Privacy and Cookie Policy

Argonaut Capital Partners LLP, (‘Argonaut’) is committed to protecting your personal data and your privacy. We endeavour to ensure that any personal data we collect about you will be held and processed strictly in accordance with the Data Protection Act 1998 (DPA) and, on and from 25 May 2018, the European General Data Protection Regulation (GDPR). The terms Personal Data, Data Controller and processing have the meanings given to them in the GDPR (which can be accessed here), unless otherwise indicated.

Article 5 of the GDPR states that Personal Data must be processed lawfully, fairly and in a transparent manner. This privacy policy is for this website; and governs the privacy of its users, who choose to use it. It explains how we comply with GDPR, the DPA and the Privacy and Electronic Communications Regulations (PECR).

Which policy is relevant to your situation?

At Argonaut, we collect and process Personal Data in a number of ways. For instance, please see the below:

You are browsing our website, enquiring about our services; receiving, reading or listening to our marketing communications, responding to one of our surveys or otherwise interacting with us as a prospective, current or former customer other than in connection with ongoing services we are providing to you or your organisation;
You are a client of Argonaut;
You are applying for or enquiring about a job at Argonaut
You are an employee or contractor of Argonaut
You are a supplier or service provider to Argonaut

Marketing Privacy Policy

1. Scope

This Privacy Policy demonstrates how Argonaut handles the Personal Data you provide to us, or which we collect about you, in the following ways (Your Data):

by you submitting information to us through our website www.argonautcapital.co.uk or when you subscribe to our newsletter, factsheets, quarterly investment calls and/or blog (Website User Data);
through your use of our other marketing resources, such as events or webinars which we run or sponsor (Marketing Data);
from what we learn about you from your visit to our website (Website Background Data); and/or
by you otherwise interacting with us a prospective, current or former customer, (for example, where you provide your business card to us) other than in connection with ongoing services we are providing to you or your organisation (Prospect Data).

This statement does not apply to:

the collection and processing of Personal Data in the course of providing investment or regulatory or other services to our clients. For information about privacy in the context of services provided to our clients, please contact the relevant person at Argonaut responsible for your matter.
the collection and processing of Personal Data about our employees or contractors. For information about privacy in the context of working for Argonaut please contact Argonaut Capital Partners LLP.
the collection and processing of Personal Data in relation to job candidates or applications for roles advertised on this website. For information about privacy in this context, please contact Argonaut Capital Partners LLP.
the collection and processing of Personal Data on our suppliers or service providers. For information about privacy in this context, please contact Argonaut Capital Partners LLP.

2. Identity and Contact Details of Data Controller

For the purposes of the DPA and the GDPR, Argonaut is the controller of Your Data. If you have any queries regarding this policy or complaints about our use of Your Data, please contact us at sales@argonautcapital.co.uk or at the address below and we will do our best to deal with your query as soon as possible.

Argonaut Capital Partners LLP
50 Sloane Avenue
London
SW3 3DD
FAO: Data Processing

3. What we use Your Data for

The table below sets out the purposes for which we may process Your Data and the legal basis for the processing:

Data	Purpose	Legal Basis
Website User Data Marketing Data Prospect Data	To keep you informed of any activities undertaken by us which we believe may be of interest to you and this use may include sending you emails and postal marketing from time to time or requests to respond to a survey	Legitimate interest of Argonaut Capital. We send your emails with regards to our activities. Before doing so we would ensure that we have weighed your interests and risk posed to you against our own and that such interests are proportionate and appropriate such as for the purposes of marketing.
Website User Data Website Background Data	Website analytic purposes. For further details on the technology we use in order to analyse our website’s performance, please see our cookies policy below	Consent – this will be obtained when you accept the disclaimer when you enter our website to accept certain cookies. Legitimate interest of Argonaut (see our cookies policy for further information)
Website User Data Marketing Data Prospect Data	To provide you with the newsletter(s) or information you have requested	Performance of a contract
Website User Data Marketing Data Prospect Data Website Background Data Prospect Data Survey Data	To respond to requests for information from regulated bodies or government agencies	Compliance with a legal obligation
Website User Data Prospect Data	To respond to an enquiry you have submitted	Legitimate interest of Argonaut Capital – it may be necessary for us to process Your Data in order to reply or respond to your enquiry

4. Who we share Your Data with

Please note that we may on occasion be required to share your information with the following categories of recipients:

Third parties who provide services on our behalf. For example, we use third parties such as Campaign Monitor to provide marketing automation services, WildWest who host our website and BrightTalk for quarterly investment calls. A full list of all our third-party service providers is available on request.
Your information may be sent to, and we may use information from, credit reference agencies and fraud prevention agencies. We may need to send your information to external parties if we are legally required or are permitted by law or regulation to do so. This could be as a result of, for example, a contractual obligation, a court order, a regulatory requirement (e.g. Financial Conduct Authority) or a request from another body or organisation such as the police, the Department of Work and Pensions or Her Majesty’s Revenue and Customs.
We use external outsourcers for a variety of purposes, e.g. to carry out administration on our behalf or to provide support services. As a result your information may need to be passed to them. This will change from time to time but currently includes by way of example administration services, document storage or retention and providers of IT services. In each case a contract will be put in place with these outsourcers or service providers with obligations about the use and security of your information.
In certain circumstances we may transfer your personal information overseas to countries that may not provide the same level of data protection as the UK. This is most likely to happen in the case of administration outsourcing. If we do this, appropriate steps will be taken to ensure that your information is protected.

We have taken steps to ensure that all such entities keep Your Data confidential and secure and only use it for the purposes that we have specified and have informed you of. Our service providers are subject to data processing agreements which are, or are in the process of being updated to become, compliant with the requirements set out in the GDPR. Further details regarding any third parties who are located outside the EEA are set out in paragraph 5 below.

In relation to any other third parties, we will only disclose your information in the following circumstances:

where you have given your consent;
where we are required to do so by law or enforceable request by a regulatory body;
where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights; and
if we sell our company, go out of business, or merge with another company.

5. International Transfers

In certain circumstances, we may transfer Your Data to countries outside the EEA, which may not adhere to the same levels of data protection to which countries within the EEA are subject. Any such transfers are, at all times, made in accordance with the DPA and the GDPR. Details of the circumstances and mechanisms in place to ensure compliance are set out below:

Campaign Monitor: We use Campaign Monitor as our third-party mailing system. Campaign Monitor is a global organization based in 20 cities including Sydney, San Francisco and London. All data is stored on servers located in San Jose (USA). Any such transfer outside the EEA is made in accordance with the Standard Contractual Clauses approved by the European Commission. For more information on the security and privacy measures implemented by Campaign Monitor please see this link. For more information on Campaign Monitor’s privacy policies please follow this link.

Google Analytics: We use Google Analytics to obtain information on website statistics. Google, (including Google LLC and its wholly-owned US subsidiaries) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Google Analytics terms prohibits the collection of any personally identifiable information. Analytics data is transmitted over HTTPS. Reports are only available to authorised Google accounts. Transfers of Personal Data to Google in the United are therefore made subject to appropriate safeguards in accordance with the DPA and the GDPR. Google’s privacy policy can be viewed here.

6. Retention Period

Your Data will be stored for a maximum period of 6 years, after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained. If you consent to marketing, any information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information. unless we request your consent to store it for a longer period.

7. Your Rights in relation to Your Data

Under the GDPR, you will have the following rights in relation to how we process Your Data:

Right to request access – you may obtain confirmation from us as to whether or not Your Data is being processed and, where that is the case, access to Your Data.
Right to rectification and erasure – you have the right to obtain rectification of inaccurate personal data we hold concerning you and to obtain the erasure of Your Data without undue delay in certain circumstances.
Right to restriction of processing or to object to processing – you may require us to restrict the processing we carry out on Your Data in certain circumstances or to object to us processing Your Data.
Right to data portability – you have the right to receive Your Data in a structured, commonly used and machine-readable format.
Right to withdraw consent – where you have provided your consent to us processing Your Data, you have the right to withdraw your consent at any time. This can be done by emailing sales@argonautcapital.co.uk at any time or by clicking the “unsubscribe” link on any marketing communications you receive from us.
Right to lodge a complaint – you may lodge a complaint with any supervisory authority in the EU. The supervisory authority for the United Kingdom is the Information Commissioner’s Office.

For further information on your rights, please see the Information Commissioner’s website here.

8. Additional Information

There is no statutory or contractual requirement for you to provide Your Data to us and you are not obliged to do so. Please note, however, that we may not be able to provide you with the services you have requested, such as to receive information on our funds, if you do not provide your contact details. As set out in our cookies policy, our website may not be able to function fully if you do not agree to certain cookies being set on your computer.
We do not undertake automated decision-making or profiling on Your Data.
We keep our privacy policy under constant review and may change it from time to time to reflect our practices or to remain compliant with relevant legislation. We will notify you of any material changes to our privacy policy via a notification on our website. Your continued use of this website or our other marketing services, following the posting of changes to these terms, will mean you accept these changes.

9. Security of personal information

We recognise the need to ensure that personal information gathered via this website remains secure. Our site has security measures in place to protect against the loss, misuse and alteration of the personal information under our control. Our security measures include the use of a hardware firewall to prevent unauthorised access. You should acknowledge that although we exercise adequate care and security there remains a risk that information transmitted over the Internet and stored by computer may be intercepted or accessed by an unauthorised third party.

10. Data obtained indirectly

In some circumstances, we may obtain Personal Data about you from other sources. This information may include your name, contact details and job title, which we obtain from third party sources such as Preqin, organisers of events we sponsor or other publicly available sources, such as your company’s website.

11. Links

Our website may contain links to other websites belonging to third parties. We do not control the privacy practices of these other websites. You should therefore make sure when you leave our website that you have read that website’s privacy policy.

12. Changes to this Privacy Policy

We keep our privacy policy under review and may change it from time to time. This policy was last reviewed on 18 May 2018.

13. Queries or Complaints

If you have any queries about the personal information we hold or about this Privacy Policy please write to:

The Data Protection Officer
Argonaut Capital Partners LLP
50 Sloane Avenue
London
SW3 3DD
Email: sales@argonautcapital.co.uk

The Information Commissioner’s Office is the UK’s independent authority setup to promote access to official information and protect personal information. They provide lots of helpful advice and guidance. They can be contacted at www.ico.org.uk

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Cookie policy

Argonaut’s website uses cookies, to help provide you with a good experience when you browse our website and it also allows us to improve our site.

A cookie is a small file of letters and numbers downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognise a user’s device. A cookie can be used for authenticating, remembering specific information about users, such as site preferences.

The use of cookies on the Argonaut website is limited and currently only used to prevent our disclaimer page from reappearing when return to the site.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you.

We do not use cookies for:

Collect any personally identifiable information (without your express permission).
Collect any sensitive information (without your express permission).
Pass personally identifiable data to third parties.

Our cookies

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

We use Google Analytics, a web analytics serviced provided by Google. Google uses ‘cookies’ to help analyse how visitors use the websites.

Cookie	Purpose	More Information
_ga	Used to distinguish users.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gtagjs_google_analytics_4_-_cookie_usage
_gid	Used to distinguish users.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gtagjs_and_analyticsjs_universal_analytics_-_cookie_usage
_gat_gtag_UA_33197370_1	Used to throttle request rate for www.argonautcapital.co.uk.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gtagjs_and_analyticsjs_universal_analytics_-_cookie_usage
_ga_3S2WHN646C	Used to persist session state for www.argonautcapital.co.uk.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gtagjs_google_analytics_4_-_cookie_usage
_gat_gtag_UA_33197370_2	Used to throttle request rate for blog.argonautcapital.co.uk.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gtagjs_and_analyticsjs_universal_analytics_-_cookie_usage
_ga_Y35ZWZMB2M	Used to persist session state for blog.argonautcapital.co.uk.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gtagjs_google_analytics_4_-_cookie_usage
AMP_TOKEN	Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gtagjs_and_analyticsjs_universal_analytics_-_cookie_usage
argonaut_disclaimer	Once you have accepted the website’s terms and conditions the information will be saved to the cookie.
Argonaut TV	Videos embedded onto the Argonaut TV section of the website will set various cookies. These are controlled by the various publication sources such as Asset TV, Kulu Valley, Vimeo, CNBC, and any others which may be added in future.
BrightTalk	BrightTalk host the Conference Calls section of the website. Please see their cookie policy at the referenced url for a list of cookies they use.	https://business.brighttalk.com/company/cookie-policy/

Giving us permission to use cookies

If the settings on the software that you are using to view our website (your browser) are adjusted to accept cookies, we take this, and your continued use of the site, to mean that you are happy with this. Should you wish to remove, or not use, cookies from our site you can learn how to do this below (“Turning cookies off”). However, doing so will likely mean that our site will not work as you would expect.

Turning cookies off

If you wish to restrict or block cookies you can do this by altering your web browser settings to control or delete cookies. We suggest that you visit: www.allaboutcookies.org which explains how you can do this.

You should be aware that by restricting cookies this may affect the functionality of certain features of our site.