CZ CAPITAL LLP
CZ CAPITAL SERVICES LIMITED
CZ CAPITAL LLP is incorporated in England and Wales and its registered office is 4th Floor Reading Bridge House, George Street, Reading, Berkshire, RG1 8LS. It is authorised and regulated in the UK by the Financial Conduct Authority. Its company number is OC315992.
References to “CZ”, “we”, “us” and “our” are references to CZ CAPITAL LLP.
About this privacy notice
We are a data controller in respect of your personal data for the purposes of the UK General Data Protection Regulation (“GDPR”). We are responsible for ensuring that we use your personal data in compliance with data protection law.
This privacy notice applies to you if (i) you are a client or prospective client of CZ (including an investor or prospective investor in a vehicle or entity that we manage or advise (“CZ Funds”)), a service provider to us or to a CZ Fund, (ii) your personal data has been provided to us in connection with any of the foregoing by another person (such as where you are a director, partner, trustee, employee, agent or direct or indirect owner of such person); or (iii) you otherwise enter into communications with us by email or other means.
This privacy notice sets out the basis on which personal data about you that you provide to us, that we create about you or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.
Consent – Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Data Controller – The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by UK law, the controller or the specific criteria for its nomination may be provided for by UK law.
Data Processor – A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. A processor must only act on the documented instructions of a controller. If a processor determines the purpose and means of processing then it will be considered to be a controller.
Personal data – Any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing – Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
The data privacy principles CZ adheres to
- CZ will process all personal data in a lawfully, fair and transparent manner;
- CZ will only collect personal data where it is necessary for;
- CZ to provide a service to you;
- you to provide a service to CZ;
- CZ to keep you informed of its products and services; or
- CZ to comply with its legal and regulatory obligations;
- CZ will process all personal data in a lawfully, fair and transparent manner;
- CZ will only collect personal data where it is necessary for;
- The personal data collected by CZ will be adequate, relevant and limited to what is necessary in relation to the specific purpose for which your data will be processed;
- CZ will take all reasonable steps to ensure that personal data is accurate and, were necessary, kept up-to-date;
- CZ will maintain personal data in a form that permits identification no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with CZ’s record retention requirements as mandated by the Financial Conduct Authority;
- CZ will hold and process person data in a manner that ensures appropriate security;
- CZ will only share personal data where it is necessary to provide the agreed service or where it is necessary for CZ to comply with its legal and regulatory requirements.
- CZ will only utilise a service provider based outside of the UK for the processing of personal data where this is strictly necessary to facilitate our services to you. In all cases, we will ensure service providers are fully compliant with GDPR, or deemed equivalent, ahead of transferring any personal data.
Personal data that we might use
We might process the following personal data about you:
- Information provided to CZ or to a CZ Fund or its administrator by you or (if different) the applicant for interests in a CZ Fund. This might include your name and address (including proofs of name and address), contact details, date of birth, gender, nationality, photograph, signature, copies of identity documents, occupational history, job title, income, assets, other financial information, bank details, investment history, tax residency and tax identification information. Such information might be provided in an application form or in other documents (as part of an application process or at other times), face-to-face, by telephone, by email or otherwise.
- Information that CZ collects or generates: This might include information relating to your (or an applicant’s) investment in a CZ Fund, emails (and related data), call recordings and website usage data.
- Information that CZ obtains from other sources: This might include information obtained for the purpose of our know-your-client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically exposed person checks, sanctions checks), information from government or public bodies, public websites and other public sources and information received from the applicant’s advisers or from intermediaries.
Uses of your personal data
We collect your personal information to fulfil our contractual obligations, our statutory and regulatory obligations and/or the legitimate business interests of CZ or a CZ Fund and for other purposes for which CZ has a lawful basis under the privacy laws, including:
- Compliance with legal and regulatory obligations and industry standards, including know-your-client procedures, the automatic exchange of tax information and legal judgments.
- General business administration, including communicating with investors, communicating with service providers and counterparties, accountancy and audit services, risk monitoring, the administration of IT systems and monitoring and improving products.
- Assessing and processing applications for interests in a CZ Fund and other dealings with CZ, including performing know-your-client procedures, issuing and redeeming interests, receiving payments from and making payments to the applicant, calculating net asset value, and overseeing these processes.
- Business activities, such as investor relations, discussions with our or a CZ Fund’s service providers and counterparties, decision-making in relation to the CZ Funds, and business strategy, development and marketing.
We are entitled to process your personal data in these ways for the following reasons:
- You may enter into an investment contract with CZ or a CZ Fund and some processing will be necessary for the performance of that contract, or will be done at your request prior to entering into that contract.
- Processing may be necessary to discharge a relevant legal or regulatory obligation.
- The processing is necessary for the legitimate business interests of CZ or a CZ Fund or its administrator or another person, such as:
- carrying out the ordinary or reasonable business activities of CZ, a CZ Fund or its administrator or other persons, or other activities previously disclosed to you or referred to in this privacy notice;
- ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud;
- establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and
- ensuring the security of information systems.
- In respect of any processing of sensitive personal data falling within special categories, such as any personal data relating to the political opinions of a politically exposed person, the processing will be necessary for reasons of substantial public interest.
Disclosure of your personal data to third parties
We may from time to time, in accordance with the purposes described above, disclose your personal data to other parties, including (a) our affiliates including CZ Capital Services (Cayman) Limited, (b) a CZ Fund’s administrator and its affiliates, (c) professional advisers such as law firms and accountancy firms, (d) other service providers of CZ or a CZ Fund or its administrator, including technology service providers, (e) counterparties and (f) courts and regulatory, tax and governmental authorities. Some of these persons will process your personal data in accordance with our instructions and others will themselves be responsible for their use of your personal data. These persons may be permitted to further disclose the personal data to other parties.
Transfers of your personal data outside the UK or European Economic Area
Your personal data may be transferred to, stored or accessed by persons outside the UK or European Economic Area (“EEA”) such as a CZ Fund, CZ CAPITAL LLP’s affiliate CZ Capital Services (Cayman) Limited (a company established in the Cayman Islands), and in particular may be transferred to, stored or accessed by affiliates or service providers of the CZ Funds or their administrators outside the UK or EEA.
Where personal data is transferred outside the UK or EEA, we will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted under applicable law. For example, the country to which the personal data is transferred may be approved by the UK government or European Commission (as applicable) or a relevant data protection authority (as offering equivalent protections to those afforded in the UK or EEA (as applicable)), the recipient may have agreed to model contractual clauses approved by the UK government or the European Commission (as applicable) that oblige them to protect the personal data.
You can obtain more details of the protection given to your personal data when it is transferred outside the UK or EEA, including a copy of any standard data protection clauses entered into with recipients of your personal data, by contacting us using the details set out under “Contacting us” below.
Necessity of personal data for us to provide services to you or an investment in a CZ Fund
The provision of certain personal data is necessary for us to provide services to you or for interests in a CZ Fund to be issued to any applicant and for compliance by CZ and the CZ Funds and our and their respective service providers with certain legal and regulatory obligations. Accordingly, if certain personal data is not provided when requested, we may not be able to provide services to you and/or an application for interests might not be accepted or interests might be compulsorily redeemed.
Retention of personal data
How long we hold your personal data for will vary. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal data).
CZ has comprehensive policies and procedures in place to ensure your personal data is kept safe and secure, with these including: data encryption; firewalls; background checks for staff; and security procedures across CZ’s operations.
How have you been categorised in accordance with GDPR?
The GDPR requires CZ to inform you of the legal basis on which we maintain your personal data. As a general rule, the following is applicable:
|Data Subject||Legal Basis|
|Clients||Information is maintained on the basis of contractual obligation and/or legitimate interests (where relevant)|
|Service providers||Information is maintained on the basis of contractual obligation|
|Database/marketing contacts||Information is maintained on the basis of legitimate interest|
You have a number of legal rights in relation to the personal data that we hold about you. These rights include the following:
- You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email CZ at GDPR@czcapital.co.uk. CZ will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.
- You have the right to request that the information CZ holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for CZ to retain this information.
- As a data subject, you have the right to request that any information CZ holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as ‘data portability’.
- You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact GDPR@czcapital.co.uk.
- You have the right to object to your information being processed, for example for direct marketing purposes.
- You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
- You have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/) if you are not happy with the way that we manage or process personal data.
You can exercise your rights by contacting us using the details set out under “Contacting us” below. You can find out more information about your rights by contacting the UK’s Information Commissioner’s Office, or by searching its website at www.ico.org.uk.
Changes to this Privacy notice
CZ may, from time to time, review and update this Privacy Notice. The Firm will maintain the latest version of this Privacy Notice on its website.
If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions and requests to James Gore of CZ CAPITAL LLP on +44 (0)20 7667 6590.