Absail Partners Ltd (company number 9898096) and Absail Capital Ltd (company number 9922355) at 1918 Portland House, Bressenden Place, London SW1E 5RS United Kingdom (us or we) are committed to ensuring that your privacy is protected, and all data collected by us will be processed in accordance with this privacy and cookies policy. Please read this policy carefully to ensure you understand our views and practices regarding your personal data and how we will treat it.

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR), the data controller for both firms is Dr Eric D. Warner. We can be contacted at ericdw@absailpartners.com or on 0208 43306857.

By visiting our Site or by providing us with information you are consenting to and accepting the practices described in this Privacy and Cookies Policy.

1 WHAT INFORMATION DO WE COLLECT AND WHY DO WE COLLECT IT?
1.1 We may collect and process the personal information about you, including:
1.1.1 your name, email address and telephone number, that you give us by exchange of business cards, email correspondence, or by filling in the contact form on our website https://www.absailpartners.com (our Website);
1.1.2 information that you provide by filling in forms on our Website, requesting further services or reporting a problem with our Website;
1.1.3 information that you provide when you use our professional services as a client;
1.1.4 information received in correspondence that you send to us;
1.1.5 information provided to us as part of a job or student placement application you make;
1.1.6 information received during certain calls to and from us ;
1.1.7 information concerning your visits to our Website (including but not limited to traffic data) and the resources that you access, including information we may automatically collect such as technical information including the internet protocol (IP) address used to connect to the internet, information about your visit including the full Uniform Resource Locators (URL) clickstream and your search history on our Website.
1.2 We may also collect information about you in other ways, for example:
1.2.1 if you are a customer of one of our clients, and we are undertaking business services on our client’s behalf;
1.2.2 if you have any other dealings with one or more of our clients which are related to the business services which we are providing to our client or on our client’s behalf;
1.2.3 indirectly, through one of our people, a client or a third party;
1.2.4 if you are a supplier of ours, from that supplier relationship;
1.2.5 from publicly available sources, for example the electoral roll or Companies House.

2 HOW WE USE YOUR PERSONAL DATA
2.1 When you provide us with your information we will use it for the purpose of developing our business relationship and/or administering your query and responding to you. We therefore have legitimate interests in processing your personal data in this way, since if we do not process your data we will be unable to do this.
2.2 By providing us with information, including your contact details etc, you are consenting to receive information from us. Any consent that you provide can be withdrawn at any time by clicking “unsubscribe” on any marketing email we send to you, or emailing us at ericdw@absailpartnetrs.com. Withdrawing your consent does not affect the lawfulness of any processing which occurred prior to the withdrawal of consent.
2.3 The way we process your personal data we collect as set out above varies depending on our relationship with you. In each case the purposes for which we request the information will be clear from the context in which it is acquired. These include:
2.3.1 providing our services to you or an entity for which you work;
2.3.2 verifying your identity;
2.3.3 keeping a record of the services you have subscribed to and delivering services you may have requested;
2.3.4 administration, billing and record-keeping purposes;
2.3.5 communicating with you by telephone, email, fax or post;
2.3.6 meeting our legal, regulatory and contractual obligations arising from any our relationship with you (for example under anti-money laundering legislation);
2.3.7 providing and improving customer service and support;
2.3.8 administering our Website, enhancing operational capabilities and for internal operations;
2.3.9 verifying or enforcing compliance with this Policy and applicable laws;
2.3.10 to inform you of other products, services or events which we think may be of interest to you (unless you have opted out of receiving such marketing communications).
2.4 We may also use your personal information:
2.4.1 to help us provide you with the best possible service;
2.4.2 to notify you about changes to the services we offer;
2.4.3 to ensure that the content from our Website is presented in the most effective manner for you and your computer;
2.4.4 as part of our efforts to keep our Website safe and secure; and
2.4.5 for analytical and statistical purposes.

3 DISCLOSURE OF INFORMATION
3.1 We will only supply your personal information to a third party:
3.1.1 where we need to share the information to provide a product or a service requested by you;
3.1.2 where we need to send the information to persons or organisations who work on our behalf to provide a product or service to you, but such persons or organisations may only use this information in order to provide such product or service and not for any other purpose;
3.1.3 companies which perform marketing services on our behalf or with whom we have joint marketing agreements, where we have your consent to share the information;
3.1.4 if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
3.1.5 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of our company, our customers or others, including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

4 WHERE WE STORE YOUR INFORMATION
4.1 The data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers for the purposes set out above only. Any such third party will treat your personal data in a way which is consistent with the UK and EU’s laws on data protection by virtue of an adequacy decision by the European Commission, registering with the EU-US Privacy Shield, the use of standard contractual clauses approved by the European Commission or another method that ensures adequate protection.
4.2 If we do not correspond or hear further from you, we will retain your information for six (6) years, after which time it will be destroyed.

5 LINKS TO OTHER WEBSITES
5.1 This policy extends only to our Website and does not cover your use of, provision of data to and collection of your data on any other website.
5.2 Our Website may from time to time contain links to and from other websites. If you follow a link to any of these websites please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You should always check these policies before you submit any personal data to any third party website.

6 YOUR RIGHTS IN RESPECT OF YOUR INFORMATION
The GDPR gives you a number of rights in respect of your data, including:
6.1 Right to access
6.1.1 You have the right to access the information we hold about you. If you would like a copy of this information please contact. We may request proof of your identity before sharing such information.
6.2 Right to rectify your personal data
6.2.1 If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information.
6.3 Right to be forgotten
6.3.1 You may ask us to delete information we hold about you in certain circumstances. It may not be possible for us to delete all of the information we hold about you where we have an ongoing relationship. However, please contact us and we will do our best to assist with your request.
6.4 Other rights
6.4.1 In addition to the above, you may also ask us to stop or restrict processing of the information we have about you. You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any other information on these aspect of your rights, please contact us.

7 CONTACT
7.1 If you have any questions, want to exercise any of your rights or make a complaint, please contact us using the details at the beginning of this policy.
7.2 If we are unable to resolve your complaint you may contact the Information Commissioner’s Office at the Exchange Tower, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tele: 0303 123 1113.

8 CHANGES TO THIS PRIVACY POLICY
This policy may be reviewed and amended from time to time. As a result of improvements we make to our services, changes in the law or developments in technology, we may change the information we hold about you, the method and purposes for which we process such information. If we make any substantial change in the way in which we use your personal information we will notify you by email.

9 LAW AND JURISDICTION
Your use of the Website and the policy is subject to the laws of England and Wales and the exclusive jurisdiction of the English courts regarding any disputes that may arise under it.

Absail Capital Ltd “Absail” (FRN:732573) is an Appointed Representative of Sturgeon Ventures LLP. Sturgeon Ventures LLP (FRN 452811) is authorised and regulated by the Financial Conduct Authority.
Absail Capital Ltd is registered in England and Wales with its registered office at Suite 1918, Portland House, Bressenden Place, London SW1E 5RS. Tel: + 44 (0) 208 433 6857