Privacy Notice
GTO PARTNERS LLP
PRIVACY & COOKIES
PRIVACY
GTO Partners LLP ("GTO", "we", "us" or "our") is committed to protecting and respecting the confidentiality, integrity and security of personal data about individuals whose data we hold ("you", "your").
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and how we comply with our responsibilities under applicable data protection laws, including the General Data Protection Regulation (Regulation (EU) 2016/679) as it forms part of the laws of the United Kingdom and the Data Protection Act 2018 ("Data Protection Laws"). Please read this policy carefully. This website is not intended for children and we do not knowingly collect data relating to children.
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of our website and the services that we provide to you. It applies to (a) our investors (actual or potential), consultants, suppliers, advisers, business partners and associates and other visitors to our website, and (b) job applicants and potential job applicants.
Data Controller
For the purpose of the Data Protection Laws, the data controller of your personal information is GTO Partners LLP, a limited liability partnership registered in England (registered number OC430916). You can contact us by post (at Forum House First Floor, 15-18 Lime Street, London EC3M 7AN) or by email at enquiries@gtopartners.com.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at the above email address.
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 (www.ico.org.uk). We would, however, appreciate the chance to address your concerns before you approach the ICO so please contact us in the first instance.
Changes to this privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in September 2021.
It is important that the personal data we hold about you is accurate and current and we try to ensure that we keep our records up-to-date. Please keep us informed if your personal data changes during your relationship with us.
Third party websites
Our website may, from time to time, include links to third party websites, plug-ins and applications. Following 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 content including, but not limited to, their privacy policies and practices. When you leave our website, you should read the privacy policy of each website you visit.
1. THE DATA WE COLLECT ABOUT YOU
Personal data we collect
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you. The types of data we collect depends upon the legitimate purpose for which we collect the data.
You are not obliged to provide us with your information where it is requested, but we may be unable to provide certain products and services or proceed with our business relationship with you if you do not do so.
(A) WEBSITE USERS
The following section of this policy sets out the types of personal data we may collect about the users of our website.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
a) Identity data includes your name, title, marital status, date of birth, gender and job title.
b) Contact data includes contact details such as your address, email address and telephone numbers.
c) Technical data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to
access this website.
d) Usage data includes information about how you use our website, products and services.
By operating cookies on our website we also collect certain information about you automatically when you use our website, including details of your domain name, IP address, operating system and browser. For further information about the use of cookies, please see the 'Cookies' section below.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We do not collect any special categories of personal data about you through our website (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.
How is your personal data collected?
We use different methods to collect data from and about you, including through:
a) Direct interactions whereby you may give us your personal data by filling in forms, leaving a business card or by corresponding
with us by post, phone, email or otherwise.
b) Automated technologies which automatically collect technical data as you interact with our website, including about your
equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar
technologies. In particular, we receive information from cookies used by Google Analytics and LinkedIn. Please see the
'Cookies' section below for further details.
c) Third parties or publicly available sources. We may also receive personal data about you from various third parties and public
sources including analytics providers such as Google Analytics.
(B) JOB APPLICANTS
The following section of this policy sets out the types of personal data we may collect about job applicants.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
a) Identity data includes your name, title, marital status, date of birth, gender and job title.
b) Contact data includes contact details such as your address, email address and telephone numbers.
c) Recruitment data includes employment history, qualifications, information provided to us during telephone calls, interviews
and/or meetings with you, information contained in your CV and cover letter or email, information obtained from social
media, including LinkedIn, and references.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We may also collect, store and use "special categories" of sensitive personal data including information about your race or ethnicity, religious beliefs, sexual orientation and political opinions, information about your health, including any medical condition, health and sickness records and/or information about criminal convictions and offences.
How is your personal data collected?
We use different methods to collect data from and about you, including through:
a) Direct interactions whereby you may give us your personal data by filling in forms, providing a curriculum vitae or business card,
corresponding with us by post, phone, email or otherwise, or during interviews and/or meetings with you.
b) Third parties or publicly available sources. We may also receive personal data about you from various third parties and public
sources as set out below:
• Identity and Contact Data from publicly available sources including Companies House records and social media
(such as LinkedIn).
• Recruitment agencies.
• Background check providers and credit reference agencies, including the Disclosure and Barring Service in respect of
criminal convictions.
• Your named referees on a curriculum vitae provided to us.
2. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
a) Where we need to perform a contract we are about to enter into or have entered into with you, or in order to take steps prior to entering into a contract with you.
b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
c) Where we need to comply with a legal obligation, including where it is reasonably necessary to meet our regulatory responsibilities (such as obligations imposed on us by the Financial Conduct Authority ("FCA") and compliance with our fiduciary duties).
Purposes for which we will use your personal data
We have set out below 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.
Please 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 using the contact details above if you require 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 | Lawful basis for processing including basis of legitimate interest |
| To manage our relationship with you which will include: (a) responding to enquiries from you; and (b) notifying you about changes to our terms and conditions and privacy policy |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| To use data analytics to improve our website, products/services, marketing, relationships and experiences | Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To scan and monitor emails sent to us for viruses and other malicious software | Necessary for our legitimate interests (for the provision of IT services and network security) |
| To provide you with information about investments which we manage in which you may be invested and to manage and administer those investments | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to perform activities relating to client management, including communicating with you about potential investment and value creation opportunities for GTO) |
| To update and maintain our records | a) Necessary for our legitimate interests (including the prevention of fraud, money-laundering, sanctions, terrorist financing, bribery, corruption and tax evasion) (b) Necessary to comply with a legal obligation |
| To prepare tax related information | Necessary to comply with a legal obligation |
| Obtaining professional services from our lawyers, accountants, auditors and other consultants | (a) Necessary for our legitimate interests (to run our business and receive accurate and comprehensive advice) (b) Necessary to comply with a legal obligation |
| To assist with our recruitment process including: (a) to assess your skills and qualifications, to consider your suitability for the position; (b) to carry out background and reference checks, where applicable; (c) to communicate with you about and in connection with the recruitment process; (d) to keep records related to our hiring processes; and (e) to comply with legal or regulatory requirements. |
(a) In order to take steps prior to entering into a contract with you (b) Necessary for our legitimate interests (in order to decide whether to appoint you to work for us, to grow our business and perform adequate due diligence on employment candidates) (c) Necessary to comply with legal obligations (including our obligations to the FCA) |
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 a different or 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.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
JOB APPLICANTS
We process personal data in relation to our recruitment process as described above. Details of how we process that data are set out below.
Our Recruitment Process
Once we receive your CV and covering letter or your application form, we may process that information to decide whether we have any suitable vacancies and if you meet the basic requirements to be shortlisted for that role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the work. If we decide to offer you the work, we will then take up references and we may carry out a criminal record or other checks before confirming your appointment.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Failure to Provide Information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
Special Category Data
We will use your sensitive personal data in the following ways:
• we will use information about your disability status to consider whether we need to provide appropriate adjustments during the
recruitment process, for example whether adjustments need to be made during the interview; and
• we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life
or sexual orientation, to ensure equal opportunity monitoring and reporting.
We envisage that we, or our recruiter, will process information about criminal convictions. We will collect information about your criminal convictions history if we would like to offer you the work or a position (conditional on checks and any other conditions, such as references, being satisfactory). We are required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
3. DISCLOSURES OF YOUR PERSONAL DATA
We will not disclose personal information we hold about you to any third party except as required for the reasons set out below. We only disclose personal data which we hold about you to these third parties in connection with the purposes set out in the table above.
a) Third parties who provide services to us. These may include our associated investment fund and related entities, IT and
system administration service providers, recruitment agencies, third party platforms we use for certain functions
(such as customer relationship management tools), professional advisers (such as lawyers, bankers, accountants,
auditors and insurers who provide consultancy, banking, legal, insurance, accounting, reporting, archiving and other
professional and/or advisory services).
b) If we are under a duty to disclose your personal data in order to comply with a legal obligation imposed on us.
c) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, or a successor in interest
in the unlikely event of our insolvency, winding up or liquidation. 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.
International transfers
We only transfer personal data outside of the UK where there is an appropriate safeguard to do so, including for example that the recipient country has been deemed adequate by the ICO.
We transfer personal data to the European Economic Area (EEA), which has been deemed adequate by the ICO.
4. HOW WE PROTECT YOUR DATA
We have put in place what we consider to be appropriate security measures to prevent your personal data from being used unlawfully, 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.
5. HOW LONG WE RETAIN YOUR DATA
(A) WEBSITE USERS
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, tax, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
(B) JOB APPLICANTS
If your application is successful, the information you provide during the application process will be retained by GTO as part of your employee file and held in accordance with our applicable policies (including our employee privacy notice) and applicable laws.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
6. YOUR LEGAL RIGHTS
In certain circumstances, you have rights under the Data Protection Laws in relation to your personal data which allow you to:
a) request access to your personal data (known as a "data subject access request"). This enables you to request a copy of the personal
data we hold about you and to check that we are lawfully processing it;
b) request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal
data we hold about you corrected;
c) request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no justified
reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have
exercised your right to object to processing (see point (d) below);
d) object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to processing on this ground. You also have the right
to object where we are processing your personal data for direct marketing purposes;
e) request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data
about you, for example if you want us to establish its accuracy or the reason for processing it;
f) request the transfer of your personal data to you or to a third party. This enables you to ask us to either send you the personal
data which we hold about you, and/or transfer that personal data to another controller, where our processing of that personal
data is based on your consent or pursuant to our performance of a contract with you, and where the processing is carried out by
automated means; and/or
g) withdraw your consent. If we areprocessing your personal data on the basis of your consent, you have the right to withdraw consent at any time. Withdrawing your consent will not affect the lawfulness of processes based on consent before its withdrawal. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Exercising your legal rights
If you wish to exercise any of the rights set out above, please contact us at enquiries@gtopartners.com. For more information in relation to your legal rights, you can visit the ICO website at www.ico.org.uk.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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.
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.
7. CHANGES TO THIS POLICY
We may make changes to this privacy policy at any time. Any changes we make will be posted on this page and, where appropriate, notified to you in writing. Please refer back to this page regularly to see any changes or updates to this policy.
8. CONTACT
If you have any queries about this policy or your personal data, or you wish to submit a data subject access request or raise a complaint about the way your personal data has been handled, please do so by email to enquiries@gtopartners.com.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of these websites.
We use the following categories of cookies:
• Strictly necessary cookies are cookies that are required for the operation of our website. They include, for example, cookies that
enable you to log into secure areas of our website.
• Analytical or performance cookies allow us to recognise and count the number of visitors and to see how visitors move around
our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are
finding what they are looking for easily.
• Functionality cookies are used to recognise you when you return to our website. This enables us to personalise our content for you,
greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this
information to make our website and the advertising displayed on it more relevant to your interests. We may also share this
information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| Cookie Name | Purpose | Category (see list above) | Essential / Non-Essential |
| PHPSESSID |
This cookie is used to store and identify a users' unique session ID for the purpose of managing a user session on the website. The cookie is a session cookie and is deleted when all the browser windows are closed |
Strictly necessary cookies | Essential |
| _csrf |
This cookie is essential for the security of the website and the visitor. It ensures visitor browsing security by preventing cross-site request forgery |
Strictly necessary cookies | Essential |
| _gid |
Installed by Google Analytics, this cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously |
Analytical or performance cookies | Non -essential |
| _ga |
This cookie is installed by Google Analytics and calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookies stores information anonymously and assigns a randomly generated number to recognise unique visitors |
Analytical or performance cookies | Non -essential |
| _iub_cs-* |
This cookie is used to store cookie consent preferences |
Functionality cookie | Essential |
Third Party Cookies
Certain third parties may also use cookies, over which we have no control. These third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies. Please see below named third parties with whom we may share cookies:
To deactivate the use of third party advertising cookies, you may visit the consumer page to manage the use of these types of cookies by following the links above.
Managing Cookies
The browsers of most computers, smartphones and other web–enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the “Help” menu of your browser to learn about how to change your cookie preferences.
However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain (or all) cookies off, it will affect how our website works and you may not be able to access all or parts of our website.
Further information about cookies (including how to turn them off) can be found at www.allaboutcookies.org and www.ico.org.uk/for-the-public/online/cookies.
Some information about how to manage cookies on popular browsers is set out below:
• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari
To find information relating to other browsers, visit the browser developer's website.
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.