Parabellum Investments (UK) Limited (“Parabellum Investments”) are obliged to inform the public using its website of their intentions with regards to the processing of personal data. This policy has been devised to comply with the requirements of the EU General Data Protection Regulation (“GDPR”) and in particular to the requirements stipulated in Article 15.
We do not collect information from visitors unless you contact us via email in which case we may collect the following categories of personal data: –
No special categories of personal data as defined in Article 9 of the GDPR.
In addition to the above, we anonymously collect information about your visit to our website. Please see our Cookies Policy for more details.
We process personal data collected via this website for the purposes of dealing with your enquiries and requests
We will disclose data when obliged to disclose personal data by law, or the disclosure is ‘necessary’ for purposes of national security, taxation and criminal investigation.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 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.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
You have the right to see what personal data we hold about you free of charge. To obtain a copy of the personal data we hold about you, please write to Alan Chan, General Counsel at Parabellum Investments, 8th Floor, 125 Old Broad Street, London, England, EC2N 1AR.
Please note that we reserve the right to refuse, or charge a reasonable fee (based on the administrative cost of providing the information), for requests that are deemed to be manifestly unfounded or excessive, in particular because of their repetitive character. We may also charge a reasonable fee to comply with requests for the same information.
Information will be provided within one month of receipt of the request, however, the period of response may be extended by up to two months in cases where requests are complex or numerous. If an extension is required, you will be notified within one month of receipt of the request along with an explanation. The data may be provided in electronic format where possible.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the transfer
You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: