Privacy policy

This privacy statement applies to Upturn Ltd and Upturn CA Ltd, with registered address at 75 Western Avenue, Southall UB25HQ, and the entities we own or control (“Upturn”, “Upturn CA”, “we”, “us” or “our”).

Upturn and Upturn CA are committed tothe principles of the General Data Protection Regulation and Data Protection Act to protect your information by handling it responsibly and safeguarding it using appropriate technical, administrative and physical security measures.

We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Legislation and as set out in this statement.

When we provide services to associates or our clients and perform due diligence checks in connection with our services (or discuss possible services we might provide), we will process personal data.

We may process your data because:

  • you give it to us (for example, in a form on our Website);
  • other people give it to us (for example, your employer or adviser, or third- party service providers that we use to help operate our business); or
  • it is publicly available.

The personal data we process may include your:

  • contact information, such as name, address, country of residence, email, and mobile phone number;
  • employment and education details (for example, the organisation you work for, your job title and your education details);
  • financial information, such as bank account and VAT information.

We do not typically collect sensitive or special categories of personal data about individuals.

We process information about our associates, their companies and/or our clients to enable us to provide our services to our associates or our clients, and to meet our legal or regulatory obligations.

In addition to the above, we may also use your personal data collected via our Website:

to manage and improve our Website;

  • to tailor the content of our Website to give you a more personalised experience;
  • to draw your attention to information about our services that may be of interest to you; or
  • to manage and respond to any request you submit through our Website.

We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process personal data. We rely on one or more of the following lawful grounds:

  • Contract – we may process personal data in order to perform our contractual obligations.
  • Consent - we may rely on your freely given consent at the time you provided your personal data to us.
  • Legitimate interests – we may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:
  • o Delivering services to our clients – to deliver the professional services our clients have engaged us to provide.
  • o Direct marketing – to deliver timely market insights and speciality knowledge we believe is welcomed by our business clients and individuals who have interacted with us.
  • Legal obligations and public interests – we may process personal data in order to meet regulatory and public interest obligations or mandates.

We have put appropriate technical and organisational security policies and procedures in place to protect personal data from loss, misuse, alteration or destruction. We aim to ensure that access to personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information.

The transmission of data over the internet (including by e-mail) is never completely secure. So although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.

We seek to ensure that we only keep your personal data for the longest of:

  • the period necessary for the relevant activity or services;
  • any retention period that is required by law; or
  • the period in which litigation or investigations might arise in respect of the services.

You have various rights in relation to your personal data. In particular, you have a right to:

  • obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
  • be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed if at all, storage periods, any third party sources from where it was obtained);
  • ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
  • ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);

If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavour to respond within a reasonable period, and in any event within one month in line with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject. Both Upturn and Upturn CA are registered with the ICO and the Data Protection Officer is Sasha Lilley, Hd of Comrcl & Finance, Upturn and Upturn CA;