Privacy Notice

INTRODUCTION

We at Arma Partners are committed to respecting your privacy and protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), and in the interactions we may have after your visit, and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. Important Information And Who We Are
  2. The Data We Collect About You
  3. How Is Your Personal Data Collected
  4. How We Use Your Personal Data
  5. Disclosures Of Your Personal Data
  6. International Transfers
  7. Data Security
  8. Data Retention
  9. Your Legal Rights
  10. Glossary

1. Important Information And Who We Are

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Arma Partners collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Arma Partners LLP is a limited liability partnership registered in England and Wales. We are affiliated with certain other entities and so when we mention “Arma Partners”, “we”, “us” or “our” in this privacy notice, we are referring to Arma Partners LLP or the relevant affiliate responsible for processing your data. We will let you know which entity will be the controller for your data when you engage us to provide services to you. Arma Partners LLP is the controller and responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO at: DPO@armapartners.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was updated in May 2018. Any changes to this privacy notice will be posted on this website and will be effective on posting.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data such as your name, your employer, your title or position and your relationship to a person or information collected by us as part of our business acceptance processes.
  • Contact Data such as your billing address, email address and telephone numbers.
  • Financial Data such as bank account details.
  • Technical Data such as information from your visit to our website, or in relation to materials and communications we send to you electronically, including your IP address.
  • Marketing and Communications Data such as your preferences in receiving marketing from us, your communication preferences and information you provide to us for the purposes of attending meetings and events, including access and dietary requirements.
  • Personal Information provided to us by or on behalf of our clients, partners and employees or generated by us in the course of providing services and employment, including applications for employment submitted to us, which may include special categories of data.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect 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 perform the contract we have or are trying to enter into with you. In this case, we may not be able to provide the requested service to you but we will notify you if this is the case at the time.

3. How Is Your Personal Data Collected

We use different methods to collect data from and about you including through:

  • Direct interactions including when you or your organisation seek advice or employment from us, or when you or your organisation offer or provide services to us as a vendor.
  • Automated technologies or interactions such as when you visit, or interact with,our website or you email us or provide data in respect of attending Arma Partners’ events or send an application for a position with us.In respect of our collection of personal data by the use of cookies please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including Identity and Contact Data from publicly availably sources such as Companies House and WorldCheck.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the principal ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / activityLawful basis for processing including basis of legitimate interest
To register you as a new clientPerformance of a contract with you
To process and deliver our services to you including:
(a) Manage payments, fees and charges

(b) Collect and recover money owed to us
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of such content we serve to youNecessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, client relationships and experiencesNecessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To analyse your application in respect of a position at Arma PartnersNecessary for our legitimate interests (to respond to an application)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We may use certain of your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you.

You will receive marketing communications from us if you have requested information from us or if you have engaged us to provide services to you and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us during the course of a transaction or us providing services to you.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures Of Your Personal Data

We may have to share your personal data with our affiliates, details of which can be found on our website, both inside and outside the European Economic Area (the “EEA”). We may also need to transfer personal data to third parties, including third parties based outside the EEA, such as other advisors, accountants and third parties involved in your matters.

We require all third parties, including our affiliates, to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

  • Service providers based in the EEA or the United States who provide IT and system administrative services.
  • Professional advisers including lawyers, bankers, auditors and insurers based in the EEA or the United States who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom or the United States who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to: