Privacy Notice

1.  Who we are

Sephton Capital LLP (Sephton) is the Controller of the personal data you provide to us.  If you have any questions about this Privacy Notice or the information we hold about you please contact us using the details set out below:

Mail:     The Privacy Officer, Sephton Capital LLP, 30 Park Drive, London SW14 8RD


2.  What types of data do we use?

We collect & process personal data in the course of providing our services to clients and customers, and procuring services needed for our business from service providers. Greater detail of the range of services and circumstances involved is set out in section 4 below.  The personal data that we may collect, use, store and process about you may include:

  • Employment or business details and work history/background;
  • Personal details such as name, address, date of birth, email address and telephone number. Other details needed to comply with statutory or employer reporting obligations may also be included;
  •  Information on trading or other financial activity;
  •  Financial information (financial position and history);
  • Documentary data (can include passport, drivers licence or other forms of identification);
  • Goods or services;
  • Public records (or openly accessible data) such as the Electoral Register and Companies House;
  • Historical information i.e. previous names and addresses.

3.  Consequences of not providing some types of information

Where we need to collect your personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to provide the services you sought.  In this case we may have to cancel the services but we will tell you if this is the case.

4.  How we will use your personal information

We obtain, use, keep and keep updated personal data where we need it for a specific purpose. We are only able to use your personal information if we have a proper reason or basis for doing so.  This is called a lawful basis and the regulations require that we have a lawful basis so that your privacy is protected.  The lawful bases under which we will use your data are:

  • To fulfil a contract with you; and/or
  • Where it is our legal duty; and/or
  • When it is in our legitimate interest.

Most commonly we will collect or use your information in the following ways and areas:

  • Providing investment management services and advice;
  • Monitoring clients’ investments and reporting on them;
  • Liaising with investee companies;
  • Maintaining our accounts and records;
  • Invoicing for services;
  • Filing reports and returns with the tax and statutory authorities;
  • Managing and supporting our employees;
  • Promoting our services and dealing with enquiries;
  • Networking;
  • Evaluating and procuring services from suppliers, professional advisers & consultants.

5.  Storing your information

We will keep your personal data securely and for as long as is necessary for the purposes for which it was collected, taking into account:

  • The types of data collected;
  • The requirements of our business and the services provided;
  • Our contractual obligations to you;
  • Our statutory, regulatory or legal obligations under UK and EU law
  • The lawful basis under which we collect and use the data.

6.  Sharing your information

We may pass your personal data to third party external organisations where we are required or permitted by law, where it is necessary to administer the relationship between us, when we use third party service providers (such as data processors, accountancy firms, tax advisers and lawyers) to supply or support our services, or where we have another legitimate interest in doing so. Third party service providers undertake appropriate and commercially reasonable security measures in relation to personal data.

7.  Your rights

You are provided with a number of different rights under the data protection laws in relation to your personal information.  These allow you:

  • To access your information;
  • To request we correct your information;
  • To request that we erase your information;
  • To object to the processing of your information;
  • To request a restriction in the processing of your information; and
  • To request a transfer of your information..

If you wish to exercise any of these rights please make written application to the contact details provided in section 1 above of this Notice. Corrections and updates will be made at the earliest opportunity. Other requests and objections will be considered on a case by case basis. Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights.  We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request.  We may also need to seek further information from you to confirm your identity before we release any personal information.  This does not affect your right to make a complaint.

8.  Complaints

You have the right to complain about the processing of your personal data. If you wish to do so please contact us in the first instance using the details in section 1 above. If you are still unsatisfied you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.