Arini Capital Management Privacy Notice – UK

This privacy notice tells you how Arini Capital Management Limited (the “Firm”, “us”, “we”) collects, uses and processes your Personal Information. 

For the purposes of any applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679) (“GDPR”) (the “Data Protection Laws”), the Firm is a “data controller” responsible for Personal Information that you provide to us in relation to this website. 

This Policy may be updated from time to time. Any changes will be published on this page. 

Identity and contact details of the data controller:

Arini Capital Management

2 Park Street, 

London, 

W1K 2HX

Please contact a member of the Firm’s Compliance Team with and queries or concerns regarding the handling of your Personal Information: [email protected]

The Compliance Team will direct you to the Firm’s designated privacy officer. 

What Personal Information we collect

By “Personal Information” we mean all of the personal and financial information that we collect, use, share and store, which relates to you and directly or indirectly identifies you. 

We collect your personal information, in the following ways and for the following purposes, including but not limited to: 

1. For the purpose of investor / client establishment.
2. Anti-Money Laundering and due diligence requirements related to on-boarding as e.g. a client / investor / counterparty. 
3. Employee / contractor on-boarding and related due diligence requirements. 
4. Potential marketing distribution requests. 

We may collect and process the following kinds of Personal Information: 

1. Personal Information provided directly to us by you, or another person on your behalf. This may include, (by way of a non-exhaustive list): 

1. First and last name;
2. Contact details; 
3. Residential or business addresses;
4. Emergency contacts;
5. Education details;
6. CV;
7. Nationality;
8. Employment history;
9. Verbal or written references;
10. Right to work information; and
11. Details of any criminal convictions (e.g. Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks). 

1. Personal Information supplied to the Firm through Investor Relations as a prospective or actual investor. This may include, (by way of a non-exhaustive list):

1. Investment details, including aims and objectives;
2. Financial information associated with managing your account with us;
3. Country of tax residency;
4. Social Security /Tax identification number;
5. Information about assets or net worth;
6. Credit history;
7. Signature;
8. For regulatory purposes, copies of your passport or driver’s license; and
9. Any other relevant information provided by you to us in correspondence, whether by email, written letter, or telephone call.

How and why do we use your Personal Information? 

We process your Personal Information to the extent necessary for us to carry our investment activities, provide communications to you, meet our legal and regulatory obligations, and for other legitimate purposes permitted by law. 

These purposes may include (by way of a non-exhaustive list): 

1. Operation, administration and management of our business;
2. Maintaining the quality of, and improving the website; 
3. Communicating, where you have requested or consented, information updates or marketing materials;
4. Recruitment purposes;
5. Identification checks, including due diligence, KYC, anti-money laundering or other similar checks to ensure we are compliant with our legal obligations; 
6. Protecting against and identifying fraud, cyber attacks and other unlawful activity;
7. Compliance with applicable laws, rules, regulatory requirements and internal policies and procedures; and 
8. Complying with requests from regulatory, governmental, tax and law enforcement authorities.

We may have disclosed any of the categories of Personal Information listed above for any of the business purposes described in this section in the past 12 months.

Lawful bases 

Under UK data protection law, we must have a “lawful basis” for collecting and using your Personal Information. You can find out more about lawful bases on the ICO’s website. 

We are entitled to process your Personal Information for the above purposes on the following bases:

1. ‘Contract performance’ – collecting or using Personal Information so we can enter into or carry out a contract with you. This is the Personal Information needed to operate/manage your account, product or service. 
2. ‘Legal obligation’ – collecting or using your Personal Information so we can comply with the law. 
3. ‘Legitimate interest’ – using your Personal Information where the benefits of us using your Personal Information are legitimate and not outweighed by your interests or legal rights.
4. ‘Consent’ – using your personal information where we have permission from you after we gave you all the relevant information. Where consent is the only legal basis for us using your information, you may withdraw this at any time. 

How long we keep Personal Information

We will not retain Personal Information for longer than is necessary in relation to the purpose for which it is collected, subject to the applicable Data Protection Laws. How long we hold your Personal Information for may vary. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which we have to keep your Personal Information). 

From time to time, we will review the purpose for which Personal Information has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

Who we share Personal Information with

We may share your information within the Firm for the purposes described above, in accordance with this Policy. All employees and contractors are required to follow our data Privacy Policy when handling information.

We may also share your Personal Information with third parties outside of the Firm for the following purposes:

1. Legal Obligation: we may share Personal Information:
   1. To the extent that we are require to do so by applicable law, regulation or court order, by a governmental body, regulator, law enforcement agency;
   2. In connection with any legal proceedings or for crime prevention purposes;
   3. In order to establish or defend our legal rights.
2. Service Providers and Third Parties: we may share Personal Information with the below (by way of non-exhaustive list). 
   1. Services relating to HR, including payroll service providers, benefits providers, reference providers, human resource management providers, background check providers and healthcare providers;
   2. Cloud services providers, relating to data storage, sales, marketing, investigations and customer support;
   3. Professional third parties, including law firms, accountants, and auditors;
   4. Affiliated third parties, including financial institutions such as investment advisers and transfer agents. 

These Service Providers and Third Parties will be subject to appropriate data protection obligations, and they will only use your information as described in our Privacy Policy, or as otherwise notified to you.

1. Business sale: we may share Personal Information in connection with the sale of our business or assets, or an acquisition of our business or assets by a third party for due diligence purposes. 

Protection of Personal Information

We have in place appropriate technical and organisational measures to protect the Personal Information that we hold about you.

To protect your personal information from unauthorised access and use, we apply organisational and technical security measures in accordance with applicable Data Protection Laws. These measures include computer safeguards and secured files.

We will notify you of any material Personal Information breaches affecting you in accordance with the requirements of applicable Data Protection Laws.

Your Rights

Depending on your home country, you have a number of legal rights in relation to the Personal Information that we hold about you¹. In most cases these can be exercised free of charge. These rights include the following: 

1. The right to request access to your Personal Information; 
2. The right to request rectification of your Personal Information; 
3. The right to request erasure of your Personal Information; 
4. The right to restrict our processing or use of your Personal Information; 
5. The right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities); 
6. If your consent to processing has been obtained, the right to withdraw your consent at any time;  
7. Where relevant, the right to request the portability of your Personal Information; 
8. The right to receive some Personal Information in a structured, commonly used and machine-readable format where this is technically feasible (note this only applies to Personal Information which you have provided to us, and may not always apply);

1. The right to not to be subject to solely automated decisions, including profiling, which have a legal or similarly significant effect on you; and
2. the right to lodge a complaint with a supervisory authority.

Please note that there may be circumstances where you ask us to erase or limit processing of your Personal Information, but we are otherwise legally entitled or required to refuse such a request. 

Cookies:

We may send text files (“cookies” or other cached files) or images to your web browser to collect and/or store information on your computer. Such text files and images are used to support the operation of our digital offerings and for technical convenience to store information on your computer. 

We may use information stored in such text files and images to customise your experience on our website and to monitor use of our website. Many web browsers allow you to block cookies. If you block cookies you may not be able to access certain parts or use all features of our website. You can disable cookies from your computer system by following the instructions on your browser or at http://www.allaboutcookies.org/.

How to complain

If you have any concerns about our use of your Personal Information, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

In Ireland, the data protection authority is the Data Protection Commission (available at https://www.dataprotection.ie/). 

Last Updated

September 2024

¹A request must (a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and (b) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.