Group 2

Privacy Policy

1. Who we are

  1. We are Blue Current Capital Limited (referred to as “Blue Current Capital”, “BCC”, “we”, “us” and “our” in this Privacy Notice), a company incorporated in England and Wales with company registration number 12592858 and whose registered office address is Belvedere, 12 Booth Street, Manchester, M2 4AW. BCC is a wholly owned subsidiary of Arrow Global Limited (referred to as “the Group” and “AGG” in this Privacy Notice).
  2. This Privacy Notice applies to all products and services offered by us through any websites, web applications, mobile applications or similar devices, channels, platforms, service applications or other applications operated by or on behalf of us or which reference these terms and conditions and also applies to any data transferred to us from any third-party financial investment or advisory entity (“Services”). This Privacy Notice applies to you if you are a past, prospective or current client or an intermediary or client of an intermediary of BCC.
  3. We are the data controller in relation to the processing of the personal information that we hold. Our contact details are as follows:
    1. Address: 11 Golden Square, London, W1F 9JB, United Kingdom.
    2. Telephone number: +44 (0) 75 7238 3316
    3. Email address: privacy@bluecurrent.capital (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).

2. How we collect your information

  1. How you engage with us
    1. The information we hold about you comes from the way you or your business engage with us, for example by doing any of the following:
      1. providing us, or one of our partners, with information in the course of registering for and/or using our Services;
      2. from third parties, for example whilst carrying out regulatory, financial and identity checks (including any such checks on the officers and beneficiaries of our clients) during your account creation process and from intermediaries when entering into or administering your agreement with us;
      3. interacting with any of our marketing material;
      4. from cookies collected from your use of our website;
      5. in so far as you are an individual, interacting with us using social media; and/or
      6. contacting us offline, for example by telephone, SMS, email or by post.
    2. We may also obtain information about you from credit reference agencies and fraud prevention agencies.
  2. What information do we collect?
    1. The information we collect when you engage with us for any of the purposes described above may include, for example:
      1. basic personal details such as your name, date of birth or age, address, email address, telephone number, gender and marital status;
      2. your national insurance number and any tax identification number;
      3. the Internet Protocol (IP) address attached to your device;
      4. your login information, browser type and version, time zone setting, browser plug in types and versions, operating system and certain device information
      5. financial information, bank account and payment details, employment history, nationality and dependents;
      6. details about authorised signatories, agents, or representatives of our clients and copies of any associated legal documents;
      7. your marketing preferences.

3. What we use your information for

  1. We may use your information for the following purposes:
    1. Pursuing the legitimate interests of the business
      1. Including:
        1. to communicate with our clients and other parties with whom we do business;
        2. to monitor and the performance and operation of our Services;
        3. outsourcing some or all of our back office functions to third parties or other members of the Group;
        4. for marketing and promotional purposes (for more information see below at paragraph 9);
        5. to create new products and services or improve our existing Services;
        6. keep you informed of other services which might be of interest to you and to notify you about important updates or changes to our Services.
    2. It is necessary for the performance of our contract with you
      1. In so far as any contracting party is an individual (or if the contract counterparty is a business, if any data regarding data subjects is passed to us as a result of our contractual obligations), for the purposes as set out in our specific contract with you, including contracts relating to our investment and financial advisory Services, our seed investment Services, or any other contract which a BCC company may enter into.
    3. It is necessary for our compliance with our legal obligations
      1. For the purposes of carrying out necessary checks on the identity, source of funds, or other necessary checks relating to our clients or suppliers, including anti-money laundering checks, or any other regulatory requirements as specified by the Financial Conduct Authority or any other applicable authority.
      2. To comply with our record keeping and tax obligations under any applicable law.
  2. We do not use your personal information in automated decision-making.

4. Our legal grounds for processing your information

  1. Except in circumstances where we require your express prior consent (see below), by proceeding to use our Services or otherwise interact with us as set out in paragraph 2, you give us your permission to process your personal information for the purposes set out in this Privacy Notice and we accordingly will be processing your personal information on the basis that it is necessary for us to do so for the performance of a contract, to pursue our legitimate business interests, or to comply with our legal obligations.
  2. In certain circumstances (and in accordance with data protection legislation), we will only collect and process your personal information if you have provided consent for us to do so. For example:
    1. sensitive or special personal information – in providing services to you as detailed above, we may need to collect information which data protection legislation defines as “sensitive or special personal information” (such as medical history or criminal convictions). At the time you provide this information, we will always request your express consent to process this information for the purposes stated in this Privacy Notice; and
    2. market analysis and emails – we will only send recommendations about products and marketing emails to you if we have your consent to do so.
  3. In particular, where we intend to further process your information for a purpose other than that for which it was collected, we shall provide you prior to that further processing with information on the other purpose and with any relevant further information.

5. Sharing your information

  1. How we use and share information within the Group
    1. We may share and aggregate information about you with any company within the Group for the purposes set out in this Privacy Notice only (e.g. for the provision of our Services or a back-end part of such Services by a Group member).
  2. How we use and share information outside the Group
    1. If you purchase a product or service, your personal information may be shared with and processed by:
      1. our associated companies and partners for the purposes of providing our Services to you as requested by you, and to facilitate products and services offerings to you;
      2. to providers of investments or services we work alongside with;
      3. regulators (such as the Financial Conduct Authority) or other third parties, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
      4. to any relevant tax authority who may request certain information about you;
      5. financial institutions with whom you hold an account;
      6. any investment vehicle who is acting as an intermediary between you and us;
      7. credit reference and fraud prevention agencies;
      8. any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
      9. our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
      10. our service providers and agents (including their subcontractors) or third parties which process information on our behalf (e.g. IT, internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested or which we believe may be of interest to you;
      11. third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);
      12. third parties for marketing purposes (with your consent), e.g. our partners and other third parties with whom we work and whose products or services we think will interest you; and
      13. another organisation to whom we may transfer our agreement with you or if we sell or buy (or negotiate to sell or buy) our business or any of our assets;
    2. We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.

6. International Transfers

  1. It may be necessary in certain cases for us to transfer your personal information outside the UK or the European Economic Area (EEA). However, we will only do so:
    1. where necessary for the performance of a contract with you, or where necessary for the conclusion or performance of a contract between us and a third party which is in your interest; or
    2. provided that one of the appropriate safeguards and protections are in place, such as:
      1. entering into a contract with a third party containing the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA, and which offers you protection equal to or greater than the protection offered by this privacy notice;
      2. the country to which the data is being transferred has been deemed to provide an adequate level of protection for personal data by the European Commission;
      3. where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
  2. Where a transfer takes place in accordance with paragraph 6.1 of this Privacy Notice, we will inform you that the transfer has taken place, and the reasons for making the transfer.

7. How long will we keep your information for?

  1. Unless we are required or permitted by law to hold on to your data for a specific retention period (for example, by rules imposed by the Financial Conduct Authority) or where we retain data pursuant to our policy with you or for our legitimate business purposes, we will only hold your personal information on our systems for as long as is necessary to fulfil the purposes outlined in Schedule 1 of this Privacy Notice.
  2. Where we no longer need your personal information, we will dispose of it in a secure manner.

8. Security

  1. We keep your information protected by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:
    1. where appropriate, data is encrypted when transiting on our system or stored on our databases;
    2. where appropriate, our Services use HTTPS to help keep information about you secure;
    3. we have implemented safeguards in relation to access and confidentiality in order to protect the information held within our systems; and
    4. we frequently carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems to prevent fraud.
  2. However, while we will do our best to protect your personal information, we cannot guarantee the security of your information which is transmitted to any Application via an internet or similar connection.

9. Marketing

  1. From time to time, we may use your information to contact you with details about our applications, products and services which we feel may be of interest to you.
  2. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on any applications to us in respect of the Services, or by sending an email to us at info@bluecurrent.capital.
  3. You can also unsubscribe from any electronic marketing communications at any time using the links provided in the emails we send to you.

10. Your rights to your personal data

  1. You have certain rights under existing data protection laws, including the right to (upon written request) access a copy of your personal data that we are processing. If you are based within the UK or the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you will also have the following rights:
    1. right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs);
    2. right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete;
    3. right to erasure/“right to be forgotten”: the right to withdraw your consent to our processing of the data (if the processing is based on your consent) and the right to request that we delete or erase your personal information from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
    4. right to restriction of use of your information: the right to stop us from using your personal information or limit the way in which we can use it;
    5. right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and
    6. right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or for marketing purposes.
  2. Please note that if you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our Services.
  3. If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: www.ico.org.uk

11. Changes to this Privacy Notice

  1. We may amend this Privacy Notice from time to time for example, to keep it up to date, to implement minor technical adjustments and improvements or to comply with legal requirements. We will always update this Privacy Notice on our website, so please try to read it when you visit the website (the “last updated” reference tells you when we last updated our Privacy Notice).
    1. right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs);
    2. right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete;
    3. right to erasure/“right to be forgotten”: the right to withdraw your consent to our processing of the data (if the processing is based on your consent) and the right to request that we delete or erase your personal information from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
    4. right to restriction of use of your information: the right to stop us from using your personal information or limit the way in which we can use it;
    5. right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and
    6. right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or for marketing purposes.

12. KYC information

  1. All personal data relating to KYC, anti-money laundering or other required regulatory information will be held for a period of 7 years following the completion of the contract or completed performance of the Services. If we are required by any applicable law or regulation to retain such information for a longer period, when we will retain such information only for as long as required by the applicable law or regulation.

13. Marketing

  1. Contact information relating to clients and contacts will be held for so long as we believe the information to remain accurate and the individual concerned remains a genuine connection of BCC, or of one of our partners and staff.

Any marketing information will be otherwise deleted 24 months following the last contact with a client or contact.