Gravis – Privacy Notice
Gravis Capital Management Ltd and Gravis Advisory Ltd or any third-party service provider or consultant appointed by Gravis to act on its behalf (together "Gravis" “we”, “us” or “our”) are committed to protecting your personal data and are required, by Data Protection Legislation (as defined below), to provide individuals with certain information about how we use your personal information. This privacy notice (“Privacy Notice”) explains what information we collect from you or you provide to us, how we use it and with whom we share that information. The Privacy Notice also sets out your rights and who you can contact for more information. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
In this Privacy Notice:
This Privacy Notice is directed to individuals whose personal data we handle in the course of carrying on our commercial activities. These individuals could be:
For the purposes of Data Protection Legislation, Gravis is a controller of personal data.
1. What information we collect about you
We may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Legislation and as set out in this Privacy Notice.
The personal data we collect, record and process may include:
Information you provide to us
This is likely to be determined by the nature of our relationship with you but may include:
In certain circumstances, we also collect and process what are known as ‘special categories’ of personal data (as defined by Data Protection Legislation). Money laundering, sanctions, financial crime and fraud prevention checks sometimes result in Gravis obtaining information about actual or alleged criminal convictions and offences.
Information we collect
This will include information that we generate about you during our relationship with you and may include internal files which we produce as a record of our relationship with our clients or prospective clients and any personal data you provide during correspondence with us which we may need for our business purposes or to comply with our legal obligations.
Information we obtain from other sources
In certain circumstances we process personal data provided from other sources including:
You are not obliged to provide us with your personal data where it is requested but we may be unable to proceed with your business relationship with Gravis if you do not do so.
2. How we use your information
Our primary purpose in collecting your personal information is to enable us to carry out our investment management business.
Additionally, we use your information for the following specific purposes:
3. Legal grounds for using your personal information
Data Protection Legislation permits us to process your personal data in the way that we do because the processing is:
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that personal data; (ii) you have made the data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.
Where such processing is being carried out on the basis that it is necessary to pursue our legitimate interests, such legitimate interests do not override your interests, fundamental rights or freedoms.
4. Providing your information to third parties
The following categories of recipients may receive your personal information and process it for the purpose outlined in this Privacy Notice:
Where we share information with third parties we will ensure we do so in compliance with Data Protection Legislation.
Gravis does not provide information to third parties for their own marketing purposes.
5. Transferring data outside of the EEA
Personal data may be transferred outside of the EEA to other third countries and international organisations. We will ensure that any such transfer is subject to appropriate safeguards in accordance with Data Protection Legislation.
This may be dine in the following ways:
6. Automated processing
Gravis does not carry out automated decision-making or profiling.
7. Your rights
At any time, you have the right:
Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.
8. How long we keep your information
We will only keep the information we collect about you for as long as is necessary to carry out the purpose (as further described above) for which it was collected, including for the purpose 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 data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. How we protect your information
We ensure there are appropriate technical, physical, electronic and administrative safeguards in place to protect your personal details from unauthorised access.
10. Changes to Privacy Notice
This Privacy Notice may be amended from time to time without notice, in which case we will place an updated version on this page. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to:
The Compliance Officer
Gravis Capital Management Ltd
24 Savile Row
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
If you have any concerns about our use of your information, you also have the right to make a complaint to your local supervisory authority. In the UK, the Information Commissioner’s Office (“ICO”) is the supervisory authority for data protection issues. Further information can be found at www.ico.org.uk.
Current version: December 2021