Neptune Group is responsible for your personal information and remains committed to protecting your privacy. With effect from 25 May 2018, Neptune Group is, as data controller of your personal information, subject to the European Union General Data Protection Regulation 2016/679 (the "GDPR") and any locally applicable data protection laws. In this Privacy Notice, "we", "us" and "our" mean all Neptune Group entities that you have instructed or that are providing services or communication to you.
As a result of GDPR, we are introducing this Privacy Notice which makes it easier for you to find out how we collect, use, protect and disclose your personal information and which rights and options you have in relation to the personal information we hold.
This Privacy Notice will provide you with additional details such as:
The personal information we may collect include:
We collect personal information about you in various ways, including:
We will only collect information in line with relevant regulations and laws and this may relate to services you apply for, currently hold or have held in the past. You provide us with your personal information entirely voluntarily. However, there may be statutory or (pre-) contractual conditions under which Neptune Group will not be able to take action or process your instructions without you providing the relevant personal information to us.
We will only use your personal information as allowed by law e.g. carrying out an instruction or agreement, fulfilling a legal obligation, because we or third party recipient have a legitimate interest or as agreed by you. In particular, we have, inter alia, a legitimate business interest to use your personal information:
We may share your personal information with:
If you provide personal information about someone else such as a director, employee or someone with whom you have business dealing, you must ensure that you are authorised to disclose that information without us taking further steps we will collect, use and share the information as set out in this Privacy Notice. In particular, you must ensure the affected individual is aware of this Privacy Notice and its contents including our contact details.
We will keep your information for as long as you have a relationship with us. After it ends we will keep your information for up to 10 years or as long as we may have a legitimate purpose or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing your data. In particular, we will retain your personal data
Your information may be transferred and stored as set out in this Privacy Notice to countries outside the European Economic Area or to countries not approved by the European Union as providing an adequate level of protection for personal information. This may include countries which do not provide the same level of protection for personal information. When this happens, we will ensure any such transfers are made subject to appropriate or suitable safeguards. Such transfers will occur where you have given explicit consent; where the recipient has entered into European Union Standard Contractual Clauses or where the recipient is based in the United Stated of America and has registered under the EU/US Privacy Shield.
You have a number of rights relating to your information including:
We may request that you provide prove of your identity in order for us comply with our security obligations and to prevent unauthorised disclosure of data. We reserve the right to charge a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data. Please note these rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
We will consider any requests or complaints and provide you with a response within 4 weeks. If you are not satisfied with our response you may lodge a complaint with the relevant data protection regulator. We will provide you with details of the relevant regulator upon request.
We reserve the right to update and change this Privacy Notice from time to time in order to reflect regulatory changes or changes to the way we process your personal information. In case of any such changes, we post the amended Privacy Notice on our website. The changes will come into effect upon publication.
For more details, queries or comments about anything covered in this Privacy Notice, please contact us by:
Post: Neptune Group 14 Holywell Row, London EC2A 4JB
Tel: 020 7655 0888
In order to comply with regulatory obligations, we will add this Privacy Notice to our current terms and conditions. We are not changing our terms of engagement and any other agreements already in place between us shall continue in full force. Please refer to our terns and conditions if you wish to learn more about our client confidentiality obligations. In the event of conflict or discrepancy between this Privacy Notice and our terms and conditions, this Notice shall prevail. If you do not notify us of your disagreement with any of the terms of this Privacy Notice, you will be deemed to have accepted it.