Last updated April 12, 2023
Eos Advisory LLP (“Company“, “we“, “us“, “our“) is a limited liability partnership incorporated in Scotland (company number SO306577) with its registered office at Kinburn Castle, Doubledykes Road, St Andrews, KY16 9DR. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at email@example.com.
When you visit our website eos-advisory.com (the “Website“), and more generally, use any of our services (the “Services“, which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which includes any related services, sales, marketing or events).
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
1. WHAT INFORMATION DO WE COLLECT?
Information collected in the provision of our services
In Short: We collect information about you from the forms that you complete, when you contact us, and from the services that we provide to you.
In the normal course of providing our services to you we expect to collect your personal details and contact information, your bank details (in order to receive or make payments to you), identity documents and tax details, information about your finances and professional experience, the events you attend and the investments that you make.
Information third parties give to us
In Short: We may have arrangements with third parties who collect or process data about you.
We may get information about you from third parties engaged in the provision of services to, or for, you. This might include fund administrators, custodians of client assets, solicitors involved in transactions, and identity checking services for anti-money laundering purposes.
We may also receive information our through other third parties such as advertising networks, search engine providers, analytics providers, and social networking sites.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information to fulfil our contract with you, to comply with our legal obligations, with your consent, and for purposes based on legitimate business interests.
We use personal information for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.
We use the information we collect or receive:
- To allow us to perform our contract. We use your personal information to provide you with the services you request from us, to arrange investments, and to manage the Eos syndicate and our investment funds.
- To provide you with support. We will use some of your personal data to track the services you use, to provide you with customer support and handle complaints.
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To comply with our legal obligations. We are required to maintain proper records about the services we provide to you.
- To prevent money laundering. We may carry out analysis and research using your personal data to detect and prevent money laundering, fraud, or other financial crime.
- To respond to legal requests or proceedings.We use personal information in order to comply with applicable law, governmental requests, judicial proceedings, court orders, or other legal process.
- For marketing purposes. We will use your information to keep you informed (subject to your expressed preferences) by email or other electronic means such as via social and digital media about current and new products, services, offers and promotions which may be of interest to you. We may use a third-party software and storage solution to analyse the personal data that you have provided to us in order to ensure that the marketing that you receive is as relevant and beneficial to you as possible. We retain full ownership of your personal data and ensure that it is secure at all times. If you are not happy for your personal data to be used in this way, you can manage your preferences through your account or unsubscribe at any time to remove your details from our contact list.
- For other business purposes.We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations.
More specifically, we may need to process your data or share your personal information in the following situations:
- Identity checks. We use an electronic identity verification service for the purposes of preventing money laundering. We may do this ourselves or through an agent acting on our behalf.
- Safe custody. Where we appoint a custodian to hold client assets for you, we will share data about you with the custodian. The custodian may share data with a nominee or a sub-custodian.
- Investee companies. We will provide personal details to investee companies as necessary to enable you to acquire, hold, and dispose of investments, and (where appropriate) to claim available tax reliefs.
- We will provide investee companies with your details for submission to HMRC in connection with claims for available tax reliefs.
- Solicitors, auditors, and other professional advisors. We will provide your details to solicitors, auditors and other professional advisors but they will always be subject to professional and/or contractual obligations of confidentiality.
- Our regulators. We may be asked to provide personal data to the Financial Conduct Authority or the Financial Ombudsman Service as part of our regulatory obligations.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Our partners may use the personal data you provide for purposes such as fraud prevention or for internal analysis (such as monitoring customer demographics, market trends or pricing analysis). In certain circumstances we are obliged to report information to law enforcement agencies.
We are not responsible for the privacy policies or practices of our partners (or other websites you may click though to from our website). You should ensure you read and are fully aware of the terms and conditions and the privacy policies of third-party websites.
We may also transfer your personal data to generic service providers who control or process personal data on our behalf to enable the efficient technical and logistical provision of our services. These service providers supply us with cloud data storage, data security services, customer relationship management software, and support ticketing services. We may substitute a technical or logistical service provider from time to time.
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in the UK. If you are accessing our Website from outside the UK, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE? above), in and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
6. DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
Under the terms of the data protection legislation, you have a number of rights. You may:
- ask of a copy of the information, or some of the information, that we hold about you (rights of access and portability);
- ask us to correct or remove any information about you that we hold (rights to rectification and erasure);
- ask us to stop processing or restrict the processing of information that we hold about you (rights to restrict and object to processing, including profiling).
You can ask us to do any of these things through our website and we will do this free of charge. We will respond to your request within 30 days.
If you believe we are unlawfully processing your personal information, you also have the right to complain to the Information Commissioner’s Office.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website http://www.aboutads.info/choices/. For further information, please see our Cookie Notice: https://eos-advisory.com/cookies.
9. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at firstname.lastname@example.org