WHO WE ARE

This privacy policy sets out how African Capital Investments Limited uses and protects any information that you give African Capital Investments (ACI) when you use its website or services.

ACI may change this policy from time to time by updating this page. You should check regularly to ensure that you are happy with any change.

Our registered office is at 49 Grosvenor Street, Mayfair, London, W1K 3HP and we are a company registered in England and Wales under company number 08775924.

We are registered on the Information Commissioner's Office Register; registration number CSN2427780, and act as the data controller when processing your data.

We are authorised and regulated by the Financial Conduct Authority; registration number 706522 and by the Financial Services Board: registration number 47979.

Our designated Data Protection Officer is Gareth Thomas, who can be contacted at 49 Grosvenor Street, Mayfair, London, W1K 3HP, tel: 020 7 399 3950, email: gareth.thomas@aci.africa.



INFORMATION THAT WE COLLECT

In summary, the personal information we collect may be used by us to pursue our legitimate business purposes.

We are an African focussed corporate advisory boutique and the majority of the personal information relates to individuals in their professional capacity which is provided to us in the course, and in connection with, our services. We may occasionally use external lead generation organisations to provide us with the contact details of people who may be interested in our services. Occasionally, we may come into possession of personal contact details, such as personal email address. In any event, we use such information only in connection with our normal business activities, i.e. providing our advisory services.

We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. The personal data that we collect from you may include

• contact information, such as your name, job title, postal address, including your home address, business address, telephone number, mobile phone number, and email address;
• information collected from publicly available resources, integrity data bases and credit agencies;
• personal information, as required by relevant laws or regulations, such as:
  
  • Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number);
  • Passport details, driving licence and utility bills;
  • Details of the services you request from us;
  • Any records held by financial crime prevention agencies, on the Electoral Register and by providers of utility services; and
  • Details of your employment status, income and source of wealth.
  • payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
  • other personal data regarding where it is relevant to advice or services that we provide.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect personal information about you in a number of circumstances, including when you apply to use any of our services, become our client, or contact us in person, by telephone, by email or by post.

In some circumstances, we collect personal data about you from a third party source. For example, we may collect personal data from your organisation, other organisations with whom you have dealings, government agencies, an information or service provider or from a publicly available record.

LAWFUL GROUNDS FOR PROCESSING OF PERSONAL DATA

Under the Data Protection Laws we need a lawful basis to collect and use your personal data. The law allows for six lawful bases to process people’s personal data, and one of them allows personal data to be legally collected and used if it is necessary for a legitimate interest of the organisation – as long as it is fair and balanced and does not unduly impact the rights of individuals.

Due to the nature of our business and the size of our database, it is not practical for us to ask every individual for his/her consent. We have assessed our interests in carrying out our business activities and we have carefully considered the impact the collection and use of personal data could potentially have on individuals’ rights. Our database contains mainly data about individuals solely in their business capacity, which is used for the purposes of our normal business activities. Such activities are unlikely to affect the fundamental rights and freedoms of individuals concerned. We have therefore concluded that the most appropriate lawful ground for the processing of your personal information is our legitimate interest in maintaining our business database, and promoting, running and managing our business.

SHARING AND DISCLOSING YOUR PERSONAL INFORMATION

All information you provide to us is stored on our secure servers located in the United Kingdom. The data we collect may be transferred to, and stored at, a destination outside the United Kingdom. It may also be processed by staff operating outside the United Kingdom who work for us or for one of our suppliers. We will take the necessary steps to ensure that your data is treated securely and that any such transfer outside the United Kingdom is in accordance with the Data Protection Laws.

Keeping personal information secure is very important to us and we take appropriate precautions to protect against the loss, misuse and alteration of personal information. However, no data transmission over the internet can be guaranteed to be totally secure. As a result, whilst we strive to protect your personal information, we cannot ensure or warrant the security of any information which is send via the internet.

We may disclose your personal information to any of our affiliated companies, to our suppliers, agents or representatives or to other users for the purposes associated with our legitimate interests (see above). We may also disclose your personal information to third parties where this is necessary in connection with the services we provide or our legitimate interests. If our services are provided in conjunction with, or by involvement of third parties, such third parties may need to have your personal information in order to fulfil your request.

We do not sell, trade or rent personal information to third parties.

HOW LONG WE KEEP YOUR DATA

We only ever retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

YOUR RIGHTS

you have the following rights:

• right of access to personal data that we process about you, which includes the right to obtain confirmation as to whether or not we process any of your personal data and if this is the case, you have the right to request a copy of your personal data, and the details of our processing of your personal data;
• to require us to correct any inaccuracies in your data;
• to object to our processing of your personal data (including for direct marketing purposes) or to withdraw your consent if you have previously given us your consent;
• in certain circumstances you may have the right to request erasure of your personal data (often referred to as the “right to be forgotten”), for example if we no longer have any legal ground for processing your personal data, e.g. we no longer need it for our legitimate interests (as set out above);
• instead of erasure, you can request restriction of processing of your personal data (i.e. limit the use of your data by us), for example when the accuracy of your data is being verified by us, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings; and
• you may request the transfer of any personal data you have provided to us to a different organisation.

If you wish to exercise any of the above rights, you should put your request in writing and email it to us at info@aci.africa and;

• include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill). This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and
• provide the details of the request that you are making, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.

LODGING A COMPLAINT

We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

CHANGES TO THIS POLICY

We may change this Policy from time to time. The current version of this Policy will always be available from us in hard copy or on our website. We will post a prominent notice on our website to notify you of any significant changes to this Policy or update you by other appropriate means.

This Policy was last updated on 29 August 2018.