Privacy Notice

Square Capital LLP is a 100% Square Capital LLP affiliate and offers a comprehensive range of financial services to its clients.
The protection of your personal data is important to Square Capital LLP, which has adopted strong principles in that respect for the entire Group in its Privacy Policy.
This Data Protection Notice provides you with detailed information relating to the protection of your personal data by Square Capital LLP.
Square Capital LLP, having its registered office at 1, Cork Street Mews, London, W1S 3BL and/or its Group entities (“we”) are responsible, as a controller, for collecting and processing your personal data in relation to our activities. The purpose of this Privacy Notice is to let you know which personal data we collect about you, the reasons why we use and share such data, how long we keep it, what your rights are and how you can exercise them.
Further information may be provided where necessary when you apply for a specific product or service.

1. WHICH PERSONAL DATA DO WE USE ABOUT YOU?


We collect and use your personal data to the extent necessary in the framework of our activities and to achieve a high standard of personalised products and services.
Depending among others on the type of product or service we provide to you, we may collect various types of personal data about you, including:
• identification information (e.g. name, ID card and passport numbers, nationality, place and date of birth, gender, photograph, IP address);
• contact information (e.g. postal address and e-mail address, phone number);
• family situation (e.g. marital status, number of children);
• economic, financial and tax information (e.g. tax ID, tax status, income and other revenues, value of your assets);
• education and employment information (e.g. level of education, employment, employer’s name, remuneration);
• banking, financial and transactional data (e.g. bank account details, credit card number, money transfers, assets, declared investor profile, credit history, debts and expenses);
• data relating to your habits and preferences:
o data which relate to your use of our products and services in relation with banking, financial, transactional data and any other real estate data;
o data from your interactions with us (eg: our internet websites, our apps, our social media pages, meeting, call, chat, email, interview, phone conversation, correspondence, requests for information or documents, method of commercialisation);
• connection and tracking data (eg: audit trail, timestamping, cookies, connection to online service)
• data necessary to fight against over-indebtedness, fraud, money laundering and terrorist financing.
We may collect the following special categories of data, which are more sensitive in nature than personal data only upon obtaining your explicit prior consent where required.
We never ask for personal data related to your racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data or data concerning your sex orientation, unless it is required through a legal obligation.
The data we use about you may either be directly provided by you or be obtained from the following sources in order to verify or enrich our databases:
• publications/databases made available by official authorities (e.g. the official journal);
• our corporate clients or service providers;
• third parties such as credit reference agencies and fraud prevention agencies or data brokers in conformity with the data protection legislation;
• websites/social media pages containing information made public by you (e.g. your own website or social media); and
• databases made publicly available by third parties.

2. SPECIFIC CASES OF PERSONAL DATA COLLECTION, INCLUDING INDIRECT COLLECTION


In certain circumstances, we may collect and use personal data of individuals with whom we have, could have, or used to have a direct relationship such as:
• Prospects
For some reasons, we may also collect information about you whereas you have no direct relationship with us.
This may happen for instance when your employer provides us with information about you or your contact details are provided by one of our clients if you are for example:
• Family members;
• Co-borrowers / guarantors;
• Legal representatives (power of attorney);
• Beneficiaries of payment transactions made by our clients;
• Beneficiaries of insurance policies and trusts;
• Landlords;
• Ultimate beneficial owners;
• Clients‘ debtors (e.g. in case of bankruptcy);
• Company shareholders;
• Representatives of a legal entity (which may be a client or a vendor);
• Staff of service provider and commercial partners.

3. WHY AND ON WHICH LEGAL BASIS DO WE USE YOUR PERSONAL DATA?


a. To comply with our legal and regulatory obligations.
We use your personal data to comply with various legal and regulatory obligations, including:
• Real estate regulations
• banking and financial regulations in compliance with which we:
o set up security measures in order to prevent abuse and fraud;
o detect transactions which deviate from the normal patterns;
o monitor and report risks that institution could incur; and
o record, when necessary, phone calls, chats, email, etc.
• reply to an official request from a duly authorised public or judicial authority;
• prevention of money-laundering and financing of terrorism;
• compliance with legislation relating to sanctions and embargoes;
• fight against tax fraud and fulfilment of tax control and notification obligations.
b. To perform a contract with you or to take steps at your request before entering into a contract
We use your personal data to enter into and perform our contracts, including to:
• provide you with information regarding our products and services;
• assist you and answer your requests;
• evaluate if we can offer you a product or service and under which conditions; and
c. To fulfil our legitimate interest
We use your personal data in order to deploy and develop our products or services, to improve our risk management and to defend our legal rights, including:
• proof of transactions;
• fraud prevention;
• establishing aggregated statistics, tests and models, for research and development, in order to improve the risk management of our group of companies or in order to improve existing products and services or create new ones;
• personalising our offering to you and that of other BNP Paribas entities through:
o improving the quality of our products or services;
This can be achieved by:
• qualifying our prospects and clients;
• monitoring transactions to identify those which deviate from the normal routine.
d. To respect your choice if we requested your consent for a specific processing
In some cases, we must require your consent to process your data, for example:
• where the above purposes lead to automated decision-making, which produces legal effects or which significantly affects you. At that point, we will inform you separately about the logic involved, as well as the significance and the envisaged consequences of such processing;
• if we need to carry out further processing for purposes other than those above in section 3, we will inform you and, where necessary, obtain your consent.
4. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
In order to fulfil the aforementioned purposes, we only disclose your personal data to:
• Service providers which perform services on our behalf;
• Independent agents, intermediaries or brokers, banking and commercial partners, with which we have regular relationship;
• Financial or judicial authorities, arbitrators and mediators, state agencies or public bodies, upon request and to the extent permitted by law;
• Certain regulated professionals such as lawyers, notaries or auditors.

5. TRANSFERS OF PERSONAL DATA OUTSIDE THE EEA


In case of international transfers originating from the European Economic Area (EEA), where the European Commission has recognised a non-EEA country as providing an adequate level of data protection, your personal data may be transferred on this basis.
For transfers to non-EEA countries whose level of protection has not been recognised by the European Commission, we will either rely on a derogation applicable to the specific situation (e.g. if the transfer is necessary to perform our contract with you such as when making an international payment) or implement one of the following safeguards to ensure the protection of your personal data:
• Standard contractual clauses approved by the European Commission;
• Binding corporate rules.
To obtain a copy of these safeguards or details on where they are available, you can send a written request as set out in Section 9.

6. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?


We will retain your personal data for the longer of the period required in order to comply with applicable laws and regulations or another period with regard to our operational requirements, such as proper account maintenance, facilitating client relationship management, and responding to legal claims or regulatory requests.
We will keep your Personal Data for no longer than reasonably necessary. We will retain your personal information in accordance with legal and regulatory requirements as set out in our Data retention policy.

7. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?


In accordance with applicable regulations, you have the following rights:
• To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
• To rectify: where you consider that your personal data are inaccurate or incomplete, you can require that such personal data be modified accordingly.
• To erase: you can require the deletion of your personal data, to the extent permitted by law and where we have no legal basis for further processing.
• To restrict: you can request the restriction of the processing of your personal data e.g. when you contest lawfulness of processing
• To object: you can object to the processing of your personal data, on grounds relating to your particular situation where the Processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject, which require protection of Personal Data, in particular where the Data subject is a child.
o You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
• To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time. To do that, please email us at info@squarecapital.co.uk
• To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.
• We do not conduct automated decision making.

If you wish to exercise the rights listed above, please send a request to info@squarecapital.co.uk or a letter to the following address: 9-10 Savile Row, London, W1S 3PF. Please include a scan/copy of your identity card for identification purposes.

In accordance with applicable regulation, in addition to your rights above, you are also entitled to lodge a complaint with the competent supervisory authority, however we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. To lodge a complaint with the Information Commissioners Office (the UK Supervisory Authority); you can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

8. HOW CAN YOU KEEP UP WITH CHANGES TO THIS DATA PROTECTION NOTICE?


In a world of constant technological changes, we may need to regularly update this Data Protection Notice.
We invite you to review the latest version of this notice online and we will inform you of any material changes through our website or through our other usual communication channels.

9. HOW TO CONTACT US?


If you have any questions relating to our use of your personal data under this Data Protection Notice, please contact info@squarecapital.co.uk, who will investigate your query.

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