Privacy Policy

This privacy policy was last reviewed on 1 January 2023.

This privacy policy explains what information we gather about you, what we use that information for and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries.

Please read this privacy policy carefully. If you have any requests concerning your personal information or any queries regarding our processing, please contact us at hello@72capital.co.uk.

In this privacy policy “Data Protection Legislation” means any applicable law relating to the processing of personal data and/or privacy including, without limitation, the UK Data Protection Act 2018 and the UK GDPR.

Information About Us

In this privacy policy, references to “we”, “us”, “our” are references to 72 Capital Limited, a private limited company registered in England (registered no. 07480103) with registered address 71-75 Shelton Street, London, WC2H 9JQ. We are the controller for the purposes of Data Protection Legislation.

Collection of Information About You

We may collect and process the following data about you:

Information you give us. You may give us information about you by filling in forms on our website, submitting any job application or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our website, enter a survey and when you report a problem with our website. The information you give us may include your name, address, e-mail address and phone number.
Technical information when you visit our website, including the Internet Protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, geographical location, browser plug-in types and versions, operating system and platform. Please see the paragraph “Cookies” below for more information.

How We Use Your Information

When you provide personal information to us, we may use it for any of the purposes described in this privacy policy or as stated at the point of collection (or as otherwise permitted by law), including:

to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to notify you about changes to our service(s);
to process and acknowledge any job application that you may make;
to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
to improve our website to ensure that content is presented in the most effective manner for you and for your computer.

We will not use your personal information for automated decision making processes.

Legal Basis for Processing Your Information

We rely on one or more of the following processing conditions in order to process your personal information:

our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (provided these do not interfere with your rights);
to satisfy any legal and regulatory obligations to which we are subject;
to perform our obligations under any contracts that we have agreed with you, including our terms of use; or
where no other condition for processing is available, if you have agreed to us processing your personal information for the relevant purpose.

We may process your personal information on more than one of the grounds listed above, depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information.

Sharing of Information

We may disclose your personal information to our employees, officers, or insurers as reasonably necessary for the purposes set out in this privacy policy.

Your personal information may be transferred to third-party service providers who process information on our behalf, including providers of information technology, identity management, website hosting and management, data analysis, data back-up, security and storage services.

The third-party providers may use their own third-party subcontractors that have access to personal data.

We may disclose your personal information to law enforcement, regulatory, or other government agencies or to other third parties as required by, and in accordance with, applicable law or regulation.

We require all third-parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Security of Personal Information

We have implemented generally accepted standards of technology and operational security to protect personal information from loss, misuse, alteration or destruction. Only authorised persons are provided access to personal information collected via the website; such individuals have agreed to maintain the confidentiality of this information.

Although we use appropriate security measures once we have received your personal data, the transmission of data over the Internet (including by e-mail) is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to or by us.

International Transfers

Your personal data will not be transferred to countries or territories outside the UK and the European Economic Area.

Retention of Personal Information

We will retain your personal information only as it is required for the purposes for which it was collected, or as required to do so by law, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information 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 information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the information, the purposes for which we process the information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

Direct Marketing

Where we are legally required to obtain your explicit consent to provide you with marketing materials, we will only issue you with such marketing materials if you have provided consent for us to do so.

If you have elected to do so, you will receive automated emails when content is updated. If you opt into any newsletters, you will receive emails known as newsletters.

Unsubscribing from Marketing

If you want to unsubscribe from mailing lists or any marketing, you should look for and follow the instructions we have provided within the appropriate area(s) of the website or in the relevant communications to you.

If you do not wish to receive emails or marketing communications from us, you can contact us at any time to request that such communications cease. If you choose to unsubscribe from any or all mailings, we shall cease to issue the relevant marketing communications to you but may retain your personal information as described under the heading “Retention of personal information” above.

Rights in Relation to Your Information

You may have certain rights in relation to the personal information we hold about you. In particular, you may have a right to:

request a copy of personal information we hold about you;
ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information;
object to our processing of your personal information;
request the transfer of your personal information to you or a third party; and/or
withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).

If you would like to exercise these rights, please contact us using the details set out at the end of this privacy policy. You will not usually have to pay a fee to access your personal information (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 could refuse to comply with your request in these circumstances.

Cookies are small text files that are placed on your computer by websites that you visit, if you agree. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you.
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests.

Cookies are essential for helping us deliver a high-quality online experience for our clients. By consenting to our use of cookies through our cookies banner or otherwise, you consent to us using non-essential cookies in accordance with this privacy policy. If you would prefer us not to use cookies, then you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Except for essential cookies, all cookies will expire after 1 year.

Failure to Provide Personal Information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

Third-party links

Our 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 policy. When you leave our website, we encourage you to read the privacy policy of every website you visit.

If you have any questions or complaints about this privacy policy or the way your personal information is processed on the website or would like to exercise one of your rights set out above, please contact us by email at hello@72capital.co.uk.

You also have the right to lodge a complaint with your local data protection regulator.

Modifications

We may update this privacy policy at any time by publishing an updated version here. To ensure you are aware of when we make changes to this privacy policy, we will amend the revision date at the top of this page. The new modified or amended privacy policy will apply from that revision date. Therefore, we encourage you to review this privacy policy periodically to be informed about how we are protecting your information.