This policy sets out the basis on which any personal data we collect from you, that you provide to us, or we receive from others will be processed by us.
Atempo Growth with its registered office at 1 Cinema House, 93 Wardour Street London, W1F 0UD and other companies in the Alma I Advisory Limited group collect and use certain Personal Data. Atempo Growth is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
The General Data Protection Regulation defines “personal data” as any information relating to an identified or identifiable natural person (a data subject). The data subjects are identifiable if they can be directly or indirectly identified, especially by reference to an identifier such as a name, an identification number, location data, an online identifier or one of several special characteristics, which expresses the physical, physiological, genetic, mental, commercial, cultural or social identity of these natural persons. In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Atempo Growth or any other person in respect of an individual.
Types of personal data we collect
We will need to obtain Personal Data about you to perform the services we have been engaged to provide. In relation to each of the Services described at paragraph 2.1 above, we will collect and process the following Personal Data about you:
Information that you provide to Atempo Growth
This includes information about you that you provide to us. The nature of the Services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
- Basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country of residence, nationality);
- Other Personal Data (such as education and employment history; references; ID documentation)
- Any information that you choose to share with us (whether through our websites or otherwise) which may be considered Personal Data;
Information that we collect or generate about you
This includes (by way of a non-exhaustive list):
- Information about the Services which you have purchased and our interactions with you;
- Information we are required to collect in order to comply with our legal, regulatory and compliance obligations;
- When you visit Atempo Group websites, cookies are used to collect technical information about the services that you use, and how you use them. For more information on the cookies used by Atempo Group please see our Cookie Notice.
- In addition to the categories of Personal Data described above, Atempo Growth will also process further anonymized information and data that is not processed by reference to a specific individual.
How we use your information
Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- For ongoing review and improvement of the information provided on or operation and security of Atempo Growth Websites;
- To assess your application for our Services, where applicable;
- To provide you with our Services;
- To understand feedback on our Services and to help provide more information on the use of those products and services quickly and easily;
- To communicate with you to provide you with services or information about Atempo Growth and our products and services;
- For the management and administration of our business;
- To comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
- For the administration and maintenance of databases storing Personal Data; and / or
- We may process business communications traffic data sent and received by us for the purposes of evaluating our existing or prospective business relationship.
However, we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include where:
- We need to do so in order to perform our contractual obligations with our stakeholders;
- We have obtained your consent;
- We have legal and regulatory obligations that we have to discharge;
- We may need to do so to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- The use of your Personal Data as described is necessary for our legitimate business interests, such as:
- Allowing us to effectively and efficiently manage and administer the operation of our business;
- Conducting market research or business analysis;
- Maintaining compliance with internal policies and procedures; and
- Promoting our business or Atempo Growth Services.
Disclosure of information to third parties
We may share your Personal Data within Atempo Growth for the purposes described above, and we may also share your Personal Data outside of the Atempo Growth group for the following purposes:
- With our business partners. For example, this could include intermediaries that introduced you to us or through whom you purchased our Services. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
- To the extent required by law, for example if we are under a duty to disclose your Personal Data to comply with any legal obligation (including, without limitation, to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;
- If we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
- If we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third-party buyer.
International transfers of personal data
Atempo Growth is a pan-European business. Our operations are spread around Europe. That means that we may transfer your Personal Data to locations outside of your country.
Where we transfer your Personal Data to another country outside the UK or EEA (as applicable), we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe or UK, for example, this may be done in one of the following ways:
- The country that we send the data to might be approved by the European Commission or UK Government (as applicable) as offering an adequate level of protection for Personal Data;
- The recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission or UK Government (as applicable), obliging them to protect your Personal Data; or
- In other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.
Safeguarding your information
We have controls in place to maintain the security of our information and information systems. The information we handle is protected with safeguards appropriate to its sensitivity. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed, or stored is limited to authorised employees.
As a condition of employment, Atempo Growth employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by an Atempo Growth employee is prohibited and may result in disciplinary measures.
How long we keep your personal data
How long we will hold your Personal Data for will vary and will be determined by the following criteria:
- The purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
- Legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
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 using email@example.com.
In all the above cases in which we collect, use, or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
- The right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
- The right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
- In some circumstances, the right to receive some Personal Data in a structured, commonly used, and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly us;
- The right to request that we rectify your Personal Data if it is inaccurate or incomplete;
- The right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
- The right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
- The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
Questions and concerns
If you have any questions or concerns about Atempo Growth’ handling of your Personal Data, or about this Policy, please contact the Data Protection Team using the following contact information:
Atempo Growth, 1 Cinema House, 93 Wardour Street, London, W1F 0UD
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction, in the UK this is the Information Commissioner’s Office (www.ico.org.uk).