Privacy Policy

At Bowmoor Capital Limited (referred to as “Bowmoor Capital”, "we", "us" or "our" in this privacy policy), we respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

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Purpose of this privacy policy

This privacy policy aims to give you information on how Bowmoor Capital collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Bowmoor Capital is the controller and responsible for your personal data. Bowmoor Capital is also the controller and responsible for this website. We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy policy.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us by email at hello@Bowmoorcapital.com or by post at our registered office address at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in April 2023. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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.

The data we collect about you

Personal data, or personal information, 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 which we have grouped together as follows:

Identity Data includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and other similar information.
Contact Data includes your billing address, delivery address, email address, social media profile details, telephone numbers and other similar information.
Nationality or Tax Identification Data includes your nationality, immigration and/or visa status, passport number(s), other government issued national identification number, place of birth, national insurance number, tax residency and tax identification information, social security number, driving licence number, images of passports, driving licences or other proof of identity document(s) and other similar information.
Employment Data includes your industry role, business activities, names of current and former employers, copies of your CV or resume and other similar information.
Financial Data includes your bank account details, payment card details, history of investment holdings and transactions, credit checks and other similar information.
Transaction Data includes details about payments to and from you, travel and other expenses and other similar information.
Technical Data includes 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, other technology on the devices you use to access this website, and other similar information.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not seek to collect or otherwise process your sensitive personal data (being personal data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life or orientation, genetic or biometric or any other information that may be deemed to be sensitive under applicable law) except where:

the processing is necessary for compliance with a legal or regulatory obligation (including anti-money laundering processes, counter-terrorist financing procedures, sanctions checks, politically exposed persons checks and, where relevant, political contribution checks which may include information about your political opinions or criminal offences data);
the processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law or regulation;
you have made such sensitive personal data public;
the processing is necessary for the establishment, exercise or defence of legal rights;
the processing is necessary for reasons of substantial public interest and occurs on the basis of an applicable law or regulation that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests; and
we have in accordance with applicable law and regulation, obtained your explicit consent prior to processing your sensitive personal data (it should be noted that this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How your personal data is collected

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services; create an account on our website; subscribe to our service or publications; request marketing to be sent to you; or give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as follows:

Technical Data from the following parties: analytics providers such as Google based outside the UK; advertising networks; and search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the UK.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

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:

Where we need to perform the contract we are about to enter into or have entered into with you.
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. This means that we process your personal data for purposes such as: for the provision of financial services and ancillary services; for anti-money laundering, anti-bribery, “know your client” and other due diligence processes; to onboard new business relationships; to manage our relationship with you efficiently; to allow us to effectively and efficiently manage and administer the operation of our business, including the management of our properties and offices; for the prevention of fraud; and for managing risks to which our business is exposed.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

More specifically, we may process your personal data in the following situations (please note that not all process will be relevant to you and your relationship with Bowmoor Capital and some of these purposes may overlap):

Provision of services to you: To enable us to provide products and services you have requested; to provide you with any information relating to such products or services; and to respond to any comments you may send us.
Anti-money laundering, anti-bribery, “know your client” and other due diligence processes: To fulfil our regulatory and legal obligations relating to the prevention of money laundering, anti-bribery, fraud prevention, counter-terrorist financing, politically exposed persons checks, sanctions, regulatory and law enforcement checks and any other “know your client” checks. We may use third party services, such as fund administrators or third party screening service providers to help with these processes. This includes confirming and verifying your identity, and screening against lists maintained by a third party which assists with this process (such as sanctions lists from governments around the world, as well as other information about individuals on this list which may include information about criminal convictions or political opinions, which has been obtained from publicly available sources, such as newspapers and company registrars).
New business onboarding: To onboard new business relationships and comply with our internal policies and procedures.
Administration of any interests you may hold in Bowmoor Capital: To enable us to administer your investment in shares in Bowmoor Capital and to maintain our shareholders register.
Relationship management: To enable us to efficiently manage our relationship with you or your business; to keep our records up to date; to maintain records of services provided and our interactions with you; and to respond to any complaints we may receive from you and to seek to resolve these.
Manage service provider and distributor or intermediary relationships: To enable us to manage how we work with other companies that provide services to us and our investors.
Product development: To assist in the development of new products and services.
Research: To conduct market, client or investment research; and to engage with you for the purpose of obtaining your views on our services, products and events.
Business and financial management: To run our business in an efficient and proper manner, including managing our financial position, business capability, planning, communications, corporate governance (such as company registers and other company secretarial functions), audit, insurance, sales, event organisation and vendor management; to enable third parties to provide us (or our clients or prospective clients) with services; to respond to client due diligence requests; to investigate and respond to client complaints; and to manage the performance and security of our equipment, IT systems and electronic platforms, including administering access rights.
Risk management: To effectively operate our audit, compliance controls and other risk management functions.
Legal, regulatory and compliance: To operate effectively our legal, regulatory and compliance processes, including but not limited to those that relate to the maintenance of regulatory registrations and conflicts of interest management.
Investigations: To detect, investigate and prevent breaches of legal obligations or internal and regulatory policies; and to detect, investigate and prevent the commission of criminal offences, in each case in accordance with applicable law and regulation.
Fraud prevention: To detect, prevent and investigate fraud or potential fraudulent activity.
Legal proceedings: To establish, exercise or defend our legal rights.
Operation of this website and IT operations: To operate and support this website; to process your registration on this website; to communicate and interact with you via this website; to manage our IT systems and operations; and to operate our IT security and audits.
Security: To provide for physical security of our premises, staff, tenants of or visitors to those premises (including records of visits to our premises and CCTV recordings) and electronic security (including login records and access details, where you access our electronic systems).
Health and safety: To perform health and safety assessments and recordkeeping; and to comply with related legal obligations.
Marketing and event planning: To provide you with information concerning features, services, products, fund launches, corporate events and related information.
Suitability and appropriateness: To determine your suitability to be granted access to this website; to determine your eligibility for any financial services products offered by Bowmoor Capital; and to satisfy other regulatory suitability and appropriateness requirements.

Marketing and opting out

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase, experience or other transactions.

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.

Disclosures of your personal data

We share your personal data with Bowmoor Capital staff for the business purposes described above, such as providing services to you and operating this website. In addition, we may share your personal data with the third parties set out below for the purposes set out above:

Governmental, legal, regulatory, tax or similar authorities, ombudsmen, central and/or local government agencies; and/or law enforcement officials (if mandated by law and regulation or if required for the protection of our legitimate interests).
Anti-fraud services in relation to data on known or suspected fraudulent activity;
Third party service providers (for example, providers of website hosting and maintenance, provision of website analytics and online advertising, who process personal data on behalf of Bowmoor Capital).
Third parties to whom you request us to send your personal data.
Third party processors (such as payment services providers and banks).
Our professional advisers (such as our auditors, accountants, financial advisers and lawyers).
Any relevant party, claimant, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights in accordance with applicable law and regulation.
Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law and regulation.
To any relevant party in connection with our anti-money laundering, anti-bribery, anti-fraud or “know your client” requirements (including third party service providers which carry out sanctions checks on our behalf). Such service providers may also keep personal data which we provide, or which you provide to them direct, in order for them to provide identity verification services to other organisations.
Any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation) or the assets or business of any of our funds.

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

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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.

How long we retain and use your personal data

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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. 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.