This Data Privacy Policy (the “Policy”) – together with our terms and conditions and any other documents referred to in it – describes the practices of Greensphere Capital LLP (“Greensphere”, “we”, or “us”) regarding the collection, use, disclosure, transfer, and other processing of individually identifiable information (“Personal Data”) , on visitors to our website, clients, investors and employees . We intend to process any Personal Data fairly, lawfully, and in accordance with applicable laws. By visiting our website or receiving a copy of the policy statement you are accepting and consenting to the practices described in this Policy. The information contained in this privacy policy statement is intended to provide you with details of how we may collect and process your personal data from time to time and the circumstances giving rise to the request and receiving of data.
Personal data collected
When you visit Greensphere’s website, we may collect and process Personal Data about you. If and to the extent permitted by applicable law, the Personal Data we collect and process may include the following personal details: name; home and work postal addresses; web address data; home and work telephone numbers; mobile telephone numbers; and home and work email.
The above list is not exhaustive and we may from time to time require additional information in order to satisfy our legal and regulatory obligations. Where additional information is required we will provide you with a reasonable explanation of why it is required unless we are prevented from doing so by law.
We may use methods such as pseudonymisation which is a process whereby the firm can replace identifying fields of data with other non-identifying data fields in order to anonymise the data from the individual therefore meaning the data is no longer personal. The firm may use this method where we are required to retain certain types of information for clients, such as number of females and males employed, jobs created and average salaries paid. This type of statistical data is often required for ESG (Environmental, social and governance) investment purposes by clients to show value added investments / advised made by the firm on behalf of its clients.
Use of this Website
Your Personal Data may be collected automatically each time you visit the firm’s website, for example, via the Internet protocol (IP) address used to connect your computer to the Internet. Other instances, such as inserting personal details into forms like that on our Contact Us page may result in data being collected and processed.
- The type of data we collect when you visit our site may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site as well as the types of products and services and searches you conduct on our site.
- Please see our cookie policy for your information on how the firm’s website uses them.
Why we may collect personal data
Greensphere collects, processes, and otherwise uses your Personal Data for purposes that are required by applicable law, regulations, collective agreements or other contracts, to allow the company to fulfil its business needs and legal obligations and to maintain the website. These purposes include: notifying you about information and availability of the website in your region; ensuring the proper use of IT systems; measuring and monitoring the usage of business-related resources; and liaising with law enforcement agencies.
Generally, however we only collect your personal data where we believe we have a legitimate business interest with you or we have a lawful purpose to do so. These reasons may include but may not be limited to circumstances where you:
- Are a shareholder in one of the companies to whom we have an administration and / or management agreement with;
- Are a Limited Partner or an investor in one of the funds or opportunities to which we are appointed advisor
- Are actively receiving investment advisory services or products from us under a contractual arrangement or engagement.
- Consent to receiving communications from us
- Have a contractual agreement with us
- request resources or marketing be sent to you;
- give us feedback or some other form or legitimate business interest with you.
We do not sell, lease, or otherwise disclose Personal Data for the purposes of commercial exploitation.
Special Category Data
We do not collect any Special Category data. This refers to any data which is sensitive and is subject to additional rules and requirements under the General Data Protection Regulations. Special category data may include information regarding: Criminal convictions and offences, race, ethnicity, religious or philosophical beliefs, political opinions, sexual orientation, trade union membership and information about your health, genetic and biometric data.
We are required to request information relating to criminal convictions as part of our recruitment process for staff and contractors undertaking regulated activities and as such we require consent from the individual for this. If we are required by law to request any special category data from you, aside from the reasons mentioned above we will provide you with a reasonable explanation as to the nature and purpose for this request and obtain your consent. We would not be able to proceed without your consent unless there was a lawful reason for doing so.
How we collect your personal data
Typically, where we are required to obtain your personal data we will request it from you. However, we may also from time to time receive your personal data through intermediaries where you have authorised the sharing of your personal data with us. Intermediaries may include Accountants, Solicitors, Independent financial advisors, Tax advisors and wealth managers who may be working on your behalf. Personal data may be provided to us via post, in person, email or via a specially created secure data room/ platform. The data collection may be facilitated by way of completing an application form or questionnaire or by responding to information requests from us or upon receipt of CV by way of example. We may also receive information from publicly available resources.
How and why do we use your personal data
We only use your data to be able to perform our duties under contracts we may have with you or 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.
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 get in touch via our Contact Us page if you need details about the specific legal ground we are relying on to process your personal data.
What is the lawful basis of our processing of your personal information?
Under the GDPR we need to have one or more lawful bases for processing your personal information. When processing your personal information, we rely on one or more of the following legal bases:
- Legitimate interests We may process your information where it is in our legitimate interests to do so as an organisation and without unduly prejudicing your interests or fundamental rights and freedoms. It is in our interests to ensure that our processes and systems operate effectively and to process information to help Greensphere effectively operate its business. Examples of which include:
- For good governance, accounting, and managing and auditing our business operations;
- For establishment and defence of legal rights;
- For the prevention, detection and investigation of financial crime, including fraud, money laundering, and terrorism financing; and
- To send you marketing communications.
- As necessary for employment purposes or to provide products / services to you, including communicating with you for the relevant product or service or for employment purposes:
- To take steps at your request prior to entering into it;
- To decide whether to enter into it;
- To manage and perform the above;
- To update our records; and
- To trace your whereabouts to contact you about your product, services or for employment purposes.
- When we process your personal information to achieve such legitimate interests, we balance them against any potential impact on you and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you (unless, for instance, we are otherwise required or permitted to by law).
- Consent We may process your information where you give us your consent to do so. For example, we may ask for your consent to use your personal information to send you marketing material by email, and we may ask for your explicit consent to collect special categories of your personal information. Examples of which include:
- When you request us to disclose your personal data to other people or organisations;
- When we process any special categories of personal data about you at your request (e.g. your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation); and
- To send you marketing communications where we’re required to ask for your consent to do so.
- Complying with a legal obligation We may process your information in order to comply with a legal obligation which applies to us (for example, when we are required to carry out a Know Your Client check, obtain regulatory references for certain positions at Greensphere or provide information to regulatory authorities).Examples of which include;
- When you exercise your rights under data protection law and make requests;
- For compliance with legal and regulatory requirements and related disclosures;
- For establishment and defence of legal rights;
- For activities relating to the prevention, detection and investigation of crime; and
- To verify your identity, and where applicable undertake anti-money laundering checks.
- Performance of a contract We may process your information where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, if you wish to become a client or work for us).
You’re free at any time to change your mind and withdraw your consent at any time getting in touch via our Contact Us page. The consequence might be that we can’t do certain things for you. To the extent that action has already been taken based on your consent, withdrawal of your consent will not apply to the processing of your personal data that has already occurred, based on your consent.
You have the right to withdraw this consent at any time getting in touch via our Contact Us page.
Who may have access to your personal data
Your Personal Data will be disclosed within Greensphere and only to those Greensphere individuals who need access to your Personal Data to perform their duties for the purposes listed in Section 3 (Purposes for collecting Personal Data) above or where required by applicable law.
Greensphere may also disclose your Personal Data to affiliated companies of Greensphere for pursuing the purposes listed in Section 3 (Purposes for collecting Personal Data) above or where required by applicable law.
Greensphere may also disclose your Personal Data to third parties providing information technology support or technical and organisational services in connection with governmental authorities or regulatory authorities for legal purposes; consultants in connection with extraordinary business events operations (e.g. mergers, acquisitions, and the like); to business partners, agents and customers; external consultants and professionals; and courts.
Greensphere will exercise appropriate due diligence in the selection of its third party service providers, and require that they maintain adequate technical and organisational security measures to safeguard your Personal Data, and to process your Personal Data only as instructed by Greensphere and for no other purposes.
It is understood that your Personal Data will be disclosed to third parties only as necessary in connection with the performance of contracts, Greensphere’s business activities and the purposes listed in above, as permitted by your consent or as otherwise authorised or permitted by the law.
We may also share your personal data with the parties set out below for legitimate business interests and lawful purposes, these may include but are not limited to:
- Professional advisers including lawyers, bankers, auditors, tax advisors and insurers who provide consultancy, banking, legal, insurance, tax and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances which may include but is not limited to The Financial Conduct Authority.
- Fraud prevention agencies,
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We will only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Our protocol for transferring data internationally
Due to the multinational character of the Greensphere’s interests, some of the affiliated companies or projects and other recipients listed above may be located in countries that do not provide data protection to a degree that is equivalent to that set forth by the UK. Greensphere will take steps to make sure that such recipients act in accordance with applicable law and provide an adequate level of protection for your Personal Data including appropriate technical and organisational security measures, also through implementation of appropriate contractual measures to secure such transfer, in compliance with the applicable law.
Should we transfer, store, process or otherwise export your Personal Data to a country outside the European Economic Area (EEA) or country which has been assessed by the European Commission or the United Kingdom as ensuring an adequate level of protection for personal data, we will do so on the basis of an agreement, designed to protect your data, in the appropriate form approved for this purpose by the European Commission.
Safeguards can include:
(i) The Standard Data Protection Clauses (also known as EU Model Clauses).
(ii) Binding Corporate Rules, provided the recipients in other countries have obtained the requisite approvals. The published list of approvals is available here: http://ec.europa.eu/justice/data-protection/international-transfers/binding-corporate-rules/bcr_cooperation/index_en.htm
Contact us using the details on Contact Us if you would like to see a copy of these agreements.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Please get in touch via our Contact Us page if you like further information regarding international transfers or visit the Information Commissioner’s Office website (www.ico.org.uk).
Data security
We maintain physical, technical, and organisational security measures to protect the Personal Data against accidental, unlawful, or unauthorised destruction, loss, alteration, disclosure, or access, whether it is processed in the UK or elsewhere. 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 such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Please note that transmission of information via the internet is not completely secure. We do our best to protect your Personal Data, however we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
We have put in place procedures to deal with data breaches in accordance with the GDPR (General Data protection regulation) and we will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention periods
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, regulatory. 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.
By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years for tax purposes and for at least five years after a client ceases to be a client under the latest UK money laundering regulations.
Other Retention period criteria is as follows:
GDPR personal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data (Subject access request).
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
We intend to keep your Personal Data accurate and up-to-date to best serve you on our website. We will only retain your Personal Data in accordance with applicable law.
For further information visit or if you wish to exercise any of the rights set out above, please get in touch via our Contact Us page.
You will not have to pay a fee to access your personal data (or to exercise any of your rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. In order to respond to a subject access request, we will need to confirm your identity as a security measure to safeguard you from your personal data from being disclosed to non-authorised third parties. Please provide us with as much information as possible to enable us to comply with your request within an acceptable time-frame. We are required to respond to subject access requests where practically possible within 30 days and if this is not possible we will provide you with a reasonable explanation as to why this cannot be achieved.
This website may sometimes contain links to and from the websites of our partners, investors, advertisers and affiliates. Please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Complaints and queries
If you are not happy with any aspect of how we collect and use your data, please contact info@greenspherecapital.com and we will do our best to resolve your issue. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
Accurate Data
We will make all reasonable efforts to ensure the data we hold on you is accurate and up to date and to correct any inaccuracies that we become aware of. Please help us to comply with our obligations by letting us know of any changes in relation to the data we hold about you as It is very important that the information we hold about you is accurate and up to date. Please Contact Us with any required updates or amendments.
Changes to this Policy
We may make changes to this Policy. Please check back frequently for updates.
Contact us
Greensphere Capital LLP – Company registration number: OC361535
Contact details for the purpose of this privacy policy statement and the person responsible for data protection and privacy for the firm is Compliance contact: Divya Seshamani.
If you have any questions about this Policy or our data privacy practices, please get in touch via our Contact Us page.
The data controller for the purposes of the EEA General Data Protection Regulation (GDPR), details of the firms privacy policy are located at 64 Knightsbridge, London SW1X 7JF, United Kingdom.