Privacy Policy

Grafton Advisors, together with its subsidiaries and affiliates (“Grafton”), respect your concerns about privacy and is committed to protecting your personal data. This Online Privacy Notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Online Privacy Notice aims to give you information on how Grafton collects and processes your personal data through your use of this website, including any data you may provide through this website when you contact us. It is important that you read this Online Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Online Privacy Notice supplements the other notices and is not intended to override them.

PERSONAL INFORMATION WE COLLECT ABOUT YOU  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you: 

  • Personal and business contact information including name, postal and email address, and telephone number; and
  • Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?  

We use different methods to collect data from and about you including through: 

  • Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone, email or otherwise.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other website employing our cookies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties

HOW WE USE YOUR PERSONAL INFORMATION 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

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. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookies help provide functionality to the website and help analyze website usage more accurately. Technical information collected through the website is used to analyze and report on website traffic, usage trends, for security purposes, and to improve Grafton’s online content and services. Grafton may use third party analytics tools to analyze website traffic and improve the site, based on information collected by cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

DISCLOSURES OF YOUR PERSONAL INFORMATION  

Generally, Grafton does not disclose personal information collected via our website to third parties for commercial purposes. Information collected through the website may be accessible to and stored by Grafton service providers, for example, service providers who design, maintain or host the website. In some cases, Grafton may disclose personal information provided through the website to other Grafton affiliates, service providers or partners in order to best respond to an inquiry or provide a service.

In certain circumstances, Grafton may be permitted or required to disclose personal information collected through the website to third parties without your knowledge or consent. For example, Grafton may disclose user information required by law or legal process, or when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.  The processing of your personal data by these service providers may involve a transfer of data outside the country in which the information was originally provided.

HOW WE PROTECT PERSONAL INFORMATION

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other 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.

PERSONAL INFORMATION TRANSFER

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. Whenever we transfer your personal data out of the country in which you initially provided the information, we will protect that information as described in this Online Privacy Notice.

HOW LONG WILL YOU USE MY PERSONAL INFORMATION FOR?  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements.

YOUR RIGHTS AND CHOICES

Under certain circumstances, you have rights under data protection laws in relation to your personal data. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.

HOW TO CONTACT US

If you have any questions about this Online Privacy Notice, including any requests for access to your personal information, please contact Grafton at: Grafton Advisors, 23 King Street, London SW1Y 6QY or +44 (20) 7866 8850

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.