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Privacy Notice

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1. Who we are

Peel Hunt LLP (“we”, “us”, “our” or “Peel Hunt”) is an independent Limited Liability Partnership offering research, sales, trading and corporate finance services (“services”) to individual clients (retail and professional), as well as to companies and institutional investors.
Peel Hunt is the data controller responsible for the personal data that you provide to us.

Peel Hunt LLP is a UK partnership whose registered office is at Moor House, 120 London Wall, London, EC2Y 5ET, United Kingdom.

We respect the privacy, and are strongly committed to protecting the personal data, of every person who visits the peelhunt.com website (“our website”), who uses the products and services that we make available through the website, or who engages with us to use the services that Peel Hunt otherwise provides.

We also safeguard any personal information provided to us by those applying to work at Peel Hunt.

2. Purpose of this Privacy Notice

This Privacy Notice (the “Privacy Notice”) explains: the nature of the personal data we might collect from you, or which we have obtained about you from a third party; the purposes for which we process your personal information; our approach to protecting that personal data; and the rights you have, for example, in requesting that we delete, update, transfer or provide you with access to that personal data.

3. How to contact us

If you have any questions about this Privacy Notice, or want to exercise your rights set out in this Privacy Notice, please contact us by:

• sending an e-mail to  dpo@peelhunt.com;
• writing to us at the above registered address; or
• telephoning us on: 0207 418 8900.

4. What personal information we collect about you

We collect, process and store different types of personal data on you, depending on whether you are a visitor to our website or offices, an existing or prospective client or investor, or a potential new recruit to Peel Hunt.

The following is a non-exhaustive list which is reflective of the varied nature of the personal information processed as part of our business.

4.1 Visitors to our website

We collect the following information about you:

• Information about your interaction with the website;
• Where you have registered on the website or requested further information on our services: your name, job title, and contact information, including email address;
• Other information relevant to our provision of services to you.

4.2 Visitors to Peel Hunt offices

We require visitors to our offices to sign-in at reception. Visitors will be asked to give their name, and also the company at which they work, unless they are visiting us in a personal capacity (e.g. to attend a recruitment interview).

We have security measures in place at our offices, including CCTV and building access controls. There are signs in our office showing that CCTV is in operation and capturing your image.

4.3 Clients

Typically, we collect the following information about clients of Peel Hunt who enter into a business relationship with us in order to use our services:

• Name and job title;
• Contact information, including postal address and email address;
• Payment information;
• Written and recorded telephone communications with you;
• Other information relevant to our provision of services to you, including information we observe about you based on your interactions with our website;
• Your consent, or otherwise, to receiving marketing material, and your preference for receiving such marketing – by telephone, email or post;
• Other relevant information as required by any regulatory ‘Know Your Client’ and ‘Anti -Money Laundering regulations (or similar); for example, evidence of identity verification.

4.4 Attendees at events

We collect the following information about you if you attend one of our events:

• Name and email address;
• Written and recorded telephone communications with you;
• Proof of identity, where required;
• Your preference for attending certain types of event;
• Your consent, or otherwise, to receiving marketing material, and your preference for receiving such marketing – by telephone, email or post;
• Special dietary requirements, where applicable.

4.5 Prospective Peel Hunt job applicants

For recruitment purposes, in many cases the information that we process comes directly from you. For example, you might tell us your contact details and work history. This personal data may be viewed and processed internally by our HR and Compliance departments and by the recruiting line-manager(s) and other relevant staff.

We process the following information about you:

• Name and contact information, including telephone number and email address;
• Curriculum Vitae, your education, employment history and similar, related information that you may provide to us;
• Right to work documentation and nationality;
• References, and other information, to carry out background checks, where necessary and in accordance with the separate Recruitment Privacy Notice;
• If necessary, we will also process information concerning your health and disability in connection with any required adjustments to working arrangements;
• Other information relevant to potential recruitment to Peel Hunt LLP or to entering into a contract with Peel Hunt LLP.

5. What we use your personal data for

We collect, process, maintain and store personal data from, and about, you in order to:

• verify your identity;
• enable us perform and deliver our services to you;
• monitor, improve and develop the quality of our services to you;
• carry out requests made by you on our website or in relation to our services;
• communicate our performance to you;
• make necessary regulatory communications with you;
• comply with applicable laws, court orders, other judicial processes, or the requirements of any relevant regulator;
• investigate or settle inquiries or disputes;
• enforce our agreements with you;
• protect the rights and property of us or third parties, including other clients and users of our website and services;
• market our services to you, where appropriate (see below);
• assess your suitability for any position at Peel Hunt for which you may apply;
• use your personal data, as otherwise required or permitted by law.

6. The legal bases for processing your personal data

6.1 Contractual and legitimate interest

It is necessary for us to store and use your personal data, either to perform our obligations in accordance with any contract that we may have with you or because it is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we deliver our services in the best way that we can.

6.2 Legal

We may also be required to use your personal data for the following business administration, legal and compliance purposes:

• to comply with our legal obligations, including Know Your Client, Anti-Money Laundering, Anti-Bribery and other similar legal obligations;
• to enter into commercial contracts with you;
• to record any trades and transactions with you;
• to make any necessary corporate filings;
• to enforce our legal rights;
• to protect the rights of third parties; and
• to execute business transactions such as mergers, acquisitions by another company, or sale of all or a portion of our assets.

6.3 Recruitment

We use your personal information for the purpose of assessing your suitability for any position for which you may apply at Peel Hunt, including membership, employment or freelancer positions, summer placements or internships, work experience and also any business support or services role, whether such application has been received by us online, via email or by hard copy or in person.

Where we use your personal information for recruitment purposes, it will be in connection with us taking steps, at your request, to enter a contract with you, or where it is in our legitimate interest to use personal information in such a way as to ensure that we can make the best recruitment decisions for Peel Hunt. We will not process any special categories of personal data about you, except where we are able to do so under applicable legislation or with your explicit consent.

Please note: if you would like further information about how we process personal data in relation to Recruitment please let us know and we can provide you with our full Recruitment Privacy Notice.

6.4 Marketing

We will only send you information about those events and services of ours which we think are most relevant and suitable to you – via telephone, email or post – where you have given us consent to receive such marketing communications, or where we have a lawful right or it is in our legitimate interest to send you such marketing communications.

You can object to receiving marketing information from us at any time, by contacting us via email or post, or by clicking on the relevant unsubscribe link in any of our marketing emails.

7. Your consent

Where our use of your personal information requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided; or
• by informing us by e-mail or post using the contact details set out in this Privacy Notice.

8. Cookies

Cookies are text files containing small amounts of information which are downloaded to your computer or other device when you visit a website - if your browser settings allow it. These cookies are accessed by the originating website on each subsequent visit.

Cookies are useful because they allow a website to recognise a user’s device and remember certain pieces of information that the user has provided to the website previously.

Where you have given your consent, we use cookies at Peel Hunt to collect personal information from the computer hardware and software you use to access our website, or from your mobile, so that we can help provide you with the best possible online experience. This personal information includes:

• an IP address, to monitor our website traffic and volume;
• a session ID, to track usage statistics on our website;
• information regarding your contact preferences and the interests you have shown in our services and products.

By using this information, we are able to measure the effectiveness of our content and how visitors use our website and our services.

You can manage cookies – for example, block or delete them – by adjusting the internet browser settings on your computer or other device.

9. Sharing data

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security policies.

Please note, that when processing your personal data we may need to share it with other third parties, as follows:

9.1 Other Peel Hunt entities

We may share personal data with other Peel Hunt entities, where necessary, for administrative purposes and to provide our services to clients, investors and intermediaries.

9.2 Third party systems providers

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.

9.3 Other third parties

We may share data with other third parties, where we are legally permitted or obliged to do so, including:

• Organisations that assist Peel Hunt in providing or administering our services;
• Companies that assist us with our marketing activities;
• Auditors, lawyers, accountants and other professional advisers;
• Law enforcement agencies;
• Branches of central and local government;
• Regulatory bodies.

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable laws and regulations, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for access to personal data where we are permitted to do so in accordance with applicable laws or regulations.

10. Transfers of personal data outside the European Economic Area

Where necessary, in order to deliver our services, we will transfer personal data to countries outside the EEA (including to Peel Hunt LLP’s US affiliates). When doing so, we will comply with our legal and regulatory obligations in relation to the personal information, including, but without limitation, having a lawful basis for transferring personal information, and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information so transferred.

11. How long we keep your personal information

We retain relevant personal information about you in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world), or for longer if we are required to do so according to our regulatory obligations or professional indemnity obligations. We may then destroy such files without further notice or liability. If you request your files and documents we may charge you the reasonable cost of obtaining and providing you with such information.

12. Confidentiality and security of your personal information

We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security. We regularly review the appropriateness of these measures to keep your personal safe and secure.

In particular, we have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.

All of our members, employees, workers, subcontractors, advisors, and any data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of, and comply with the policies that protect, all the personal information of visitors to our website and all users of our services.

13. How to access your information and your other rights

You have the following rights in relation to the personal information we hold about you:

13.1 Your right of access

On reasonable request, we will confirm whether we are processing your personal data and, if necessary, provide you with a copy of that personal data. If you require additional copies, we may need to charge you a reasonable fee for doing so.

13.2 Your right to rectification

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If you are entitled to rectification, and if we have shared your personal information with others, we will let them know about the required rectification, where possible. On request, and where possible and lawful to do so, we will inform you who we have shared your personal information with.

13.3 Your right to erasure

You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or if you withdraw your consent for us to process it (where you are entitled so to do). If you are entitled to erasure and if we have shared your personal information with others, we will let them know about the erasure, where possible. On request, and where it is possible and lawful for us to do so, we will inform you who we have shared your personal information with.

13.4 Your right to restrict processing

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction, and if we have shared your personal information with others, we will let them know about the restriction, where possible. On request, and where it is possible and lawful for us to do so, we will inform you who we have shared your personal information with.

13.5 Your right to data portability

You have the right, in certain circumstances, to obtain personal information you have provided to us (in a ‘structured, commonly used and machine readable format’) and to re-use it elsewhere, or to ask us to transfer this to a third party of your choice.

13.6 Your right to object

You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
• processing your personal information for direct marketing purposes.

13.7 Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect – or similarly significantly affects you – unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

13.8 Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

13.9 Your right to lodge a complaint with the Information Commissioner’s Office

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the Information Commissioner’s Office (ICO). You can contact the ICO using the following website https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

14. Collection of information by third-party sites and sponsors

Our website contains links to other sites whose information practices may be different from our own. Visitors should consult the other sites' privacy notices as Peel Hunt LLP has no control over information that is submitted to, or collected by, these third parties.

15. Changes to this Privacy Notice

To ensure that you are always aware of how we use your personal information, we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information