Privacy Policy


Moorgate Capital is committed to commercial confidentiality and the safeguarding of individuals’ personal information throughout its operations. This Policy describes our use of personal data and details individuals’ rights associated with this.


In this Policy, we use the terms:
“we”, “us”, and “our” to refer to Moorgate Capital (Corporate Finance) Ltd.;
“Personal Data” to refer to information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier;
“you” and “your” to refer to individuals with whom we interact or seek to interact, or who seek to interact with us, whether this relationship is established or prospective:
  • clients, suppliers, and counter parties to transactions, where these are individuals;
  • staff of clients, of suppliers, and of counter parties to our clients’ transactions;
  • contacts;
  • persons with significant control of clients;
  • representatives of regulatory authorities and of government bodies;
  • visitors to our web sites;
  • staff and job applicants.


Your rights in relation to Personal Data and how you may exercise them
You have the following, mostly non-absolute, rights according to circumstances:
  • where you have given consent for any processing of your Personal Data, the right to withdraw this consent, such that we can no longer use your consent as our basis for the processing;
  • the right to obtain a copy of the Personal Data we hold on you, and to be informed of the purpose(s) of our processing of it, of the categories of personal data concerned, of the retention policy applicable to it, of the category/categories of recipient to whom we disclose it, and of the existence or otherwise of automated decision-making and profiling based upon it;
  • the right to have a copy of Personal Data we obtained directly from you, and which we process by automated means, delivered in machine-readable format, either to you or directly to a data controller you designate;
  • the right, where you identify any inaccuracy, to have your Personal Data rectified or completed;
  • the right to have your Personal Data erased;
  • the right to request the restriction or suppression of our processing of your Personal Data; and
  • the right to object to processing of your Personal Data, which encompasses an absolute right to end its use for direct marketing.
In some situations, we may decide not to comply with your request. For example, we may refuse to erase Personal Data if we need to process it for the establishment, exercise, or defence of a legal claim. Were we to consider your request excessive, we could ask a reasonable fee prior to complying with it. In both cases, we would advise you of our reasons and of your options to challenge our decision.
To exercise these rights please contact us using the details in “Data Controller contact information”, below.


Our basis for processing your Personal Data
We process Personal Data only where we have a lawful reason. The lawful basis for processing will be one of the following:
  • Consent: you have given clear consent for your Personal Data to be used for this type of purpose;
  • Contract: the processing is necessary for performance of a contract of which you or your company are party, or, where you or company expresses interest in entering a contract with us, for our determination of the appropriateness of, and commercial parameters for, doing this;
  • Legal obligation: the processing is necessary for compliance with a legal obligation to which we are subject; and
  • Legitimate interests: the processing is necessary for the purposes of legitimate interests pursued by us or by a third party, for example, where you or your company is a potential counter-party in a potential transaction involving one of our clients or prospective clients.


Personal Data we collect and process
Collection and processing of Personal Data reflects the category of relationship we have with the individual:


Contacts


Collection
Individuals may become contacts in various circumstances:
  • an encounter with one of our representatives at which basic contact details, such as a business card, are provided by the individual;
  • when an individual who, in a similar encounter did not provide details, follows up by electronic message, telephone, or even letter;
  • when an individual approaches us, or one of our representatives, through any channel, and provides contact details;
  • when a third party, with the individual’s consent, shares the individual’s contact details with us, including in cases where all three parties are participating in a common piece of business. For clarity, we do not obtain contact details in bulk;
  • when one of our representatives moves communication with an existing contact onto our platform;
  • when we use publicly available information to make contact with a highly specific individual who, if not unique in this, will be one of no more than a handful of individuals with whom we seek a similar discussion; and
  • when we make contact with a supplier, that has made himself/herself/itself known in the market, with a view to procuring goods or services.
The Personal Data we collect is the basic contact details we receive or take from the public domain, being some or all of:
  • name;
  • company;
  • department;
  • position / corporate title;
  • company address;
  • phone / fax number; and
  • e mail address.
These details are maintained in electronic contact books.


Use
When we hold you to be, or to be staff of, a prospective client, supplier, or counter party to one of our clients’ transactions, we may use the Personal Data to contact you in pursuit of the respective goal; and
We may use the Personal Data to keep in occasional touch with you, with a view to identifying something to our mutual advantage in future. This may comprise an occasional, ad hoc, message written to you by our representative (usually the party to the original contact) and, very rarely, an update about a significant event affecting us. Neither type of communication will be sent when we have reason to believe it would be objectionable to you.


Retention
Personal Data is retained in our electronic contact books until we determine it no longer serves, and will never (again) serve, the above purposes and/or we erase it at your request, in accordance with your rights as described above.


Actual/prospective clients, their staff, and significant individuals associated with a progressing potential transaction
This section addresses further aspects of Personal Data that may apply to these categories of individual, in addition to those described for Contacts. This section applies only where there is a material level of engagement:
  • if you are / a member of staff of a prospective client, not an actual client, we and the prospective client have serious intentions to negotiate a contract; and
  • if you are associated with the counter party to the transaction our client is contemplating, there is potential mutual interest in creating the transaction.


Collection
We may obtain, with your consent, either directly from you or from the company with which you are associated, your career profile, curriculum vitae, or similar information. As appropriate for the envisaged transaction, we may obtain, from the company with which you are associated, or from public sources, details of your participation in the company.


Use
Where you are associated with our client, we may use the Personal Data to promote the client company to prospective counter parties, or to promote the prospective transaction to the counter party, and to brief prospective counter parties on the deal economics, as appropriate. Where you are associated with the counter party, we may use the Personal Data to assist our client assess the attractiveness of the contemplated transaction.


Retention
The Personal Data will be retained for 12 years following completion of the eventuated transaction, or if no eventuated transaction, following the point we ceased advising our client or prospective client on the process.


Clients and their staff
This section addresses Personal Data we process in association with performance of a contract we have with a client. This processing is in addition to that applicable to clients in the preceding sections.


Collection
No additional Personal Data is collected.


Use
We may process your Personal Data for the purposes of providing our services to the client.
We may process your Personal Data for the administration of our engagement by the client, including for collection of our fees and for pursuing or defending any legal claims arising from it.


Retention
We will retain the data for 12 years from the end of our engagement by the client, or to the point at which no possibility of a legal claim, associated with the engagement, remains open, whichever is the later.


Persons with significant control of actual/prospective clients
This section addresses Personal Data we may require for compliance purposes. If your only relationship with us is having significant control of, or a significant interest in, our actual/prospective client, this is the only section that need apply to you.


Collection
We may require specific information, such as identifiers issued by national or supranational authorities, for the purpose of establishing your identity.


Use
We may use the Personal Data to undertake, or have undertaken on our behalf, checks into whether your status prevents or deters us from being, or continuing to be, engaged by the client.


Retention
Processing of the Personal Data will cease if and when we have determined not to become engaged by the client, or when our engagement by the client finishes. We will retain the data for 12 years from that point.


Representatives of regulatory authorities and of government bodies


Collection
Individuals may become contacts in the course of our contacting a regulatory authority or government body or of these entities contacting us, as we discharge our responsibilities to these entities and the entities exercise their oversight of, and perform their public duties over, us. The Personal Data we collect is the basic contact details we receive or take from the public domain, being some or all of:
  • name;
  • organisation;
  • department;
  • position;
  • organisation address;
  • phone / fax number; and
  • e mail address.
These details are maintained in electronic contact books.


Use
We will use your Personal Data solely for the conduct of our relationship with the relevant regulatory authority or government body.


Retention
Personal Data is retained in our electronic contact books until we determine it no longer serves the above purposes and/or we erase it at your request, in accordance with your rights as described above.


Job applicants
When you contact us to explore the potential for building your career with us, we will obtain and process data in accordance with the Contacts section above. This section addresses additional Personal Data considerations applicable to job applicants.


Collection
For evaluation of your candidature, we may request you to provide us with your curriculum vitae. At advanced stages of the recruitment process, we may ask you for:
  • details of your referees;
  • copies of your diplomas;
  • details of your current, or most recent, package;
  • identity documents;
  • identifiers issued by national authorities, such as your National Insurance number;
You may also be asked to complete a diversity monitoring questionnaire.


Use
We may use the Personal Data to:
  • evaluate your fit with our organisation;
  • judge your suitability for the position(s) for which we are considering you;
  • assess the economics of your expectations; and
  • undertake, or have undertaken on our behalf, checks into whether we have formed an accurate perception of your history and whether your legal status is appropriate for a role with us.
Your responses to the diversity monitoring questionnaire will form no part in our decision process and will be used purely for statistical purposes.


Retention
Should you accept a position with us, we will retain your Personal Data for your tenure but for a minimum or otherwise for as long as it may be required for the establishment, exercise, or defence of a legal claim. If you do not accept a position with us, we will not otherwise process your Personal Data, except where you have agreed we can hold it for consideration for future staffing requirements.


Staff
Your contract of engagement describes the terms under which we process your Personal Data and points to where we publish our active Staff Privacy Policy. In case of any query, please contact your department’s Personnel Officer.


Visitors to our websites


Collection
We collect no Personal Data from your use of our websites. Neither do we facilitate third parties’ collection of Personal Data while you are browsing our sites. Where our websites provide links to third-party sites, we can, and do, accept no responsibility for your privacy should you visit these sites. We provide such links for your convenience and not as a general endorsement of the sites.


Others who may have access to your Personal Data
In certain circumstances we may share your Personal Data with third parties. We do this only where legally permitted. These circumstances include:
  • where required by law, ordered by a court, or demanded by a competent law enforcement authority;
  • our reliance upon business partners for provision of components of our service to clients;
  • where we use a service provider for the purpose of extending hospitality or having meeting/conferencing accommodation or similar; and
  • our use of specialists for undertaking background checks in preparation for us creating a relationship with you.
We assume discretion to share Personal Data you have provided to us, in accordance with this. If you prefer that we do not share your Personal Data in this way, please raise this with us. However, we cannot impede the disclosures for which we are legally compelled.


Protection of your Personal Data
We have instigated technical and organisational security measures to protect your Personal Data from unauthorised and unlawful use, from accidental loss, and from other damage. We have in place strong confidentiality agreements with our third party service providers and Data Processors.


Updates to this Policy
This Policy was updated 24 May 2018. Please revisit this page frequently to stay informed of updates in our Policy.


Data Controller contact information
Information Controller
Moorgate Capital
33 St James's Square

London

SW1Y 4JS

Email: dpo@moorgate-capital.com


Complaints
Whilst we trust we will give you no cause, should you want to complain about our use of Personal Data, please send an email detailing your complaint to our Data Protection Office using the email address shown above. You also have the right to lodge a complaint with the relevant supervisory authority:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Email: casework@ico.org.uk
Tel: 0303 123 1113 or 01625 545 745
Web: https://ico.org.uk/