Group 2

Privacy Notice

Who we are

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.

This Privacy Notice applies to all products and services offered by us and also applies to any data transferred to us from any third-party 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.

We are the data controller in relation to the processing of the personal information that we hold. Our contact details are as follows:

Address: 11 Golden Square, London, W1F 9JB, United Kingdom.

Email address: privacy@bluecurrent.capital (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).

How we collect your information

How you engage with us

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:

  • providing us, or one of our partners, with information in the course of registering for and/or using our Services;
  • from cookies collected from your use of our website;
  • in so far as you are an individual, interacting with us using social media; and/or contacting us offline, for example by telephone, SMS, email or by post.

What information do we collect?

The information we collect when you engage with us for any of the purposes described above may include, for example:

  • basic personal details such as your name, address, email address and telephone number;
  • the Internet Protocol (IP) address attached to your device;
  • .

What we use your information for

We may use your information for the following purposes:

Pursuing the legitimate interests of the business.  Including:

  • to communicate with our clients and other parties with whom we do business;
  • to monitor the performance and operation of our Services;
  • outsourcing some or all of our back-office functions to third parties;
  • to create new products and services or improve our existing Services;
  • to notify you about important updates or changes to our Services.

It is necessary for the performance of our contract with you.

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 or any other contract which a BCC company may enter into.

We do not use your personal information in automated decision-making.

Our legal grounds for processing your information

Except in circumstances where we require your express prior consent (see below), by proceeding to use our Services or otherwise interact with us, 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, or to pursue our legitimate business interests.

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.

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.

Sharing your information

How we use and share information

We may share and aggregate information about you for the purposes set out in this Privacy Notice only (e.g. for the provision of our Services or a back-end support).

Your personal information may be shared with and processed by:

  • 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;
  • to providers of investments or services we work alongside with;
  • regulators or other third parties, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
  • any investment vehicle who is acting as an intermediary between you and us;
  • 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);
  • our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
  • 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;
  • 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);
  • 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;

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.

Cookies

For information on how we use cookies, please see our Cookie Policy

International Transfers

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 provided that one of the appropriate safeguards and protections are in place, such as:

  • 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;
  • 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;
  • 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.

How long will we keep your information for?

Unless we are required or permitted by law to hold on to your data for a specific retention period 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 this Privacy Notice.

Where we no longer need your personal information, we will dispose of it in a secure manner.

Security

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:

  • where appropriate, data is encrypted when transiting on our system or stored on our databases;
  • we have implemented safeguards in relation to access and confidentiality in order to protect the information held within our systems; and
  • we frequently carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems to prevent fraud.

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.

Your rights to your personal data

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:

  • right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding
  • right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete;
  • right to erasure/“right to be forgotten”: the right to request that we delete or erase your personal information from our systems
  • right to restriction: the right to stop us from using your personal information or limit the way in which we can use it;
  • 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
  • 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.

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

Marketing

We do not use personal data for any direct marketing purposes.

Changes to this Privacy Notice

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.

This Privacy Notice was last updated: 28th June 2024