What is personal information?

Personal information means any information about you from which you can be identified.  Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and e-mail address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie.

Who we are

PMB Capital Limited is the Controller of the personal information you provide to us. If you have any questions about this Privacy Notice or the information we hold about you please contact us using the details set out below:

Full name of legal entity: PMB Capital Limited
Email address: info@pmbcap.com
Postal address: 49 St. James’s Street, London SW1A 1JT
Contact telephone numbers: 0203 384 2226

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

What types of information do we use?

We collect information in the course of providing our financial services to you.  The information which we collect, use, store and transfer about you are:

 

  • Employment details (job title, company name, address etc.);
  • Information on trading or other financial activity;
  • Instructions or requests (for example if you ask for investment advice);
  • Financial information (financial position and history);
  • Documentary data (things can include passport or drivers licence or other forms of identification);
  • Social and or demographic (profession, work, goals, nationality, income or family situation); and
  • Historical information i.e. previous names and addresses.

 

We collect certain special categories of personal data.  This includes details about criminal convictions and offences of prospective employees.

Consequences of not providing some types of information

Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the goods or services you asked for. In this case we may have to cancel the product or services but we will tell you if this is the case.

How do we collect information about you?

Typically we will collect information from you when you contact us directly or provide information in order for us to provide our products and services.  We collect information from and about you in the following ways primarily through direct interactions when you give us your personal information by filling in forms, during correspondence or other interactions with us.

How we will use your personal information

We only obtain, use and keep personal information where we need it for a specific purpose.  We set out in the table below the ways in which we plan to use your personal information.  We are only able to use your personal information if we have a proper legal reason or basis for doing so.  This is called a legal basis and the regulations require that we have a legal basis so that your privacy is protected.  Most commonly we will use your information in the following ways:

 

  • We have a contract with you. For example, as a client of ours.
  • We have a legal obligation. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information so you understand the risk of the financial services we can provide.
  • We, or a third party, have a legitimate interest in processing the information and your interests and fundamental right do not override those interests. For example, processing your information to source deals.

 

We set out in the table below all the ways we plan to use your personal information and the legal bases we rely on to do so.  We also explain what our legitimate interests are where appropriate:

 

Purpose

Lawful basis for processing
  • We process the personal data of our investors (or their employees and senior management) and the employees and managers of our corporate finance clients in order to facilitate corporate finance and investment advisory services.
  • (If you have a contract with us) Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • We process the personal data of our investors (or their employees and senior management) and the employees and managers of our corporate finance clients in order to facilitate corporate finance and investment advisory services.
  • (If you do not have a contract with us) Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • We process the personal data of our service providers (or their employees and senior management) in order to give effect to our contracts with them, and monitor their work as per the terms of our contracts with them.
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • We process the personal data of a wide variety of business contacts for the purposes of conducting key parts of corporate finance business. Generally, we will store this data, and may use it to communicate with the data subjects at appropriate points in time.
  • Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • We process personal data of all parties (or their employees and senior management) with whom we have a business relationship in order to comply with our KYC and customer due diligence obligations.
  • Processing is necessary for compliance with a legal obligation to which the controller is subject.

We will only use your personal information for the reason for which we collected it.  We will only use it for another reason if we believe that new reason is compatible with the original purpose.  If we do need to use your personal information for a non-related purpose we will tell you about it and explain the legal basis which allows us to do so.

Who we share your information with

We may need to provide information to third parties for a variety of reasons, for example, we may need to provide information to assist in the detection or prevention of crime or for the purpose of safeguarding national security. Please refer to the table in the section ‘How we will use your personal information’ which explains how we use your data. The third parties we share your information with are as follows:

  • Service providers such as compliance consultants, lawyers, accountants and fund administrators

 

Sending your information outside of the United Kingdom

As explained in the section above we will send your information to other third parties who are based outside of the UK, however we will only share your information with them because the following safeguards have been put in place:

  • The country we send your information to is deemed to provide an adequate level of protection by the UK;
  • The information is being transferred between organisations which are engaged in the same economic enterprise, or within our corporate group, and we have an agreement in place which sets out how your privacy will be protected;
  • The entities we transfer your information to are based in the US and are part of the Privacy Shield which requires them to provide a similar level of protection to European standards.

You can obtain further information on the specific mechanism used by us when transferring your personal information outside of the UK by contacting our Data Protection Officer

Storing your information

As a financial services provider we will typically have a contract with you and will need to keep your personal information (updated to ensure accuracy) to fulfil our contract.  We also need to comply with UK law, which often requires us to keep certain records – which will include certain personal information – for several years.

Our policy is to keep records for up to 5 years after you are no longer a client.

The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. When we decide how long we will retain your personal information, we will take into account the amount, nature, sensitivity of your information and how we want to use it as well as the potential risk of harm being caused from unauthorised use or disclosure

Your rights

You are provided with a number of different rights under the data protection laws in relation to your personal information. These allow you:

  • To access your information;
  • To request we correct your information;
  • To request that we erase your information;
  • To object to the processing of your information;
  • To request a restriction in the processing of your information;
  • To request a transfer of your information;
  • To complain to the Information Commissioner’s Office; and
  • To withdraw your consent.

If you wish to exercise any of these rights please contact info@pmbcap.com. Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.

Security

We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required to do so.