August Equity Privacy Policy

1. Introduction

At August Equity LLP (“August Equity“, “we“, “us“, “our“) we recognise that it is important for you to understand how we use your personal data. Therefore, please read the following information carefully as it contains important information regarding the August Equity website at www.augustequity.com (this/our “Site“) and the way in which we use your personal data.

This privacy policy explains how we use personal data about visitors to our Site, including customers and potential customers and about individuals that get in contact with us, social media users, agency partners, affiliates (e.g. influencers), press contacts and those individuals whose personal data we otherwise process in the course of our business. This privacy policy also covers data processing related to job applications and our recruitment activities.

Where you engage us to provide services to you, this privacy policy is to be read in conjunction with our “Terms and Conditions of Use”.

We will only use personal data in ways that are described in this policy and only ways that are consistent with our obligations and your rights under applicable data protection laws.

2. Who we are

August Equity LLP is a company registered in England with company number OC313101, VAT registration number 782 5772 89 and whose registered office is at 10 Slingsby Place, St Martin’s Courtyard, London, WC2E 9AB.

For the purpose of applicable data protection laws, the “data controller” (in other words, the organisation that determines how and for what purposes your personal data is used) will be August Equity LLP.

3. Personal data we may collect from you and how we collect it

Personal data you provide to us directly.

Ways in which you might provide the data to us

This is personal data about you that you give us, which can happen in a wide variety of ways, including by:

  • registering with us to provide you with services;
  • visiting and browsing our Site;
  • leaving a review on our Site;
  • completing our “contact us” form on our Site or otherwise enquiring about our services
  • engaging with us via email or over the phone (in some instances we will record phone calls with you);
  • subscribing to receive any of our publications or other marketing communications
  • mentioning or interacting with us on social media (for example by following/mentioning/tagging us or by contacting us directly);
  • attending one of our events;
  • providing us with feedback about the services we provide; or
  • entering into a contract with us and engaging with our services

It also includes personal data you provide if you complete one of our customer satisfaction surveys, provide us with feedback on our services, report a problem with our Site, enter into a contract with us or otherwise provide us with any personal data.

What type of data might be included?

The personal data you give us may include but is not limited to:

  • your name;
  • postal address;
  • e-mail address;
  • phone number (including mobile number);
  • date of birth;
  • gender (and preferred salutation);
  • social media handle and personal data on your social media account;
  • financial and credit card data; and
  • thoughts about our services (including complaints and reviews).

If you are a business contact, we will process your business contact details and your job role.

We will only ever ask you to give us personal data which we need in order to provide you with the services that you have requested from us.

Visiting our office

If you visit our office, we will process your personal data. This personal data may include: your name, postal address, and e-mail address and phone number (including mobile number).

We may also process your personal data in the form of video or audio recordings via CCTV. CCTV is in use in our office, for the safety of and prevention of any crimes committed against our staff, our equipment and our property, not for other monitoring purposes. In the event of any criminal investigations, we may be required by law, to share the data captured with the relevant authorities.

Personal data we collect or generate about you.

When you visit our Site or get in touch with us, we may collect, generate, store and use certain personal data about you. In some cases we will use cookies to do this, for further information about the cookies we use and how to opt out of such cookies please see our Cookie Policy in this document.

This personal data may include:

  • technical information, including: the Internet protocol (IP) address used to connect your computer to the Internet; your login information (if accessing an account with us); browser type and version; time zone setting; browser plug-in types and versions; device types; operating system; time and date of consent and platform; and any phone number used to call our customer service number.
  • information about your visit to our Site, including: the full Uniform Resource Locators (URL); clickstream to, through and from our Site (including date and time); page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse our Site.

Personal data we receive from other sources.

We may occasionally receive personal data about you from other sources, for example, a family member may provide us with your personal data in relation to the services that we are providing to them (for example, if you are named in a joint account etc.).

We always ask that if you are providing us with the personal data of someone else (for example another family member) that you notify them in advance that their personal data is being shared with us to allow us to provide services to you and you are responsible for directing them to this privacy policy.

We also engage with third parties to provide services under our branding, such as catering and retail operations. In such circumstances those third parties will share any personal data they have obtained with us, primarily for market analytics purposes.

4. Why and how do we use your personal data and what is our “lawful basis” for doing so?

Whenever we process your personal data as a data controller, we are required to identify and maintain a valid “lawful basis” (i.e. a legally compliant justification) for the processing. Typically, we will rely on the fact that our processing of your personal data is necessary:

  • to perform our contract with you;
  • to comply with our legal obligations; and/or
  • for our legitimate business interests, namely to analyse the use of our Site and our services to continually improve your experience and our business.

To help you to understand specifically what we do with your personal data and why we do it, we have described the various relevant lawful bases that we rely on in the table below.

Where we rely on our legitimate interests, we will always make sure that we assess these interests against your right to privacy before carrying out such processing and, if your rights outweigh our legitimate interests, we will not process your personal data for that purpose.

How and why we use your personal data What is our legal justification for processing your personal data
To verify your identity (i.e.to confirm that you are who you say you are). Due to the nature of our business we must process this data to fulfil our legal obligations.
To engage you as a client for the purposes of the relevant service which you instruct us for and to manage your account going forwards. We will have to process your personal data in these ways in order to perform our contractual obligation with you.

Where you provide us with details of a third party (such as a family member) you are responsible for ensuring that third party is aware that their personal data is being shared and for directing them to this privacy policy.
To provide you with advice and investment services that you request from us.
To process payments to and from you and to maintain accounts and records of such payments.
To carry out market research or similar surveys. Unless we are contacting you in a business to business capacity, we will only use your personal data to send you electronic marketing messages if we have consent from you to do so.

Where we send marketing to you in a professional capacity or otherwise carry out research or analyse our advertising, we will rely on our legitimate interests to send these types of communication (our legitimate interest in marketing and advertising our services) and conduct such activities.

You can opt out from marketing communications by using the unsubscribe links within our marketing messages, or by contacting us at any time at the contact details set out at below.
To provide you with further information about our other services and our upcoming events.
To measure or understand the effectiveness of any marketing that we serve to you.
To find out more about the visitors to our Site and our client base as a whole (rather than about you as an individual) to ensure that the services that we offer are most likely to interest our Site visitors. Typically the information collected is technical in nature and doesn’t tell us about you as an individual (see above).

We may use cookies to do this.

 We have a legitimate interest to make sure that we are providing you with the information that we think is most relevant to you.

We will not place cookies other than “strictly necessary” cookies on your device unless you have told us that you are happy for us to do so. For information on how we use cookies, please see our Cookie Policy in this document.
To notify you about changes to our services and terms and conditions. We have to process your personal data in these ways to perform our contractual obligations to you. We might also rely on our legitimate interests as a business to send you these updates.
To carry out our obligations arising from any contractual agreement with you and to provide you with the information or services you request. These may include managing your account with us, and the provision of services related to these purposes to us by our agreed third-party providers. We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data in relation to an order for products and services.

Alternatively, in some scenarios, we rely on our legitimate interests as a business (for example, it is in our interests to measure customer satisfaction and troubleshoot customer issues).
To measure how satisfied our Site visitors and our customers are and provide customer service (including troubleshooting in connection with the products you purchase from us or when you ask us questions by email, on the phone or on social media).
To prevent or detect crime, fraud or abuses of our products and services or our Site and to enable third parties to carry out related technical, logistical, research or other functions on our behalf related to these purposes. In some circumstances we will use your personal data because it’s necessary for us to comply with a legal obligation (for example, if we receive a legitimate request from a law enforcement agency).

In other cases (such as the detection of theft, fraud or ensuring security of our Site) we will rely on our legitimate interests in keeping our employees and our Site secure and to prevent theft and fraud.
To use the reviews, comments and feedback that you leave on our Site or provide to us for our own advertising purposes.

We may use a review, comment or piece of feedback that you submit in our advertising campaigns, such as in press and digital advertising, on our social media pages, in our email marketing or on our Site.

 We have a legitimate interest to promote our own products and services and to use the reviews, comments and feedback that you provide to us to do so.
For administrative or business purposes, where you contact us for a particular reason other than those set out above, such as to report problems with our Site. We have a legitimate interest to respond to your contact for the purposes of administering our business.

6. What if you fail to provide personal data?

If for any reason you failed to provide personal data which we require we may not be able to provide you with the services that you require from us.

7. Change of purpose

We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for a purpose other than that for which it was collected, we will prior to that further processing, provide you with information about the new purpose, we will explain our legal justification for doing so and we will provide you with any relevant further information. We may also issue a new privacy policy to you.

8. How we share your personal data

Third party suppliers and service providers involved in our contractual relationship with you.

Like most businesses, we work with third party suppliers and service providers as part of the day to day operations of our business. Some of these trusted suppliers will process your personal data on our behalf and provide services to us such as the provision web hosting, payment processing, marketing, and so on.

We will always make sure that these trusted suppliers meet agreed standards for the protection of your personal data and they will only ever be allowed to use your personal data in order to provide us with services and not for their own commercial purposes. We require all third parties to take appropriate technical and organisational security measures to protect your personal data and to treat it subject to a duty of confidentiality and in accordance with applicable data protection law.

Other scenarios in which we might share your personal data

We may also share your personal data:

  • with government authorities or professional bodies, such as HM Revenue & Customs in the United Kingdom (for tax purposes);
  • with our professional advisors including tax, legal or other corporate advisors who provide professional services to us;
  • with regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised law enforcement bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc.;
  • in the event of any insolvency situation (e.g. administration or liquidation);
  • if we, or substantially all of our assets, are acquired by a third party, in which case your personal data will be one of the transferred assets;
  • to protect the rights, property or safety of our employees, workers, contractors, clients, or others. This includes exchanging your personal data with other companies and organisations (including without limitation the local police or other local law enforcement agencies) for the purposes of our employee, worker, contractor and client safety, crime prevention, fraud protection and credit risk reduction; or
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

9. How do we protect your personal data?

We take the security of your personal data very seriously and have put in place physical, technical, operational and administrative strategies, controls and measures to help protect your personal data from unauthorised access, use or disclosure as required by law and in accordance with accepted good industry practice. We will always keep these under review to make sure that the measures we have implemented remain appropriate. You can obtain further information about these measures from our Data Protection Officer (using the contact details set out at part 17 of this privacy policy below).

In addition, we limit access to your personal data to those employees and other third parties who have a business need to know in order to perform their job duties and responsibilities. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

10. How long do we keep your personal data?

We will retain your personal data for as long as we need it in connection with our relationship with you. There may also be circumstances where we need to retain your personal data for longer than our relationship with you, for example:

  • where we have a statutory or regulatory obligation to retain the information (we are required to keep certain information for specified minimum periods, and in some cases indefinitely, depending on the services we provide); or
  • to ensure our business is properly run in an efficient and compliant manner.

Personal data which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal data where applicable.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you. In this case, we may retain such information for a longer period without further notice to you.

11. Your rights in relation to your personal data

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes so that our records can be updated. We cannot be held responsible for any errors in your personal data in this regard unless you have notified us of the relevant change.

Data protection law grants you a number of specific rights in respect of your data in addition to the broad and general right to have your data protected. We have set out some information in respect of each of those specific rights, below:

  • Right to be informed about how your personal data will be processed. This enables you to receive information about how we use your personal data. We have set this information out in this policy.
  • 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 information we hold about you corrected.
  • Request erasure of your personal data (commonly known as the “right to be forgotten”). 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 exercised your right to object to processing (see below).
  • 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.
  • 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.
  • Request the transfer of your personal data to another party.
  • Not to be subject to a decision solely based on automated processing. We do not anticipate making decisions about you based solely on automated decision making where that decision would have a significant impact on you. If we ever make a decision about you automatically by a computer or an algorithm without human intervention you can ask us to have that decision reviewed by a human.

If you want to exercise any of the rights set out above, please contact our Data Protection Officer (using the contact details set out at part 17 of this privacy policy below).

12. Where your personal data may be processed

In some cases, third parties that we engage may transfer personal data outside of the UK or EEA. Where personal data is transferred outside of the UK or EEA, we will ensure that the personal data is provided the required protection when doing so by ensuring adequate contractual safeguards for such transfer (e.g. the European Commission’s standard data protection clauses and UK IDTA Addendum), to ensure the security of your personal data is maintained when it is processed by the third party.

13. Cookies

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and allows us to improve our Site and our services.

We also place tracking cookies in our marketing emails as this helps us to improve our marketing activities — for example, these cookies allow us to see how many people open our emails, what time of day they open our emails and whether they click through on any of the information contained in the emails.

The cookies we use are “analytical cookies” sent by Google Analytics. They allow us to recognise and count the number of visitors and to recognise and track which parts of our Website you visit when you are using our Website. This helps us to improve the way our Website works, for example by making sure visitors are finding what they need easily.

We may also use the information collected from our use of cookies to estimate our audience size, analyse trends and general usage patterns of our Website, optimise our Website, and for other research and marketing purposes. This is statistical information and does not identify any individual.

An overview of Google Analytics is available at google.co.uk/intl/en/analytics/privacyoverview.html

You are not obliged to accept cookies. If you wish, you can set your browser to notify you before you receive a cookie so you have the chance to accept it and you can also set your browser to refuse to receive or send all cookies. The website www.allaboutcookies.org (run by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users.

Google Analytics also uses web beacons (also known as web bugs). A “web beacon” is a clear picture file which keeps track of your navigation through the website. Turning off the Website’s cookies as detailed above will prevent web beacons from tracking your specific activity. The web beacon may still record an anonymous visit from your IP address but unique information will not be recorded.

If you wish to opt out of being tracked by Google Analytics across all websites you can visit tools.google.com/dlpage/gaoptout and download the Google Analytics Opt-out Browser Add-on.

By using our Website without disabling cookies you are consenting to our use of cookies and web beacons as described in this policy.

More information on cookies and web beacons is available at the website allaboutcookies.org.

14. Third-party websites

Our Site may, from time to time, contain links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for the ways in which personal data is processed on such websites. Please check the relevant policies before you submit any personal data to these websites.

15. Changes to this privacy policy

We reserve the right to update or amend this privacy policy at any time, including where we intend to further process your personal data for a purpose other than that for which the personal data was collected or where we intend to process new types of personal data. We will place any updates here on this page. This privacy policy was last updated on 16 September 2024

16. Complaints

We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your personal data (our details are in the section immediately below). We will try to put things right.

However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to the Information Commissioner’s Office (“ICO”). You can contact the ICO at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF; 0303 123 1113; or ico.org.uk.

17. Contact

If you have any questions about this privacy policy or how we handle your personal data, please contact our Compliance Officer as follows: daniel.venn@augustequity.com.