Contracts and general correspondence (emails, post and other communications) obtained in the course of providing our services: Such information will be stored for 10 years following completion of the services or termination or expiry of the relevant contract (whichever is later).
    2. Contact details for marketing purposes: Contact information relating to clients and contacts will be held for so long as we believe the information to remain accurate and the individual concerned remains a genuine connection of our business. 
    3. Contracts and general correspondence (emails, post and other communications) obtained in the course of providing your services: Such information will be stored for 6 years following completion of the services or termination or expiry of your contract (whichever is later).
  6. Your rights in respect of your personal data
    1. You have the following rights under the GDPR:
      1. right to access: to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs); and
      2. right to rectification: to have your personal information rectified if it is inaccurate or incomplete; and
      3. right to erasure/”right to be forgotten”: the right to withdraw your consent to our processing of the data (if the legal basis for processing is based on your consent) and the right to request that we delete or erase your personal information from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
      4. right to restriction of use of your information: to stop us from using your personal information or limit the way in which we can use it;
      5. right to data portability: to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and
      6. right to object: to object to our use of your personal information including where we use it for our legitimate interests or marketing purposes.
    2. Please note that if you withdraw your consent to the use of your personal information for purposes set out in our Privacy Policy, we may not be able to carry out our contractual obligations to you or provide you with access to all or certain parts of our services.
    3. If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: www.ico.org.uk.  
  7. Automatic decision making

    We do not make decisions based solely on automated data processing, including profiling.

  8. Changes to this Privacy Policy

    We may amend this Privacy Policy from time to time, so please try to read it when you visit the website (the “last updated” reference tells you when we last updated our Privacy Policy).

Data about our clients, and all individuals in respect of whom we have acquired personal information in connection with any services offered by us

What we collect: We may use your information for the following purposes, based on the following legal grounds: Recipients:
  • Contact details such as your name, and contact details.
  • Employment information such as your position/title and qualifications.
  • If it is necessary for the performance of our contract: for the purpose of negotiating and entering into contractual agreements with you, in the course of providing our services.
  • If it is in our legitimate business interests to do so: for internal record keeping for administration purposes, for the purpose of communications in relation to establishing a relationship, obtaining evidence of identity, communications regarding our service and fees and sending information to you about services which we think may be of interest to you for marketing purposes.
  • Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with legal requirements.
How we share information within the Yoo Capital Group We may share information about you with any company within the Yoo Capital Group (which includes Yoo Capital Investment Management LLP, Yoo Capital Advisors Management Limited and Yoo Capital Management Limited) for the purposes set out in this Privacy Policy only.

How we share information outside the Yoo Capital Group

We may share your personal information with:
  1. regulators or other third parties for the purposes of monitoring and/or enforcing our compliance with any legal, regulatory and statutory obligations;
  2. credit reference and fraud prevention agencies;
  3. any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully;
  4. other parties and/or their professional advisers involved in a matter where required as part of our services;
  5. our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
  6. our service providers and agents (including their subcontractors) or third parties which process information on our behalf;
  7. third parties for any event for which you have expressed an interest in attending; and
  8. another organisation to whom we may transfer our agreement with you or if we sell or buy (or negotiate to sell or buy) our business or any of our assets (provided that adequate protections and safeguards are in place).
  • Identification information
    contained in or provided to us as part of our client ID checks.
  • If it is our legitimate business interests to do so: for the purposes of obtaining evidence of identity and internal record keeping for administration purposes.
  • Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.
  • Consent: if disclosing to other organisations where we cannot rely on any legal obligation to do so.

Data about suppliers and supplier personnel

What we collect: We may use your information for the following purposes, based on the following legal grounds: Recipients:
  • Contact details such as your name, and contact details.
  • Employment information such as your position/title and qualifications.
  • Payment information
  • If it is necessary for the performance of our contract or for the purposes of entering into a contract: for the purpose of negotiating and entering into contractual agreements with you, in the course of receiving services from you.
  • If it is in our legitimate business interests to do so: for internal record keeping for administration purposes, for the purpose of communications in relation to establishing a supplier relationship, obtaining evidence of identity, and making payment.
  • Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with legal requirements.
How we share information within the Yoo Capital Group We may share information about you with any company within the Yoo Capital Group (which includes Yoo Capital Investment Management LLP, Yoo Capital Advisors Management Limited and Yoo Capital Management Limited) for the purposes set out in this Privacy Policy only.

How we share information outside the Yoo Capital Group

We may share your personal information with:
  1. our clients, in the course of providing services for and/or performing our contractual obligations to clients;
  2. regulators or other third parties for the purposes of monitoring and/or enforcing our compliance with any legal, regulatory and statutory obligations;
  3. credit reference and fraud prevention agencies;
  4. any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully;
  5. our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
  6. our service providers and agents (including their subcontractors) or third parties which process information on our behalf;
  7. another organisation to whom we may transfer our agreement with you or if we sell or buy (or negotiate to sell or buy) our business or any of our assets (provided that adequate protections and safeguards are in place).
  • Identification information
  • Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

Last updated 20 January 2020