Privacy Policy

Version: October 2018

This privacy notice was last updated on 23rd October 2018.

This privacy notice sets out the basis on which we collect and process your personal data through the use of our website, our digital applications, and/or signing up for newsletters and other marketing activities either in person or online.

Any changes we make to this policy in the future will be posted on this page so please check this page regularly.

Who we are

Southgate Capital is the Data Controller responsible for your personal data within the context of the data you choose to directly pass to us through our website, digital applications, marketing activities, by email, phone or face to face.

Southgate Capital will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means Southgate Capital determines the purposes and way in which any personal data are, or will be, processed.

Our registered office is at 12-14 Ridgeway Street, Douglas, Isle of Man, IM1 1EN.

If you have any questions about this privacy notice, the use of your personal information, your dealings with our website or our digital applications, you can contact us at phillip@southgatecapital.co.

Our principles of data protection

Southgate Capital are committed to safeguarding the privacy of our website visitors and service users and complying with the General Data Protection Regulation and the Data Protection Act 2018.

Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you the best user experience.

We have published this notice to help you understand

how and why Southgate Capital collect information from you;
who we share your information with, why and on what basis; and
what your rights are.

What information we collect and why?

Information you provide to us directly

When you visit or use some parts of our website and/or services we might ask you to provide personal data to us. For example we ask you for your contact information when you submit an enquiry, submit your CV for a job application, submit a quote request, book an appointment, give feedback, send us a brief etc...

Where you are requested to fill in form (either online or offline), it’s your choice as to which fields to complete and with what data.

If you don’t want to provide us with your personal data you don’t have to but it might mean you can’t use some parts of our website or service.

Information we collect automatically

We collect some information about you automatically when you visit our websites or use our services, like your IP address and device type. We also collect information when you navigate through our website and digital applications such as what pages you looked at and what links you clicked on and so on. This information is useful as it helps us get a better understanding of how you use our websites and services so that we can continue to provide the best experience possible.

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more, take a look at our cookie policy.

Information we get from third parties

The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publically available materials. We may use this information to supplement the personal data we already hold on you, in order to better inform, personalise and improve our services and to validate the personal information you provide.

Where we collect personal data, we’ll only process it:

To perform a contract with you, or
Where we have legitimate interests to process the personal data and they’re not overridden by your rights
In accordance with a legal obligation or
Where we have your consent

How do we use your information?

Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:

Contract - your personal information is processed in order to fulfil a contractual arrangement
Consent – where you agree to us using your information in this way
Legitimate Interests - this means the interests of Southgate Capital in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way e.g. to transfer your data to certain Third Parties in order to deliver you the requested service
Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.

Here is a list of the ways that we may use your personal information, and which of the reasons described above we rely on to do so. Where we list legitimate interests as a reason, we also describe below what we believe these legitimate interests are.

What we use your personal information for	Our reasons (legal basis)	Our explanation of Southgate Captial’s legitimate interests
To communicate with you or to market to you	Consent or Legitimate Interest	Marketing communications in accordance with your marketing preferences Asking you for feedback or to take part in research we are conducting
		To advertise to you using targeted display advertising
To provide you with services	Contract or Legal Obligation	In order to perform a contractual relationship Provide you with the information you’ve requested Operational communications like changes to our websites and services, security updates or assistance with using our services Billing Communications
To analyse, aggregate and report	Legitimate Interest	Monitoring and improving our website and services (whether obtained directly or from third parties). This is typically but not always anonymised analytics and reports. To develop new sites and offerings in order to offer you new and more effective services.
To detect, investigate and report financial crime (e.g. Fraud) and ensure compliance with a legal obligation	Legal Obligation / Legitimate Interests	Developing and improving how we deal with financial crime. Complying with any legal obligation placed on us by regulators. Complying with any regulations that apply to us. Complying with legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Process efficiency in dealing with such activity, and to make service and process improvements.
To undertake website and or service personalisation	Legitimate Interests	Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites. Defining types of customers for new products or services
Maintaining network and data security	Legitimate Interests	To maintain the security of our network this in turns helps us to maintain the safety and confidentiality of your information.
Logistics planning, demand forecasting, management information and research	Legitimate Interests	We use information about buying habits, services bought and volumes, to help us to respond to demand, ensure the right products get to the right areas and to help us plan our ranges.

Who we share your information with and why

There may be times when we need to share your data with third parties. We will only disclose your personal data to:

Other companies in the Southgate Capital where it is a shareholder or stakeholder and for the purposes of performing its contractual obligations and services
Third party providers and partners who assist and enable us to use the personal data to support delivery of services or functionality of services or to market services and products to you
Regulators, law enforcement, government agencies, courts or other third parties where we think its necessary to comply with applicable laws or regulations or to exercise, establish or defend our legal rights
An actual or potential buyer and or its advisers in connection with a purchase, merger or acquisition of any part of our business
Other people where we have your consent
Payment processors
Sub processors who are vetted for GDPR compliance
Debt Recovery, Credit Checking Services and Fraud Prevention Services

Transfers to third countries

Southgate Capital operates Internationally.

Some of the information you provide to us may be transferred outside the European Economic Area. This is a transfer to a “third country”.

Whilst your data is held in UK, Ireland or Isle of Man data centres, our colleagues and partners in third countries may access it to undertake services necessary for the fulfillment of our contracts and services.

Southgate Capital also works with suppliers and partners who may make use of cloud and/or hosted technologies. We undertake data security due diligence on our partners and ensure that these partners conform to appropriate accreditations.

Wherever transfers of data to third counties occurs Southgate Capital will put in place an appropriate contractual provisions to ensure that there are strict rules regarding both the confidentiality and security of your information. To find out more please contact us at phillip@southgatecapital.co.

Your rights

Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.

For more information or to exercise your data protection rights, please contact us at phillip@southgatecapital.co.

You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.

Keeping in touch with you

We want to keep you up to date with information about new products and improvements to our websites and services. When you initially contact us over the website we will ask you if you want to receive this type of marketing information.

Southgate Capital will not share your information with companies outside of those listed in “Who we share your information with and why”.

If you decide you do not want to receive this marketing information you can request that we stop by writing to the Data Protection Officer at the address provided above or emailing phillip@southgatecapital.co.

You may continue to receive mailings for a short period while your request is dealt with.

How long we keep your information

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your information above. The only exceptions to this are where:

the law requires us to hold your personal information for a longer period, or delete it sooner;
you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

Security

Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens.

What are your rights

You are entitled to request the following from Southgate Capital, these are called your Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk

Right of access –to request access to your personal information and information about how we process it
Right to rectification –to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased. Email phillip@southgatecapital.co
Right to restriction of processing – to restrict processing of your personal information
Right to data portability - to electronically move, copy or transfer your personal information in a standard form
Right to object - to object to processing of your personal information
Rights with regards to automated individual decision making, including profiling – rights relating to automated decision making, including profiling

If you have any general questions about your rights or want to exercise your rights please contact phillip@southgatecapital.co

You have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website www.ico.org.uk where your personal information has or is being used in a way that you believe does not comply with data, however, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.