FC CORPORATE FINANCE PRIVACY POLICY

BACKGROUND:

FC Corporate Finance Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone whose personal data we process and/or store, including visitors to our website, and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

2. Information About Us

We are FC Corporate Finance Limited, a company registered in England & Wales under company number 09415193. Our website is owned and operated by us.

Registered address and trading address: 30 Chorley New Road, Bolton, BL1 4AP, England.

VAT number: 207-9219-07.

Data Protection Officer: Iain Campbell.

Email address: ic@fccorporatefinance.com.

Telephone number: 01204 267766.

Postal Address: as above.

We are a member of the Institute of Chartered Accountants of Scotland (“ICAS”) and in our conduct are subject to its Code of Ethics which can be found at www.icas.com/ethics/icas-code-of-ethics.  We observe and act in accordance with the bye-laws and regulations of ICAS.

We are not authorised by the Financial Conduct Authority. However, as we are licensed by the Institute of Chartered Accountants of Scotland, we provide certain investment services that are complementary to, or arise out of, the professional services we provide to our clients.

We have a policy of professional indemnity insurance with Arch Insurance Company (Europe) Limited of 60 Great Tower Street, London EC3R 5AZ. This policy has worldwide application except in relation to professional business carried on by the insured from its own offices in the USA or Canada.

3. What Does This Policy Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

This site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

15. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
16. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
17. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
18. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
19. The right to restrict (i.e. prevent) the processing of your personal data.
20. The right to object to us using your personal data for a particular purpose or purposes.
21. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
22. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. What Data Do We Collect?

6.1 Business contacts and their employees; business contacts of clients and companies/businesses owned or part-owned by or prospectively owned by or part-owned by our clients, and the employees of such business contacts; suppliers and their employees; suppliers to our clients and companies/businesses owned or part-owned by or prospectively owned by or part-owned by our clients, and the employees of such suppliers; customers of clients and companies/businesses owned or part-owned by or prospectively owned by or part-owned by our clients, and the employees of such customers; professional advisers, finance providers and other service providers to clients and companies/businesses owned or part-owned by or prospectively owned by or part-owned by our clients, and the employees of such professional advisers, finance providers and other service providers business contacts, others who contact us.

• Names
• Occupations/positions in organisations;
• Postal addresses;
• Telephone numbers (landline and mobile);
• E-mail addresses.

6.2 Clients and their employees or representatives.

• Personal residence data;
• Age and gender;
• Immediate family personal details;
• Detailed personal financial circumstances and personal tax information and history;
• Employment or occupation details;
• Bank details and other financial details.

6.3 Personnel

• Name;
• Contact Details;
• National Insurance number;
• Age;
• Gender;
• Ethnicity;
• Nationality;
• Religion;
• Details of sick leave;
• Medical conditions;
• Disabilities;
• Prescribed medication;
• Interview notes;
• CVs, application forms, covering letters, and similar documents;
• Assessments, performance reviews, and similar documents;
• Details of remuneration including salaries, pay increases, bonuses, commission, overtime, benefits, and expenses;
• Details of trade union membership (where applicable);
• Employee monitoring information;
• Records of disciplinary matters including reports and warnings, both formal and informal;
• Details of grievances including documentary evidence, notes from interviews, procedures followed, and outcomes; and
• Results of Disclosure and Barring Service checks (where relevant and depending on the role).

• Recruitment applicants

• Name;
• Contact Details;
• Areas of interest;
• CV, experience, education, academic and professional qualifications;
• Information provided as part of interviews and assessments;
• Diversity and equal opportunities data;
• Pre-employment screening information if your application is successful;
• Information about your and your immediate family’s financial relationships if your application is successful;
• Bank account details if your application is successful.
• Interview and assessment results and feedback;
• Job offer details;
• References from your named referees;
• Results of Disclosure and Barring Service checks (where relevant and depending on the role applied for); and
• Verification of information provided during the recruitment process by contacting relevant third parties (for example, previous employers, education and qualification providers) or using publicly available sources (for example, to verify your experience, education and qualifications).

• Visitors to our website

Our site uses Google Analytics, which collects data from each visit to the site, including through the use of Cookies, but does not store any personally identifiable information.

7. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data.

The lawful basis on which we process personal data on individuals and unincorporated businesses is CONTRACT (in the case of clients, suppliers and providers of services to us) and LEGITIMATE INTERESTS (in the case of any other parties). We may also process certain personal data by LEGAL OBLIGATION.

Your personal data may be used for one or more of the following purposes:

• Contacting clients and prospective clients about their financial, tax and business affairs;
• Contacting current and prospective providers of finance, investors, financial intermediaries, professional advisers and other affected third parties about client affairs and lending or investment opportunities;
• Marketing our own services;
• Marketing acquisition or investment opportunities on behalf of clients;
• Contacting our own suppliers, professional advisers, professional bodies, regulators, bankers;
• Contacting parties in legal claims and disputes
• Compliance with professional obligations and maintaining a record of our work in case of future regulatory enquiry or professional negligence claims.
• Maintaining a database of work precedents than can be used in future assignments;
• To facilitate the provision of professional services to our clients including, but not limited to, accountancy and tax services and financial advice;
• Compliance with professional obligations and maintaining a record of our work in case of future regulatory enquiry or professional negligence claims;
• Maintaining a database of work precedents than can be used in future assignments;
• For employees and job applicants:
• Identifying and communicating with staff;
• Managing staff (including performance management and disciplinary);
• Staff training and development;
• Administering pay, pension and benefits;
• Managing time, attendance, sickness and absence;
• Compliance with legal or regulatory obligations relating to employees;
• Dealing with complaints, claims and litigation;
• Human resources administration and maintenance of HR records;
• Communications, public relations, marketing and business development;
• Financial reporting and analysis, business planning and forecasting and business restructuring;
• Managing business risk (including relating to information technology and communications);
• Safety, security and preventing and detecting inappropriate, unethical or unlawful activities;
• Ensuring equal opportunity and diversity;
• Recruitment and selection;
• Pre-employment verification and screening;
• Responding to reference requests;
• Obtaining recruitment feedback;
• Dealing with recruitment complaints.
• Job offers;
• Contacting unsuccessful job applicants about future opportunities;

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our services or of business opportunities we wish to introduce to you. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

We do not use any automated systems for carrying out decision-making or profiling.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods:

9. How and Where Do You Store or Transfer My Personal Data?

We will only store your personal data in the UK or within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

With the exception of certain categories of personal data that are categorised as sensitive personal data, we may share your data with external third parties, as detailed below in Part 10 that are based either within or outside of the EEA. The following safeguards are applied to transfers of data outside the EEA:

Either:

1. We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection; or
2. We will use specific contractual clauses with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR; or

• Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe; or

1. We may transfer your data outside the EEA with your express consent having informed you of the risks; or
2. We may transfer your data outside the EEA where this is necessary for the performance of a contract between you and us; or
3. We may transfer your data outside the EEA where this is necessary for the performance of a contract between a third party and us which is in your interests.

Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• The use of passwords, encryption and network security software;
• Regular updating of software;
• Physical security of premises and files;
• Taking regular data backups and storing them in an off-site secure location;
• Restrictions and conditions on the storage and processing of personal data on portable devices, including those owned by employees, agents or contractors personally;
• Internal procedures and authorisation protocols for processing and transferring personal data;

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

1. Where you have expressly consented; or
2. Where sharing the personal data in question is necessary for the performance of a contract between you and us; or

• Where sharing the personal data in question is necessary for the performance of a contract between a third party and us which is in your interests; or

1. In some limited circumstances, where we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal or regulatory obligations, a court order, or the instructions of a government authority.
2. We may share your data within the “group” of companies with substantially common ownership to us.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.

11. How Can I Control My Personal Data?
    • We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or at the point of providing your details.
    • You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

Subject to the following paragraph, you may access our site without providing any personal data at all.

Our site uses Google Analytics, which collects data from each visit to the site, including through the use of Cookies, but does not store any personally identifiable information. If you do not wish data to be collected (but not stored) by Google Analytics, please do not use our website.

13. What Are My Rights In Relation To My Personal Data And How Can I Exercise Them?

Your right of access

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Data Subject Request Form is available on request for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

Your right to have incorrect data corrected

You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.

Any request to update personal data should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Data Subject Request Form is available on request for you to use.

When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make updates as appropriate based on your updated information and inform you that we have done so within one month. The period may be extended by up to two months in the case of complex requests. If such additional time is required, we will inform you that this is the case.

Your right to erasure or “right to be forgotten”

You have the right to obtain deletion of your personal data in the following cases:

• the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
• our legal grounds for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
• our legal grounds for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to our processing and we do not have overriding legitimate grounds;
• you object to our processing for direct marketing purposes;
• your personal data have been unlawfully processed; or
• your personal data must be erased to comply with a legal obligation to which we are subject.

All data deletion requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Data Subject Request Form is available on request for you to use.

Your right to restrict processing

You have the right to restrict our processing of your personal data in the following cases:

• for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data;
• your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
• your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; or
• for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.

All data processing restriction requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Data Subject Request Form is available on request for you to use.

Your right to object to processing

You have the right to object to our processing of your personal data in the following cases:

• our legal grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or
• our processing is for direct marketing purposes.

All data processing objections should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Data Subject Request Form is available on request for you to use.

Your right to withdraw consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time.

All consent withdrawal should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Data Subject Request Form is available on request for you to use.

Please see the relevant “Use of personal data” sections of this privacy statement for further details about our processing of personal data based on consent.

14. How Do You Use Cookies?

Our site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us to facilitate and improve your experience of our site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by us are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our site may not function fully or as intended.

Certain features of our site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

Most browsers allow you to view, manage, delete and block cookies for a website. Be aware that if you delete all cookies then any preferences you have set will be lost, including the ability to opt-out from cookies as this function itself requires placement of an opt out cookie on your device. Links to information on how to control cookies for common browsers are set out below:

Microsoft Edge:

https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

Microsoft Internet Explorer:

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

Mozilla Firefox:

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

MacOS Safari:

https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Others:

https://www.aboutcookies.org/

http://www.cookiecentral.com/faq/

You can opt-out of having your anonymised browsing history within our websites or applications recorded by Google Analytics cookies. You can learn more about Google’s privacy policies and how to opt-out of their analytics cookies by clicking on following link:

http://www.google.com/analytics/learn/privacy.html

In addition to cookies that are “strictly necessary” for our site to function the following first-party Cookies may be placed on your computer or device:

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

For the attention the Data Protection Officer (Iain Campbell).

FC Corporate Finance Limited

Email address: ic@fccorporatefinance.com.

Telephone number: 01204 267766.

Postal Address: 30 Chorley New Road, Bolton, BL1 4AP, England.

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our site. We recommend that you check our website regularly to keep up-to-date.