This document sets out the policies followed by Isomer Capital LLP (“Isomer”) in implementing the privacy and information security requirements under the General Data Protection Requirements, the Data Protection Act and any other relevant legislation and guidance including GCHQ’s 10 Steps to Cyber Security, the ISO27000 family of standards and the relevant regulatory requirements set out by the Financial Conduct Authority in the Principles for Business, Systems and Controls and Conduct of Business handbooks as well as FG 16/5 Guidance for Firms Outsourcing to the ‘Cloud’ and Other Third-Party IT Services. It is the policy of Isomer to comply with any legislation concerning the protection and prevention of loss or theft of information retained and stored by Isomer
What kind of information does Isomer collect, and how?
Isomer collects contact information from its investors and partners from time to time. Contact details are collected directly from individuals and corporations that Isomer meets.
The types of personal information and data may include, without limitation:
- Basic personal information including name, address, date of birth, contact details
- Identity documents such as passport copies
- Education and employment history
- Business activities
- Financial information including investment track record
Isomer does not collect information via third parties. The firm is registered as a data controller with the Information Commissioner’s Office (“ICO”) under registration number ZA114620 as a data controller and complies with the relevant data protection principles.
How is the information used?
Personal information and/or data may be used to:
- Stay in touch with investors, investees and partners by post, telephone, electronic mail, etc., in connection with your relationship;
- Facilitate and manage Isomer’s business relationships. This may include sharing information internally as well as disclosing it to Isomer’s professional advisor; and
- Facilitate business operations, including conducting due diligence, making investment recommendations, assessing and managing risk and fulfilling legal and regulatory requirements (including KYC and AML requirements).
Is this information shared, or transferred outside the EEA?
The personal information held by Isomer may be shared with:
- Professional advisers such as lawyers and fund administrators, with whom Isomer has a contractual relationship.
- Cloud-based service providers who hold personal information on our behalf, such as file storage and CRM tools.
Isomer does not transfer information to parties outside of the EEA, although the personal information held on cloud-based tools may located on servers outside of the EEA. Isomer only works with firms adhering to data protection laws.
How long is the information retained?
Personal information is retained by Isomer only as long as it remains necessary in the conduct of its business, or as required by applicable law or regulation.
What rights do individuals and entities have in relation to their data?
Under GDPR individuals and entities have the right to access information stored about them. They are entitled to ask Isomer about:
- The nature of the personal data;
- The purpose for processing this personal data; and
- The existence of any third parties with whom personal data may be shared.
The right to access personal data, correct it, object or cancel the data kept by Isomer can be exercised by contacting Isomer’s Compliance Officer or any Isomer executive.
If you have a complaint regarding any aspect of the personal data Isomer collects or this Privacy Notice, please contact us at the address listed below in ‘Contacting Isomer in relation to this policy’.
Complaints may also be made to the ICO using their online form: https://ico.org.uk/make-a-complaint/. Alternatively, complaints can be sent to the ICO at the following address:
Information Commissioner’s Office
Cheshire SK9 5AF
Contacting Isomer in relation to this policy
The contact person for matters relating to data and more generally this Privacy Notice shall be Isomer’s Compliance Officer. You may contact us via email (firstname.lastname@example.org) or you may send a letter to the following address:
c/o Compliance Officer
100 Victoria Street, 7th Floor
London SW1E 5JL
Changes to Isomer Capital’s Privacy Notice
Isomer aims to meet high standards of compliance with regulation so our policies are under frequent review. From time to time this privacy notice may be changed. The page will be updated periodically to reflect the latest version of the Privacy Notice.
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