Privacy & Cookies

Data Protection Privacy Notice and Cookie Policy

The scope and purpose of this Privacy Notice
This Privacy Notice explains how Essencia Capital LLP (“Essencia”, “we”, “us”, “our”), collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with us in accordance with applicable data privacy laws and the General Data Protection Regulation (“GDPR”).

Introduction
Essencia is registered as a data controller with the Information Commissioner’s Office (“ICO”). As a data controller we process the Personal Data you provide to us. In this regard, the term “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Where Essencia determines the purposes, and means of the processing of Personal Data, we are deemed to be the data controller. We may use third party providers to carry out these processing activities. In certain cases, where Essencia processes Personal Data on behalf of another data controller, we will be deemed a data processor for these purposes. At all times, we shall process all data collected from you in accordance with the applicable data protection laws and maintain our registration with the ICO.

Personal Data
The term “Personal Data” as used in this Privacy Notice means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute personal data, including name, date of birth, residential address, identification number, location data or online identifier. Personal Data does not include data from which you can no longer be identified such as anonymised aggregate data.

What information do we collect about you, how do we collect it and what do we use it for?

The kinds of Personal Data we may collect include:

  1. name;
  2. contact details (such as your email address and telephone number);
  3. country of residence;
  4. employer;
  5. online identifiers (such as your IP address)

In most cases, we will collect the Personal Data directly from you but may also obtain it from other sources. You should note that our website uses cookies and that your use of the website and related online services involves the automated collection of certain types of information, some of which may be considered Personal Data. This information relates to online identifiers and browser type. For further details on the use of cookies on our website and your options in this regard, please refer to our Cookie Policy below.

We will process your Personal Data if and to the extent applicable law provides us with lawful basis to do so. Therefore, we will only process your Personal Data if:

  1. you have consented to us doing so (consent);
  2. we need it to perform the contract we have entered into with you (contract);
  3. we need it to comply with a legal obligation (legal obligation);
  4. we need it to protect someone’s life (vital interests);
  5. we need it to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law (public task);
  6. we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms (legitimate interest) Legitimate interests may include the provision of services by us, administrative or operational processes within Essencia Capital LLP and direct marketing activities.

Given the nature of our business, it is considered unlikely that the lawful basis for us to process your Personal Data will be by reason of vital interests or public task.

We will use your Personal Data to deliver services to you and/or to work or act for you, to manage legal and regulatory requirements and for the operation and management of our website, including improving our web services. We may also use your Personal Data to inform you about us and our services and to build our relationship with you.

Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

What might we need from you?
We may need to request specific information from you to help us confirm your identity and ensure your right to access Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

Accuracy of information
It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.

What if you do not provide the personal data we request?
It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to accept an engagement from you, to provide all or some of our services, to enter into a contract with you or to send you information about us (e.g. marketing materials).

Change of purpose and anonymisation
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

With whom will we share your information?
When using your Personal Data for the purposes and on the legal basis described above we may share your Personal Data with other service providers we work with, including third party processors. We may also have to share your Personal Data with regulators, public institutions, courts or other third parties.

For the purposes described above we may have to transfer your Personal Data from the European Economic Area (EEA) to a third party outside of the EEA and in a jurisdiction not being subject to an adequacy decision of the European Commission. We will always ensure that there is a legal basis and a relevant safeguard method for such data transfer so that your Personal Data is treated in a manner that is consistent with and respects the EU laws and other applicable laws and regulations on data protection.

Your rights in relation to your information
You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

  • request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;   
  • request rectification of your Personal Data;        
  • request the erasure of your Personal Data;      
  • request the restriction of processing of your Personal Data;
  • object to the processing of your Personal Data.

While we shall endeavour to comply with your requests, it should be noted that your rights to the erasure of Personal Data is subject to a number of considerations, including our legal and regulatory obligations to maintain records of data for certain regulator prescribed periods.

You also have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues or, as the case may be, any other competent supervisory authority of an EU member state.

Right to withdraw consent
In case you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. In case we processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such marketing purposes. 

How long will we retain your information?
We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for your Personal Data, we will 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.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.

Fees
You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Notice. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Changes to this Privacy Notice
We reserve the right to update this Privacy Notice at any time, and we will make an updated copy of such privacy notice available on our website.

Further information
If you have any queries, questions, concerns or require any further information in relation to the Privacy Notice or you wish to exercise any of your rights, please do not hesitate to contact us at IR@essenciacapital.com

Cookie Policy

Introduction
A “cookie” is a small data file of letters and numbers that is transferred by a website to your computer’s hard drive and stored on your browser or computer hard drive. Essencia Capital LLP (“Essencia”, “we”, “us”, “our”) sends cookies when you surf our website or request information. Enabling the cookies used on our website can be used to identify your computer. The aggregate information collected permits us to analyze traffic patterns on our website. This can enable us, over time, to provide you with a better experience on our website by improving the content and making it easier to use. For example, cookies can allow you to enter your password only once on pages where a login is required.

Essencia website
Our website uses three types of cookies. These cookies allow our website to function properly and for us to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to make improvements to our website.

The cookies we use are “analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. You can find more information about the individual analytical cookies we use and the purposes for which we use them in the list below:

Cookie

 

Purpose

verified-user

 

Recognises your confirmation of Investor status and acceptance of our Terms and Conditions.

Buto

 

Buto hosts the videos that appear on our website. The cookie allows for more efficient playback of videos.

utma, utmt, utmb, umtc, utmv and utmz (aka Google Analytics)

 

· Recognises you when you return to our website and track the pages you visit.

· Estimate our audience size.

· Monitor traffic levels and search queries.

Cookies do not harm your computer and do not enable us or any third party to view any information on your computer’s hard drive. You can block cookies by activating the setting in your browser that allows you to refuse the setting of all or some cookies.

Browsers
Browser settings generally accept cookies automatically. You can refuse cookies, or selectively accept certain cookies, by adjusting the preferences in your browser. If you turn off cookies, though, most features of our website will not be available to you. You can find information on how you can adjust the automatic settings in order to control cookies through the respective browsers homepage.

Parts of our website may contain links to third-party Web sites for your convenience and information. If you use these links, you will leave Essencia Capital LLP website. When you access a non- Essencia Capital LLP website, please understand that we do not control the content and are not responsible for the privacy practices of that website. We suggest that you carefully review the privacy policies of each site you visit. This Online Privacy Statement does not cover the information practices of those Web websites linked to our Site. These other websites may send their own cookies to users, collect data, or solicit personal information.

Managing Cookies

For more information about the cookies used by Google analytics:

https://support.google.com/analytics/answer/6004245  

Most web browsers will allow some management of cookies via your browser settings for further information about managing cookies, please visit www.aboutcookies.org  

For further information about cookies, please visit: www.allaboutcookies.org

Changes to this Cookie Policy.
We reserve the right to update this Cookie Policy at any time, and we will make an updated copy of such cookie policy available on our website.

By accepting our disclaimer, you acknowledge that you have read, understood and accept the terms of this Disclaimer.