Cluny Capital Limited (“Cluny”) is authorized and regulated by the Financial Conduct Authority and is incorporated in England and Wales with its registered office at Belgrave House,39-43 Monument Hill, Weybridge, Surrey KT13 8RN England. Its company number is 07331340.
Cluny provides marketing and business development services to investment management firms, and is engaged to liaise with prospective and current investors on their behalf. References to “Client” are references to those investment management firms who have retained Cluny’s services.
References to “Cluny”, “we”, “us” and “our” are references to Cluny Capital Ltd.
We are a data controller in respect of your personal data for the purposes of data protection law, such as the European Union’s General Data Protection Regulation. We are responsible for ensuring that we use your personal data in compliance with data protection law.
This privacy notice applies to you if (i) you are a client or prospective client of any Client (including an investor or prospective investor in a vehicle or entity managed by the Client), (ii) your personal data has been provided to us in connection with any of the foregoing by another person (such as where you are a director, partner, trustee, employee, agent or direct or indirect owner of such person); or (iii) you otherwise enter into communications with us by email or other means.
This privacy notice sets out the basis on which personal data about you that you provide to us, that we create about you or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.
We might process the following personal data about you:
We collect your personal information to fulfil our contractual obligations, our statutory and regulatory obligations and/or the legitimate business interests of Cluny or its Client, to provide services to the Client, and for other purposes for which Cluny has a lawful basis under the privacy laws, including:
We are entitled to process your personal data in these ways for the following reasons:
We may from time to time, in accordance with the purposes described above, disclose your personal data to other parties, including (a) a Client, (b), the administrator of any fund managed by the Client (c) professional advisers such as law firms and accountancy firms, (d) other service providers of Cluny and/or of the Client including technology service providers, (e) counterparties and (f) courts and regulatory, tax and governmental authorities. Some of these persons will process your personal data in accordance with our instructions and others will themselves be responsible for their use of your personal data. These persons may be permitted to further disclose the personal data to other parties.
Should any personal data be transferred out of the EU, Cluny will obtain assurance that the transferee will adhere to the same standards as set out in this Policy.
How long we hold your personal data for will vary. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal data).
Data is stored either electronically, or in rare cases, in paper form. Electronic records are stored on Microsoft Azure cloud, accessed by one user only, and require 2 passwords to access. Paper data is stored in secure offices.
You have a number of legal rights in relation to the personal data that we hold about you. These rights include the following:
You can exercise your rights by contacting us using the details set out under “Contacting us” below. You can find out more information about your rights by contacting an EU data regulator such as the UK’s Information Commissioner’s Office, or by searching its website at ico.org.uk.
If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions and requests to Cluny Capital Limited at firstname.lastname@example.org or T: +44 (0)203 440 5035.