This notice describes how YYX Capital Partners LLP Investment Management (YYX Capital Partners LLP) uses personal data. It outlines YYX Capital Partners LLP’s data protection obligations and your data protection rights under the regime introduced by the EU General Data Protection (Regulation 2016/679, the “General Data Protection Regulation”).
The GDPR applies to “personal data” meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
YYX Capital Partners LLP needs to use your personal data to provide its services to you, so this notice outlines the following points about the processing of your personal data:• which data items are used, how they are used and who they are shared with;
• your rights and YYX Capital Partners LLP’s obligations.
Your Data are collected to effectively and properly manage your account(s) with us. Data is stored for specific purposes and only data that is relevant to that purpose will be stored. We will use the Data for several different purposes, including;1. to provide regulatory umbrella and investment services and to carry out obligations arising from any agreements entered into between you and YYX Capital Partners LLP;
If at any time you wish to be removed from marketing mailing lists or for any limits to be applied with respect to marketing materials received by you, please let us know. You can do this by e-mailing your YYX Capital Partners LLP relationship manager, data protection officer or any of the YYX Capital Partners LLP Partners. Contact details are available on our contact page.
YYX Capital Partners LLP may collect data:1. when you or an agent of yours contacts YYX Capital Partners LLP in relation to business and services offered;
5. when you use the YYX Capital Partners LLP website or online services.
YYX Capital Partners LLP stores your data on physical and electronic media. Data is safeguarded by YYX Capital Partners LLP and its Service Providers by maintaining physical and electronic security controls that are designed to comply with applicable legal standards.
The Data that is collected or held in relation to 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 works for us or for one of our Service Providers. In some cases, the laws of the destination country may not provide the same level of data protection as countries within the EEA. However, all Data wherever they are held by YYX Capital Partners LLP will be afforded a high level of protection against any unauthorised or accidental disclosure, access or deletion. By submitting your Data you agree to this transfer, storing or processing.
Unfortunately, the transmission of information via the internet is not completely secure. Although YYX Capital Partners LLP will do its best to protect your Data, we cannot guarantee the security of your Data transmitted electronically. Any such transmission is at your own risk.
During YYX Capital Partners LLP’s relationship with you YYX Capital Partners LLP will collect and process Data about you, including:1. information which individuals and entities provide when contacting us (including through using this website) (such as their names, postal addresses, telephone numbers, identification documents and e-mail addresses);
7. information regarding relationships you have with banks and/or other financial institutions (including bank details).
YYX Capital Partners LLP uses Service Providers to conduct aspects of its business, so information may be disclosed to them and their affiliates Data that you have provided in order to fulfil the purposes for which the Data is held. These Service Providers may disclose such Data to each other and to each other’s affiliates in order to achieve the same purposes.
YYX Capital Partners LLP and its Service Providers may also be required to disclose your Data to governmental agencies, self-regulatory organisations, industry associations and similar bodies in order to fulfil legal and regulatory requirements. In addition, the laws of certain countries and states give people involved in lawsuits and other legal proceedings the right under certain circumstances to obtain information from YYX Capital Partners LLP and its Service Providers, including your Data. YYX Capital Partners LLP and its Service Providers will comply with these laws to the extent required.
YYX Capital Partners LLP will not sell your Data to any third party. Wherever possible, Service Providers are required to enter into confidentiality agreements that prohibit them from selling or improperly using your Data.
YYX Capital Partners LLP will retain your personal information for a period of up to seven years following the point where the business relationship has ceased.
It may be necessary to retain your personal information beyond this period depending on additional legal/regulatory obligations. Thereafter, YYX Capital Partners LLP will refrain from collecting any further personal information on you and shall take appropriate steps to dispose of any records containing your personal information to the extent this is operationally feasible and proportionate.
YYX Capital Partners LLP assesses all personal data that is collected or stored to ensure that there is a legal basis for each type of data under GDPR. Given that YYX Capital Partners LLP is an FCA regulated firm, the majority of lawful basis for YYX Capital Partners LLP’s processing is to meet its obligations to the FCA (legal obligation basis) or to fulfil its obligations to you under contract (contract basis).
Other lawful basis may be used where YYX Capital Partners LLP assesses this is necessary and appropriate.
You have the following rights, in certain circumstances, in relation to your personal information:• Right to access your personal information (in an easily readable form);
Where YYX Capital Partners LLP or its Service Provider(s) requires your personal information to comply with AML or other legal requirements, failure to provide this information means YYX Capital Partners LLP will not be able to accept you as a client or investor.
YYX Capital Partners LLP shall notify you of any personal information breach affecting you that is likely to result in a high risk to your rights and freedoms.
YYX Capital Partners LLP will need to update its privacy notice in response to regulatory requirements or changes to its business. The latest notice will always be available on the YYX Capital Partners LLP website (www.yyxcapital.com).
Under the GDPR, data subjects can make a complaint to the supervisory authority including the Member State in which they reside or work or the place of the alleged infringement.