Stanley Privacy Policy

Last updated: November 2023

Stanley Capital Partners LLP, with a registered office at 1 Old Queen St, London SW1H 9JA,, United Kingdom and registered number: OC438675, Stanley Capital Partners GP Limited, with a principal place of business at North Suite, First Floor Regency Court, Glategny Esplanade, St Peter Port, Guernsey GY1 1WW and registered company number: 69511 and Stanley Capital Partners L.P. with a principal place of business at North Suite, First Floor Regency Court, Glategny Esplanade, St Peter Port, Guernsey GY1 1WW and registered number: 4008 (“we”, “our”, “us”), are committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which we will process any personal data or usage data we collect from you, or that you provide to us, in connection with your use of our website at https://stanley-capital.com/ (our “Website”) and in connection with any services we provide to you or interaction you have with us, including when you invest (or a person, firm or entity with which you have a connection invests) in our funds or we manage your funds account for you.

Personal data means any information that directly or indirectly identifies or otherwise relates to a living individual. It includes, for example: names, addresses, email addresses, job applications, photographs, video footage, employment records, records of donations and purchases made, bank details and correspondence to and from individuals. It also includes web browsing information (e.g., cookie data) and IP addresses.

Please read this Privacy Policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. This Privacy Policy supplements any other privacy related notices and policies we may provide to you from time to time, and is not intended to override them. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Website, use our services or otherwise provide your personal data to us. 

We change our Privacy Policy from time to time. Updates to our Privacy Policy will apply only to information collected after the date of the change. We will note on our Website when our Privacy Policy has been updated. Please check the Website regularly for notices of changes to our Privacy Policy.

For the purposes of United Kingdom (“UK”), Stanley Capital Partners LLP is the data controller. For the purposes of Guernsey, Stanley Capital Partners GP Limited is the data controller.

We collect personal data when provided to us by you:

• Prospective and current employees, staff and contractors;
• those who request our services;
• those that invest or apply to invest in a fund through us;
• for those that we manage their fund portfolio;
• those that apply to receive marketing; and
• those that contact us via our website, telephone, email, social media websites or other platforms, or via our ‘contact us’ page;

We are also working closely with third parties (including administrators, placement agents, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers) and may receive and process information about you from them. You can control what personal data is shared with us from third party websites, using the controls provided on those websites. The forgoing mentioned service providers may also act as independent data controllers with respect to your personal data as a result of your investment (or a person, firm or entity with which you have a connection invests) in any of our funds. Where relevant, you should also refer to their applicable privacy policy available on their relevant websites.

We may also collect information and personal data automatically from you when you visit our Website. This information includes: (i) your IP address; (ii) device information including, but not limited to, name and type of operating system; (iii) mobile network information; (iv) standard web information such as your browser type and the pages you access on the Website; (v) transaction information (but not payment card or account details), including device information, transaction details, and IP address; (vi) security information including a list of certain installed software, device and internet connection information, and available space on the device.

If you choose to provide personal data to us about someone else (such as an individual who wishes to invest in a fund) you must ensure that you are entitled to provide that personal data to us and that, without us taking any further steps, we may collect, use, disclose and otherwise process that personal data as described in this Privacy Policy. In addition, you must ensure that the individual concerned is aware of the various matters detailed in this Privacy Policy, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our information disclosure practices, the individual’s rights, and the consequences if the personal data is not provided (such as their inability to invest in a fund, or our inability to manage their fund portfolio or invest in a fund).

Please note that if you do not provide certain personal data to us when requested (and where relevant, provide your consent), we may not be able to provide you with some or all of our services (including those set out in this Privacy Policy or in other agreements we enter into with you).

Depending on how you use this Website, your interactions with us, the services your request from us, and the permissions you give us, the purposes for which we use your personal data include:

• to provide you with any information or services that you request from us (e.g. to invest in a fund or requesting us to manage your fund portfolio), which includes information for the onboarding process, running credit check, background checks, criminal checks, as well as information required to legally invest and/or manage your funds;
• to provide you with information about other services we offer or other funds accounts;
• to process your payments and investments;
• to communicate with you as necessary in connection with your account;
• where permitted, to provide you with marketing;
• to analyse and improve our services and to notify you about changes to fund accounts or services;
• for the management and administration of our business;
• to administer and improve the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep this Website safe and secure;
• to comply with and in order to assess compliance with applicable laws, rules and regulations (including tax reporting purposes pursuant to tax legislation and regulatory assessments), industry codes, voluntary codes we decide to adopt, or good practice and internal policies and procedures;
• to confirm and verify your identity and to conduct background, credit and related checks;
• to detect, investigate and prevent fraud, money laundering, bribery, corruption, tax evasion and other crimes or malpractice;
• for the purpose of, or in connection with, any legal proceedings;
• to obtain legal advice or to establish, exercise or defend legal rights;
• the administration and maintenance of databases storing personal data; and
• to comply with our contractual obligations.

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 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 these are required or permitted by law. 

We do not make decisions about you based on automated processing of your personal data.

We collect the following categories of personal data:

Prospective and current employees, staff and contractors:

• (i) name, (ii) age/date of birth, (iii) gender, (iv) address, (v) email address, (vi) next of kin details or emergency contact, (vii) disabilities, (viii) ID card/national identifier details, including national insurance number, (ix) passport, (x) visa/work permit, (xi) biometric data, (xii) ethnicity, (xiii) bank details, (xiv) data relating to physical and mental health and similar information, (xv) job title, (xvi) employment history, (xvii) criminal history, (xviii) salary, (xix) benefits, (xx) pension, (xxi) training records, (xxii) professional references, (xxiii) length of employment, and (xxiv) notice period.

Individuals who enter into an agreement with us for our services:

• (i) Individual or company name, (ii) address, (iii) email address, (iv) telephone number, (v) date of birth, (vi) citizenship, (vii) entities in which you or someone connected to you has an interest, (viii) the names of your legal and/or financial advisors, (ix) financial information, (x) national insurance number, (xi) information obtained from ID documents, such as drivers licence number or passport number, (xii) information about criminal convictions and offences, (xiii) employment history (including position, level, seniority and professional title), (xiv) current income and past income received; (xv) tax details, including tax status, tax identification numbers, tax residency, status under dividends and interest withholding tax rules, FATCA rules, CRS rules and any other tax rules; (xvi) bank account details, (xvii) financial information including origin of wealth, (xviii) credit scoring/ratings, and (xix) publically available information.

Individuals who attend an event we host:

• (i) Individual or company name, (ii) address, (iii) email address, (iv) telephone number, (v) data relating to physical health e.g. disability requirements when attending an event, program or educational class, (vi) data relating to health, such as dietary requirements, and (vii) biometric data from any photographs or video footage.

Individuals who invest through or with us once being onboarded as a customer:

• In addition to all the information provided above, in order to invest for or on your behalf, we will also process (i) the name of the fund, and (ii) the quantum being invested. Please note that we do not process your account details; our administrators will process your account details (and their terms, including their privacy policy, will apply to such processing).

Individuals who contact us via our contact us page or on the telephone (whether to send a request for our services or request further information relating to our services):

• (i) name, (ii) address, (iii) email address, (iv) telephone number, and (v) the reason why you are contacting us and the service you are interested in.

Individuals that sign-up to marketing:

• (i) name, (ii) address, (iii) email address, (iv) telephone number, and (v) the marketing you would like to receive.

Please let us know if any of your personal data changes as soon as possible. Failure to provide accurate information or to up to date information may have a detrimental impact upon your investment, including the processing of any subscription or redemption instructions or the suspension of your account. Failure to provide information where the same is required for anti-money laundering, pursuant to automatic exchange of information agreements, or other legal requirements means that we may not, or may no longer, be able to offer you our services and have you as a client.

We are entitled to use your personal data for these purposes because one or more of the following legal bases applies:

• your consent, e.g., when you subscribe to receive marketing or when you provide special category data, such as when we have to run credit checks or background checks, or you provide dietary requirements or disability access requirements to attend an event, as well as other categories of data for an employee or contractor to be provided with a job. Note that you can withdraw this consent at any time;
• to take steps to enter into or perform a contract with you or other individuals, e.g., to run background and credit checks, or to provide you with the services you contract with us for;
• compliance with our legal obligations;
• in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
• ours or our third parties’ legitimate interests, where these are not overridden by your privacy and data protection rights. Our legitimate interests include: fulfilling your requests for information about us, the services we offer, allowing us to effectively and efficiently provide you with our services, allow us to administer and manage the operation of our business, maintaining compliance with internal policies and procedures, personalising and tailoring the content of our Website, maintaining and improving our Website so that users can get the information they need from the Website quickly, offering optimal, up-to-date security solutions for IT systems, and for internal management purposes.

We do not use or share your personal data with others except as described in this Privacy Policy. In certain circumstances, we will share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law. Specifically, we share your personal data:

• With service providers and suppliers in our legitimate interests, or to perform a contract with you. Such third parties include: (i) banks, financial institutions or third party lenders, (ii) administrators (such as to Alter Domus (Guernsey) Limited), (iii) IT security vendors; (iv) website hosting vendors; (v) placement agents, and (vi) payment process providers who will process your investments. These service providers assist us with many different functions and tasks for the purpose of the management and administration of our business, in order to facilitate the provision and enhancement of services to you.
• When you request us to share certain information with third parties, with consent. Such as when you want to inform financial institutions about the funds you are investing in, or when you provide your dietary requirements or disability access requirements for an event. With your permission we will disclose your personal data to relevant third parties.
• With professional advisors in our legitimate interests or as required by law. As necessary, we will share your personal data with professional advisors functioning as service providers such as auditors, law firms, or accounting firms.
• For legal and security reasons and to protect our services and business, in our legitimate interests or as required by law. We will share your personal data with regulators, law enforcement agencies, public authorities, or any other relevant organisations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.
• With our affiliates, in our legitimate interests. We may share your personal data with companies within our corporate family.
• In connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organisation, in our legitimate interests. We will share your personal data with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.

These third parties will be expected to be subject to confidentiality requirements (either by contract, professional obligation, duty or otherwise) that require them to only use your personal data as described above.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the UK, the Bailiwick of Guernsey or the EEA. It may also be processed by staff operating outside the UK, the Bailiwick of Guernsey or the EEA working for us or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your payment details and the provision of services. If we transfer personal data to a third country outside of the UK, the Bailiwick of Guernsey or EEA, we will take all reasonably necessary steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy, and the personal data will be sent pursuant to a valid transfer mechanism, such as the EU standard contractual clauses, the UK Addendum or the UK International Data Transfer Agreement, or any equivalent contracts issued by the relevant competent authority of the EEA, UK or the Bailiwick of Guernsey, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. Please contact us (using the information in section 16 below) if you would like more information about these safeguards and the transfer we are carrying out.

We have implemented commercially reasonable controls and appropriate technical and organisational measures to protect your personal data, as well as to maintain the security of the information contained in our systems in respect of personal data. Appropriate controls (such as restricted access) are placed on our computer systems and used where appropriate. Reasonable measures are taken to ensure physical access to personal data is limited to authorised employees.

When you contact us about your personal data, you may be asked to provide evidence of your identity (e.g., driver’s licence or passport). These types of safeguards are designed to ensure that only you, or someone authorised by you, has access to your file.

Although we do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email and any transmission is at your own risk.

We will retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy and in each case in accordance with applicable legal and regulatory requirements in respect of permitted or required retention periods and limitation periods for taking legal action. No personal data shall be retained for longer than seven years.

We will also retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies.

We may aggregate or de-identify the personal data once the retention period has passed. Aggregation means that we combine the non-personal information of numerous people together so that the data does not relate to any individual. “De-identify” means that we attempt to remove or change certain identifiers that may be used to link data to a particular person.

We take reasonable steps using appropriate technical methods in the circumstances to delete or destroy your personal data when we no longer have a legal basis to retain it or to ensure that the personal data is anonymised or irrecoverable.

We do not knowingly collect personal data from children who aged below 18 (or whatever the age may be of a child in your jurisdiction) without first obtaining consent from their parent or guardian. 

If we learn that personal data has been collected through the Website or via any other form from children without parental consent, we will take the appropriate steps to delete the personal data. If you are a parent or guardian and you wish to review the personal data we have collected about your child or delete it, or if you discover that your child has provided us with personal data without your consent, please contact us using the contact information in section 16 below.

Depending on your preferences, and if you are in the EEA and UK, if you have opted-in or notified your interest in a particular product or service, or if you have you previously attended an event, we may send you marketing communications.

If you no longer wish to receive marketing communications from us you can opt-out at any time by informing us (using the information in section 16 below) or by using the ‘unsubscribe’ method provided on the form of marketing you received e.g. the ‘unsubscribe’ button in the email.

Your option not to receive promotional and marketing material shall not preclude us from corresponding with you, by email or otherwise, regarding your relationship with us (e.g., your account and activity or our responses to questions or inquiries you pose to us); shall not preclude us, including our volunteers, employees, contractors, agents and other representatives, from accessing and viewing your personal data for our internal business purposes; and shall not preclude us from disclosing your personal data as described in this Privacy Policy for purposes other than sending you promotional and marketing materials.

We use cookies and other similar technologies to collect information about your browsing activities over time and across different websites. Cookies allow us to recognize and count the number of users and to see how users move around our website when they are using it. This helps us to improve our services and the way our website works. You can find more information about cookies and how to manage them here.

For more information, please refer to our Cookies Policy.

If you are located in the EEA or the UK, you have certain rights in relation to your personal data:

• Access: You have the right to access personal data we hold about you, how we use it, and who we share it with.

• Portability: You have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.

• Correction: You have the right to correct any of your personal data we hold that is inaccurate.

• Erasure: In certain circumstance, you have the right to delete the personal data we hold about you.

• Restriction of processing to storage only: You have the right to require us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances.

• Objection: You have the right to object to our processing of your personal data.

• Objection to marketing: You can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you.

• Withdrawal of consent: Where we rely on consent to process your personal data, you have the right to withdraw this consent at any time by emailing us at info@stanley-capital.com.

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal data.

To exercise any of these rights, you should contact info@stanley-capital.com. We will respond to requests to exercise these rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances, such as where the request is categorised as complex, or you have been delayed in providing us with further information or proof of identity).

Our website may contain links to other websites, online platforms, plug-ins or other applications operated by third parties. We do not control such other sites or applications, and are not responsible for their content, their privacy policies, or their use of your information. These third-party sites are not subject to this Privacy Policy, and we recommend that you check the privacy and security policies of each website that you visit. We are only responsible for the privacy and security of the personal data that we process as a data controller and have no responsibility for the actions of other third party data controllers in relation to your personal data. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal data by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

If you have complaints about how we process your personal data, please contact us at info@stanley-capital.com and we will respond to your request as soon as possible.

If you think we have infringed data protection laws, you can file a complaint with the data protection supervisory authority in your jurisdiction, for example, for the UK, you may contact the UK Information Commissioner’s Office www.ico.org.uk and in Guernsey, you may contact the Guernsey Data Protection Authority www.odpa.gg.

In addition to complaining to the Guernsey Data Protection Authority, you may also appeal to certain courts against: (i) any failure of the Guernsey Data Protection Authority to give written notice of whether the complaint is either being investigated or not being investigated and where applicable, the progress and the outcome of the investigation and (ii) a determination of the Guernsey Data Protection Authority not to investigate the complaint or a determination that a controller or processor has not breached or is not likely to breach an operative provision in connection with the complaint. 

If you have any questions, comments, or concerns about our Privacy Policy, our use of your personal data, or any other data protection matters, or to submit a request relating to your personal data, do not hesitate to contact us at info@stanley-capital.com.