Privacy | Praesidium Capital Management

Last Updated: August 2023

As a controller, Praesidium Capital Management Limited (“Praesidium Capital Management Limited /we/us/our”) comply with all applicable data protection and privacy legislation in force from time to time including the UK General Data Protection Regulation, the EU General Data Protection Regulation (where applicable) (together the “GDPR”) and the Data Protection Act 2018. (“DPA18”).

This privacy notice details how we process your personal data.

We process personal information to act as an intermediary for financial transactions; typically, debt raising and treasury for financial structures such as bonds and equity products or similar for clients.

To understand how any personal information other than that provided to us through this website is processed you will need to refer to any personal communications you receive from us, check any privacy documents provided when entering into a contract with us, or contact us to ask about your personal circumstances. Contact us using the information in the contact us section. https://www.investpcm.co.uk/contact

At Praesidium Capital Management Limited we take our data protection and privacy responsibilities seriously. This privacy notice explains how we collect, use, and share personal information during our business activities, including:

What Personal Information we collect and when and why we use it
How we share personal information within Praesidium Capital Management and with our service providers, regulators and other third parties.
How we use cookies and tracking technology on our websites.
Carrying out direct marketing.
Transferring personal information globally.
How we protect and store personal information.
Legal rights available to help manage your privacy.
How you can contact us for more support.

We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice. If we make significant changes to this privacy notice, we will seek to inform you by notice on our website or email ("Notice of Change"). Privacy Notice last updated August 2023

What Personal Information We Collect And When And Why We Use It

In this section you can find out more about:

The types of personal information we collect.
The legal basis for processing personal information.
How we use personal information.
When we collect personal information
Additional information on the use of artificial intelligence and machine learning.

Praesidium Capital Management Limited Data Subjects

If Praesidium Capital Management Limited collects information about you, you will usually:

be registered with or use one of our website(s) or online services.
be a private client;
contact us (enquiries);
visit work with us as a service provider; and/or
visit a Praesidium Capital Management office or register to attend a Praesidium Capital Management event.

Personal Information we collect will fall within one of the following categories:

Your name and how to contact you:

Basic contact information about you, including your signature.

Identification data, including unique descriptors:

Government issued identifiers, other unique identifiers such as date of birth, and personal descriptors that might identify you.

Financial and Transactional:

Financial information about you, transactional information and credit information, account authentication details.

Contractual details:

Information collected as part of the products and services we provide to you.

Socio-Demographic:

Details about your work or profession, nationality, education.

Technical Information:

Details about your devices and technology that you use to access our services, including IP address.

Behavioural:

Information about how you use our products and services.

Location:

Data we receive about where you are.

Communications and CCTV:

Information we capture through your communications with us, e.g., voice recordings of telephone conversations, emails and instant messaging, and CCTV images if you visit our offices.

Publicly available data:

Details about you that are in public records and information about you that is openly available on the internet.

Sensitive categories of data:

Laws and other regulations treat some types of personal information, including personal information relating to health or criminal convictions and offences, as special and affords them additional protections. We will only collect and use these types of data if the law allows us to do so.

The legal basis for processing your personal information

We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This is explained in more detail in the section "Personal Information We Collect" below which sets out the purposes for which we collect Personal Information. For each purpose, we indicate that we will have one or more of the following reasons for using your personal information:

our use of your personal information is necessary to fulfil a contract we have with you or to take steps to enter into a contract with you, for example when you ask us to provide you with a product or service;
our use of your personal information is necessary to comply with a legal obligation that we have, for example where we are required to report to tax authorities;
our use of your personal information is required for regulatory reasons that are in the public interest, for example to prevent and detect financial crime;
you have provided your consent to us using the personal information, for example if you have agreed to receive marketing communications; or
our use of your personal information is in our legitimate interests as a commercial organisation.

The personal information Praesidium Capital Management Limited collects will usually be required to enable us to fulfil a contract or provide a service, or to fulfil our regulatory or legal obligations. If you choose not to provide certain personal information in these circumstances, Praesidium Capital Management Limited may be unable to provide the services you require. If the provision of personal information is voluntary, you will be informed of this at the point of collection and there will be no consequences to you if personal information is not provided.

Where you have provided your consent for voluntary provision of personal data, you have the right to withdraw your consent at any time. You can do so by making a request to the entity that collected your personal information by direct marketing by contacting us at the contact us section. https://www.investpcm.co.uk/contact

Where we rely on our legitimate interests, we will do so on the basis that the activity:

is necessary for us to meet our business or commercial objectives and to provide services to our clients and cannot be achieved without reliance on our legitimate interests;
is proportionate and would not cause unjustified harm;
is aligned to, or would not conflict with, your reasonable expectations;
does not undermine your individual rights, interests, or freedoms; and
on balance, does not outweigh your privacy rights.

Personal Information We Collect

Personal Information we collect will be used for one or more of the following purposes:

To manage your relationship with Praesidium Capital Management Limited

What we use your information for:

To manage our relationship with you or your business, for example by finding out how best to contact you.
To develop new ways to meet our clients’ needs and to grow our business, for example by seeking client feedback or sharing our market research.
To develop and carry out marketing activities in order to keep our clients informed about our products and services.
To develop and manage our brand

Lawful Basis:

Legitimate interests.
Consent (where required by law).

Our Legitimate Interests:

Working out which of our products and services might interest you and telling you about them.
Communicating with you about Praesidium Capital Management Limited and our industry insight and providing thought leadership.
Seeking your consent when we need it to contact you.
Keeping our records up to date and honouring your communication preferences.

To develop, deliver and support our products and services

What we use your information for:

To deliver our products and services to our individual and business clients.
To provide advice or guidance, for example to support your use of our products and services.
To develop, test and manage new and existing products and services.
To understand how our clients use products and services from us and other organisations, for example through research and analytics.
To manage how we work with other companies that provide services to us and our clients, for example our relationships with vendors and suppliers

Lawful Basis:

Contractual obligation.
Legal obligation.
Legitimate interests.
Consent (where required by law).

Our Legitimate Interests:

Enabling the development of our products and services, and what we charge for them.
Defining relevant clients for new products and services.
Ensuring that we are able to effectively and efficiently meet our legal and contractual obligations.
Complying with regulatory requirements

To administer the products and services we deliver

What we use your information for:

To make and manage client payments.
To manage and provide treasury and investment products and services.
To manage fees, charges, and interest due on client accounts.
To collect and recover money that is owed to us.
To exercise our rights set out in agreements or contracts.

Lawful Basis:

Consent (where required by law).
Contractual Obligation.
Legitimate interests.

Our Legitimate Interests:

Ensuring that we are able to effectively and efficiently meet our contractual obligations.
Complying with regulatory requirements.

Crime Prevention and Detection

What we use your information for:

To detect, investigate, report, and seek to prevent fraud, financial crime, and anti-money laundering, for example through know-your-customer checks, AML screening and other identity checks.
To comply with other laws and regulations that apply to us, for example other financial services or country-specific legislation.

Lawful Basis:

Contractual obligation.
Legal obligation.
Public Interests.
Legitimate interests.

Our Legitimate Interests:

Ensuring that we are able to effectively and efficiently meet our contractual obligations.
Complying with regulatory requirements.

To protect our brand, our business, and our clients’ interests

What we use your information for:

To manage risk for us and our clients, for example through research and statistical analysis.
To respond to complaints and seek to resolve them.
To comply with foreign laws, law enforcement and regulatory requirements that may affect us as a business.
To protect our IT systems, network, and infrastructure.
To run our business in an efficient and proper way, for example managing our financial position, building our business capability, or for planning, communications, or audit.
To assert legal claims/for defence in legal disputes.

Lawful Basis:

Legitimate interests.

Our Legitimate Interests:

Ensuring that we are able to effectively and efficiently meet our contractual obligations.
Ensuring that we can exercise our legal rights.
Complying with regulatory requirements.

Where We Collect Your Personal Information From

We will collect the personal information we use for the above purposes from one or more of the below sources:

Directly from you throughout our relationship, including when you use our products, services and websites.
From other BNY Mellon entities.
From third parties that are authorised to share your information with us, such as intermediaries, broker dealers, our institutional clients and service providers.
From publicly available sources of information.

Additional information on the use of artificial intelligence and machine learning

Praesidium Capital Management Limited uses both manual and automated methods of processing. We may use automated methods of processing such as Artificial Intelligence (“AI”) and Machine Learning (“ML”), which are a set of technologies programmed to perform tasks and actions that are commonly associated with human beings. We may use AI and/or ML to optimize and increase the efficiency of business processes (e.g. to support customer service desks that receive inbound inquiries) and/or to support and enhance existing security controls.

Automated methods of processing are subject to regularly tested controls designed to ensure accuracy and fairness of the output. By using AI and/or ML, we do not intend to make automated decisions about you and therefore its application would not produce legal or similarly significant effects concerning you, unless stated otherwise in a specific privacy notice provided to you directly.

Sharing Personal Information Within BNY Mellon, With Third Parties, With Our Regulators

In this section you can find out more about how we share personal information:

Within Praesidium Capital Management Limited.
With third parties that help us provide products and services.
Regulators.

We share your information in the manner and for the purposes described below:

Within Praesidium Capital Management Limited, where such disclosure is necessary to provide you with our services or to manage our business;
With third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back-office systems.
With agencies and organizations working to prevent fraud in financial services;
With regulators.
To comply with applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
We may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our business partners, or advertisers;
Praesidium Capital Management Limited may, in the future, sell or otherwise transfer some or all of its assets to a third party. Your personal information, technical information about your device or browser and/or other anonymous information we obtain from you via the websites may be disclosed to any potential or actual third-party purchasers of such assets and/or may be among those assets transferred.

Using Cookies And Other Technologies

About Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to.

Cookies That We Use

We use cookies that are required for the functionality and security of our website only.

Cookies Used By Our Service Providers

Our service providers use cookies, and those cookies may be stored on your computer when you visit our website.
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://policies.google.com/privacy.

Control Your Cookie Settings

Most browsers are initially set to accept cookies. However, you have the ability to change your browser settings. It may also be possible to configure your browser settings to enable acceptance of specific cookies or to notify you each time a new cookie is about to be stored on your device enabling you to decide whether to accept or reject the cookie. You can also disable cookies by configuring your browser setting to reject cookies
Please refer to the help section of your browser for instructions on disabling cookies. For more information about cookies, how they work, why they are so useful and how to disable them, you can visit: https://allaboutcookies.org
If you do not wish to accept cookies from our website, please either disable them or refrain from using our website. If cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using all or part of our website.

Legal Rights Available To Help Manage Your Privacy

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. Please note that depending on your location your rights may vary. Learn more about each right you may have below.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by getting in touch with us. Subject to legal and other permissible considerations, we will use reasonable efforts to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right To Access Personal Information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.

Right To Rectify Or Erase Personal Information

You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.

You can also request that we erase your personal information in limited circumstances where:

it is no longer needed for the purposes for which it was collected; or
you have withdrawn your consent (where the data processing was based on consent); or
following a successful right to object; or
it has been processed unlawfully; or
to comply with a legal obligation to which Praesidium Capital Management Limited is subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

for compliance with a legal obligation; or
for the establishment, exercise, or defence of legal claims.

Right To Restrict The Processing Of Your Personal Information

You can ask us to restrict your personal information, but only where:

its accuracy is contested, to allow us to verify its accuracy; or
the processing is unlawful, but you do not want it erased; or
it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
you have exercised the right to object, and we are considering your request.

We can continue to use your personal information following a request for restriction:

where we have your consent; or
to establish, exercise or defend legal claims; or
to protect the rights of another natural or legal person.

Right To Transfer Your Personal Information

You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

the processing is based on your consent or on the performance of a contract with you; and
the processing is carried out by automated means.

Right To Object To The Processing Of Your Personal Information

You can object to any processing of your personal information which has our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right To Object To How We Use Your Personal Information For Direct Marketing Purposes

You can request that we change the manner in which we contact you for marketing purposes.

You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

Right To Obtain A Copy Of Personal Information Safeguards Used For Transfers Outside Your Jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred to countries not providing an adequate level of data protection.

We may redact data agreements to protect commercial terms.

Right To Lodge a Complaint With Your Local Supervisory Authority

You have a right to lodge a complaint with your local data protection supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

The primary point of contact for all issues arising from this privacy notice, is our Data Protection Officer. The Data Protection Officer can be contacted in the following ways:

By Email: info@investpcm.co.uk attention Data Protection Officer

By Post (UK): The Data Protection Officer, Grosvenor House, Agecroft Road, Swinton, Manchester, M278UW.

By Telephone: +44 (0) 330 100 5497

This website is owned and operated by Praesidium Capital Management

We are registered in England under registration number. 13644117

Our registered address is at Trevalyn House, 117 Chorley Road, Swinton, M27 4AA, United Kingdom