Privacy Policy
This Privacy Notice tells you how Keyridge Asset Management Limited (“Keyridge”, “we”, “us”, “our”) collects and processes your personal data and explains your rights around how we use it.
Keyridge is regulated as an investment firm by the Central Bank of Ireland and is authorised by the Financial Conduct Authority to provide investment services in the UK through its UK branch.
“Personal data”, “process” and “processing” shall have the meaning ascribed to them in the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“EU GDPR”) and in the UK General Data Protection Regulation (“UK GDPR”).
What personal information we collect and why?
Our client base consists of professional, corporate or institutional clients and, in this context, we do not typically process personal data relating to individuals.
Where we do hold personal data, this is usually restricted to:
basic business contact details of individuals acting on behalf of our corporate or institutional clients, professional investors, Independent Financial Advisers (“IFAs”) or service providers (e.g. name, business email address and business telephone number);
identification details where required for regulatory, compliance, or anti-money laundering (“AML”) purposes.
We process this personal data for business-to-business marketing of products and services as well as relationship management purposes, or to comply with applicable laws or regulations.
The reasons and types of personal data we collect are summarised below.
Why we process personal data | What personal data we collect and control | How is personal data processed | Disclosure and/or Consent | Systems Used |
|---|---|---|---|---|
To provide information on our services and events | Name, job title, firm name, email address, telephone number | Stored in a database and used for provision of information | Opt-out on email | Internal Network Storage Microsoft365 |
To satisfy AML and Counter Terrorist Financing Legislation | Identification and address verification (where applicable) | Scanned and stored on an internal network | Privacy Statement | Internal Network Storage Microsoft365 Paper Filing FINSCAN |
We do not use personal data for direct marketing purposes.
How do we obtain your personal data?
We may collect your personal data in the following ways:
Directly from you when:
You give us your business card
You register for or attend one of our events or webinars.
From publicly available sources.
From third parties (e.g. event providers), when you have provided them with your consent on sharing of your personal data.
From affiliated companies, when you have provided them with your consent on the sharing of your personal data.
What are the lawful basis for processing your personal data?
Legal Ground | Details |
|---|---|
Consent | You have given your consent to the processing of your personal data for marketing and/or relationship management purposes. |
Legitimate business interests | We may rely on our legitimate interests to process your personal data. This includes sending professional investors, independent Financial Advisers, service providers and institutional investors information about relevant products and events. |
Compliance with a legal obligation | Processing is necessary for compliance with a legal obligation to which we are subject. |
What are your rights around your personal data?
Subject to applicable law (including the GDPR and UK GDPR), you have the following rights in relation to your personal data:
Right to Access: the right to obtain confirmation as to whether we process your personal data and to request a copy of that data.
Right to Rectification: the right to have inaccurate or incomplete personal data corrected or updated.
Right to Erasure: the right to request deletion of your personal data in certain circumstances.
Right to Restriction: the right to request that we restrict the processing of your personal data in certain situations.
Right to Portability: the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format and to request that we transmit it to another controller, where technically feasible.
Right to Object: the right to object to processing of your personal data based on legitimate interest, including profiling based on legitimate interest, and to object at any time to processing for direct marketing purposes.
You can opt out of receiving marketing communications at any time by:
Using the ‘unsubscribe’ link in our emails; or
Contacting us via email [email protected]
Right to Withdraw Consent: the right to withdraw your consent to the processing of your personal data at any time. This will not affect the lawfulness of processing before consent was withdrawn.
You can exercise your rights by contacting us using the contact details below.
How long do we keep your personal data?
Keyridge retains your personal data for marketing and relationship management purposes whilst you remain an active contact or unless you withdraw consent.
In addition to this, we may retain your personal data for a period of time that enables us to:
maintain business records for analysis and/or audit purposes;
comply with record retention requirements under the law;
defend or bring any existing or potential legal claims;
deal with any queries or complaints you may have.
We will delete your personal data when it is no longer required for these purposes. If there is any personal data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
Where do we process your personal data?
Your personal data is processed within the European Union and/or the United Kingdom. The European Union and the United Kingdom are recognised as areas providing an adequate level of data protection.
Sharing of your personal data
We will only share your personal data in any circumstances where we are permitted or required to do so by law or where we have your consent to do so.
How can you contact us?
If you have any questions or complaints in relation to our use of your personal data, you can contact Keyridge at the following addresses:
Irish Head Office
Keyridge Asset Management Limited
Beresford Court
Beresford Place
Dublin 1
Ireland
Telephone: +353 1 704 2000
Email: [email protected]
UK Branch Office
Keyridge Asset Management Limited
Level 22 Bishopsgate
London
EC2N 4BQ
United Kingdom
Telephone: +44 (0)207 415 6500
Email: [email protected]
In the event that you are dissatisfied with our response, you have the right to lodge a complaint with the appropriate national supervisory authority:
Ireland
Data Protection Commission
6 Pembroke Row
Dublin 2
D02 X963
Ireland
Telephone: +353 1 7650100
Email: [email protected]
Website: www.dataprotection.ie
United Kingdom
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom
Telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
Email: [email protected]
Website: www.ico.org.uk
Updates to this Privacy Notice
Keyridge may update this Privacy Notice from time to time, for example to reflect changes in processing activities or legal obligations.