General Data Protection Regulation – Privacy Notice

Under UK data protection law, we are required to write to inform you that Earth Capital Ltd collects and holds personal data about you in relation to you receiving information about the company, its affiliates and any of their products. This information may be collected from you directly or from other independent sources.

The types of information we collect on the Sites includes: a. business and personal contact information (such as name, postal and email addresses, and telephone number); and b. other information you submit to us (such as information provided by registering for email alerts or filling in forms). Earth Capital Ltd will hold and process this information solely for the purposes of providing information to you about the company, its affiliates and the products and services that it offers. Should you decide to invest in such a product, Earth Capital Ltd will process your data to effect this and you will receive appropriate information from the relevant contracting entity.

You may request to see the information we hold about you at any time. We may process this information and pass it to other parties in particular to Earth Capital Ltd's Advisors, insurers or our Affiliates, in order to consider your interest in our products and services and any legal or regulatory requirements related to this. In connection with such processing, personal data may be transferred outside the EEA. Should this occur, appropriate safeguards for such transfers pursuant to either Article 45 or Article 46 of the GDPR will be implemented.

You have the right to request from us, access to and rectification or erasure of personal data, or a restriction of processing, or to object to processing of data concerning you. For this, please contact us by email at info@earthcapital.net.

Information We Obtain By Automated Means

When you visit our Sites or open our emails, we may collect certain information by automated means (such as by cookies, web server logs, web beacons and JavaScript). The information we collect in this manner includes your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our Sites, and dates and times of website visits.

We use "cookies" to store and collect information regarding your usage of the site. Cookies are small pieces of information stored by the browser on your computer's hard drive. They send information stored on them back to our web server when you access our site. It helps us to know what you are viewing on our sites, and how you navigate around the sites, which ultimately helps us make improvements to the sites. If you would like to know more there are some external resources which explain more about cookies and why we have to be clear about how and when they are used. The Information Commissioner's Office is a good place to start: (links below click through) https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/ .

Our Sites may use cookies (such as HTTP, HTML5 and Flash cookies) as well as other types of local storage (such as browser-based or plugin-based local storage). Some of these cookies may be placed by third parties such as our service providers. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies you may not be able to use all of the features of our Sites or other websites and online services.

How We Use the Information We Obtain

We may use the information described above for the following purposes to:

  • operate, evaluate and improve our business (including developing new products and services; enhancing, improving and analysing our products and services; managing our communications; and performing accounting, auditing and other internal functions);
  • manage your investments;
  • comply with and enforce applicable legal requirements, relevant industry standards and our policies;
  • in some cases, in order to operate, administer and improve the user's experience of the Sites;
  • provide our products and services to you, such as market commentary and email alerts;
  • send you promotional materials, newsletters and other communications; and
  • respond to your inquiries.

We also may use the information in other ways for which we provide specific notice at the time of collection. We will only process your Personal Data as necessary so that we can pursue the purposes described above. Where we process your Personal Data for our legitimate interests as a business, we do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes. When we collect Personal Data from you, unless indicated otherwise, you should assume that, if we ask you for information, we need it for our business or compliance purposes. In limited circumstances, we are required to collect Personal Data to comply with a legal obligation and/or might ask you to provide information which is purely voluntary; in either case, this will be indicated to you. If you are a former employee, worker, contractor or member of Earth Capital Ltd, we will continue to process your Personal Data for a reasonable period following the end of your employment or engagement for our legitimate business and / or our legal compliance purposes and / or for the establishment or defence of a legal claim. Further, in some instances, we may process your data to perform our obligations under the contract between us (e.g. to pay you your final salary payment after your termination date). We only carry out such processing where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interests in pursuing those purposes. Your data will be retained and deleted in accordance with our retention policies and procedures.

Information We Disclose to Others

We do not disclose Personal Data we obtain about you through the Sites, except as described in this Online Privacy Notice. We may share your Personal Data with our affiliates and subsidiaries. We may also share Personal Data with service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We also may disclose information about you:

  • if we are required to do so by law or legal process;
  • to law enforcement authorities, regulators and/or other government entities and/or other competent authorities based on a lawful disclosure request;
  • when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer Personal Data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation); and
  • with third parties, such as service providers, in order to facilitate our business operations.
Retention and Deletion of your Information

We intend to keep your Personal Data accurate and up-to-date. We will delete the information that we hold about you when we no longer need it. We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.

Note that we may retain some limited information about you (even when we know that you have left the organisation that you represent) so that we can maintain a continuous relationship with you if and when we are in contact with you again.

How We Protect Personal Data

We maintain administrative, technical and physical safeguards designed to protect Personal Data we obtain through the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Marketing Data

We process name and contact details of individuals who have expressed interest in hearing from us about our services or have engaged with us for supply of our services in the past. We also process personal information received from third parties to whom you have provided consent for your information to be shared with us. We use third party providers to deliver our monthly e-newsletter and additional email marketing messages. We gather statistics around delivery, email opening and clicks using industry standard technologies, including clear gifs, to help us monitor and improve our marketing. All our marketing communications will be proportionate, relevant and designed with a clear focus on your privacy interests.

Links To Other Websites

Our Sites may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked websites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.

Updates To Our Online Privacy Notice

This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post the updated version on the Sites and indicate at the top of the Notice when it was most recently updated.

How To Contact Us

If you have any questions or comments about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please email us at info@earthcapital.net