PRIVACY POLICY
Introduction
Welcome to Brunswick’s Capital Ltd privacy policy.
We respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you
visit our website and tell you about your privacy rights.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Brunswick Capital Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you contact us through our contact form. This website is not intended for children and we do not knowingly collect data relating to children.
Controller
Brunswick Capital Ltd is the controller and responsible for your personal data (referred to as the “Company”, “we”, “us” or “our” in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise, please contact the DPO using the details set out below:
Contact details
Email address: info@brunswickcap.com
Postal address: Methonis Tower, Office 302, 73 Makarios Avenue, 1070 Nicosia, Cyprus
Telephone number: +357 22 451346
You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the office of the
Commissioner so please contact us in the first instance.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, email.
- Contact Data includes email address and telephone numbers.
- Technical Data includes IP address, time zone setting and location, device type, operating system, and browser type.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where you want to contact us through the contact form in our website and you fail to provide the personal data requested, we will not be able to receive your request and/or assist you.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in the contact form or by corresponding with us by post, phone, email or otherwise.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
4. How we use your personal data
Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests and your interests and
fundamental rights do not override those interests. - Where we need to comply with a legal obligation.
- Where it is necessary to process your query received through the contact
form in our website.
Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that 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 contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data |
Lawful basis for processing including basis of legitimate interest |
|---|---|---|
|
To reply to your query submitted through our contact form |
(a) Identity (b) Contact |
Necessary to grow our business |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud) |
|
To use data analytics to improve our website |
(a) Technical |
Necessary to keep our website updated and relevant, |
Cookies
For more information about the cookies we use, please see https://www.brunswickcap.com/cookies-policy/
Change of purpose
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 and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Law enforcement and public bodies if required by law;
- Professional Third Parties such us lawyers and IT.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then
the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your
personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the EU/Cyprus.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, reporting requirements and in any case we will retain your personal data for a period of 12 months.
9. Your legal rights
Under certain circumstances, you have the following rights under the data protection laws in relation to your personal data:
- Right of access to your personal data: you are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it;
- Right of rectification: you are entitled to request the rectification of inaccurate personal data;
- Right to erasure (right to be forgotten): you are entitled to request that we delete your personal data without undue delay under certain circumstances. There are also certain exceptions where we may not always be able to comply with your request for erasure, for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- Right to restriction of processing: you are entitled to ask us to suspend the processing of certain of your personal data, in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds or a legal obligation to use it;
- Right to object: you are entitled to ask us to suspend the processing of certain of your personal data, on grounds relation to your particular situation.;
- Right to data portability: you are entitled to request us to transfer your personal data to another party;
- Right to withdraw consent: you are entitled to withdrawn your consent at any time in the event that we process your personal data with your consent;
- Right to lodge a complaint with the supervisory authority in Cyprus, the Office of the Commissioner for Personal Data Protection (www. dataprotection.gov.cy).
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Changes to this Policy
This Privacy Policy was last updated in June 2023 and may be changed from time to time to reflect changing legal requirements or change in our processing practices.
11. How to contact us
If you would like more information about the way we manage personal data that we hold about you please contact our data protection officer as set out at the beginning of this policy.
