Ondra Partners Privacy Notice
Purpose of this Privacy Notice
This privacy notice (the “Privacy Notice”) aims to give you information on how Ondra Partners collects and processes your personal data. Ondra Partners is a data controller in respect of your personal data. “Personal data” is any data that can be used to identify you or that Ondra Partners can link to you and which Ondra Partners has in its possession or control.
How to read this Privacy Notice
This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below. You can download a pdf version of the policy here: Ondra Partners Privacy Notice .
Who we are
You can find our contact details and the details of the data controllers within Ondra Partners, by contacting us on GDPR@ondra.com.
If you have any questions about this Privacy Notice, please contact us in the following ways:
Email address: GDPR@ondra.com
Postal address: 125 Old Broad Street, London, EC2N 1AR
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Data we collect about you
We will collect and process personal data that you or someone acting on your behalf provides to us by filing in forms, signing up for services on the website, and communicating with us face-to-face, by phone, email or otherwise.
If you are a client, or are connected with one of our client’s matters, we will collect and process personal data about you or others that is provided to us in connection with the provision of services to you or to that client.
We will also collect and process information about you, your transactions, financial information and relationship to others, including reports and information for tax reporting or compliance with legal or regulatory obligations, such as anti-money laundering regulations, insider lists and regulator information requests.
Where required by legal or regulatory obligations or otherwise where we have a specific legal basis, we will record telephone calls between you and Ondra Partners.
Data obtained from third parties
We might receive your personal data from third parties, such as your employer, counterparties to a transaction and regulators.
How we use your data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where we need to perform a contract we have entered into with you, it is necessary for our legitimate interest or we need to comply with a legal obligation.
We will process your personal data to:
- provide our services;
- verify your identity, including to prevent fraud;
- contact you in connection with the services we offer and manage our relationship;
- perform contracts with you;
- comply with our legal obligations, including reporting and anti-money laundering obligations;
- identify and prevent fraudulent and illegal activities; and
- assess your ability to meet your financial commitments
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
We may share your personal data with third parties where it is necessary for the purposes outlined above. Examples of third parties that we may share your data with are Ondra France, professional advisers or due diligence services, and other checking services. Where personal data is disclosed to third parties, we will take steps to ensure your personal data is accessed only by people who need to do so for the purposes described in this Privacy Notice.
We may disclose your personal information to third parties if we are required to do so to comply with a legal obligation.
Finally, in the event that we sell or buy any business or assets, we may disclose personal data to the prospective seller or buyer of such business or assets. If we are acquired by a third party, personal data will be one of the transferred assets. Your personal data would only be transferred to the extent that such a transfer was required for the purposes of due diligence and was subject to appropriate security protections, such as confidentiality restrictions or anonymization.
We may share your personal data with Ondra France, which will involve transferring your data to France.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We limited access to your personal data to employees and third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long we hold your personal data for will vary. The retention period will be determined by the purpose for which we are using it and our legal obligations.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for 7 years after they cease being clients.
In some circumstances you can ask us to delete your data: see “Your rights” below for further information.
You have legal rights in relation to the data we hold about you.
You can exercise your rights, make requests and raise questions by contacting us on GDPR@ondra.com.
Right to access
You have the right to obtain information about how we process your personal data and access the personal data which we hold about you.
Right to rectification
You have the right to request that we rectify your personal data if it is inaccurate or incomplete. We may need to verify the new information you provide to us.
Right to erasure
You have the right to ask us to erase your personal data where there is no good reason for us to continue processing it, you have objected to our processing it, or where we have unlawfully processed it. If we cannot comply with your request for erasure for specific legal reasons, we will notify you.
Object to processing
You may object to us processing your personal data. You must give specific legal reasons for your objection, and we are not obliged to comply with your request if we have a compelling reason to lawfully continue processing your personal data.
Right to withdraw consent
Where we are relying on your consent to process your personal data, you have the right to withdraw your consent.
Right to complain
You have the right to lodge a complaint with the ICO if you think we have infringed your rights.