We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy was last updated on 23 May 2018.
Where used in this Policy, “NovitasFTCL”, or “the Firm”, shall mean either NovitasFTCL Limited or Novitas Capital Advisors Limited. For the purposes of applicable legislation, including the EU General Data Protection Regulation, as amended or supplemented (the “Data Protection Laws”), the NovitasFTCL company that you have dealings with is the controller of your personal information.
Personal information of business contacts
If you have had contact with NovitasFTCL, for example from a previous meeting or making contact with the Firm, we may store limited amounts of personal information relating to you, such as your name, job title, employer organisation, (potential) transactions that we have discussed and contact details. We will collect and store this personal information for the purposes of:
The personal information we hold about business contacts may be shared with:
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.
Personal information of suppliers and professional advisors
If you are a supplier or professional adviser to NovitasFTCL, we will store limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation, (potential) transactions that we have discussed and contact details. We will store this personal information for the purposes of administering and maintaining records of services or advice we have received, commissioning further services, and for other purposes of this nature.
The personal information we hold about suppliers and professional advisors may be shared with:
In accordance with the Data Protection Laws, our legal basis for storing personal information that you provide to us is that such storage is necessary for our legitimate interests in running and promoting our business.
Personal information of actual/potential management teams
If you are involved in a transaction on which NovitasFTCL advises we may store personal information such as: your CV, details of your previous employment history, your financial status and dealings, and results of other due diligence carried out. This information is collect and stored in order to:
The personal information we hold about actual and/or potential management teams may be shared with:
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that its processing is necessary for our legitimate interests in running our business. Should we enter into a transaction with your involvement, it will also be necessary to process your personal information for the purpose of performing that contract and to comply with our regulatory and legal obligations.
Mandatory provision of information
We shall explain to you when the provision of particular information is mandatory and the possible consequences of not providing particular information. NovitasFTCL will only process the personal information you provide to NovitasFTCL for the purposes listed above.
Sensitive or special category personal data
Different rules apply to data concerning race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences – these are all called sensitive or special category personal data. Please do not send us sensitive personal data as we do not need it.
International transfers of personal information
NovitasFTCL has operations throughout Europe and as such, the personal information that we hold may be transferred to and stored at a country outside of your country of residence, including countries outside of the EEA. In the event that NovitasFTCL transfers personal information to NovitasFTCL group companies or third parties outside of the EEA, we shall endeavour to ensure that those transfers take place in accordance with the Data Protection Laws, for example by entering into data transfer agreements with the recipient.