STAGE CAPITAL PRIVACY POLICY

Stage Capital (SCML, the Firm, we, us or our) is committed to protecting your privacy.

This Privacy Policy explains how we collect and look after your personal data and tells you about your privacy rights and options.

It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements any such privacy notices and is not intended to override them.

Please also refer to our Cookie Policy, which explains how we use cookies and other web tracking devices via our website www.stagecap.com.

1.Who is responsible for your personal data?

SCML is the controller of and responsible for your personal data.

2.What personal data do we collect?

We may collect the following personal data from you:

  • identity and contact information (including your name, job title, address, telephone number, mobile phone number, fax number and email address and, if you have one, your username and password for our website);
  • technical data (including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website);
  • usage data (including information about how you use our website, products and services);
  • marketing and communications data (including your preferences in relation to receiving marketing materials from us and related parties and your communication preferences);
  • information collected from publicly available resources, integrity databases and credit agencies; and
  • details of your visits to our premises or telephone calls with members of our staff.

This personal information may, from time to time, include personal data about your membership of a profession or trade association and details of any criminal record you may have.

3.  How is your personal data collected?

We may use different methods to collect data from and about you, including your voluntary provision of data when doing the following:

  • when you correspond with us by post, phone or email;
  • when you request marketing materials to be sent to you;
  • when you or your organisation browse, make an enquiry or otherwise interact on our website;
  • when you or your organisation offer to provide or provide services to us.

In some circumstances, we may collect personal data about you from third parties. These third parties may include your organisation, other organisations with whom you have dealings, government agencies, credit reporting agencies, an information or service provider or from a publicly available record.

4.  How and for which purposes will we use your personal data?

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you or your organisation;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
  • where we need to comply with a legal or regulatory obligation.

In addition, the processing may be based on your consent where you have expressly given that to us.

We may use your personal data for the following purposes only (being permitted purposes)

  • managing and administering your or your organisation’s business relationship with SCML;
  • compliance with our legal and regulatory obligations (such as record keeping obligations), compliance screening or recording obligations;
  • analysing and improving our services and dealings with you or your organisation;
  • protecting the security and access to our premises, website IT and communication systems and other systems;
  • to comply with court orders and exercise and/or defend our legal rights; and
  • for any other purpose that is related to or ancillary to the above or for which your personal data has been provided to us.
  • communicating with you, including by sending you marketing communications regarding our products or services.

Where required, we will only send you marketing communications where you have opted-in and will provide you with the opportunity to opt-out at any time if you no longer wish to receive marketing communications from us.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

We will not use your personal data for taking any automated decision affecting you or creating profiles other than described above.

We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. With whom will we share your personal data? 

We may share your personal data with the following parties and in the following circumstances:.

  • other companies in the SCML group, acting as processors, where required for the purposes of providing products or services to you or your organisation and for administrative, billing and other business purposes;
  • organisations providing services for money laundering checks and other fraud and crime prevention purposes;
  • courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a claim or for the purposes of a confidential alternative dispute resolution process;
  • third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets or to whom we may assign or novate any of our rights or obligations;
  • third party service providers, to process personal data for one or more of the permitted purposes on our behalf and in accordance with our instructions – we will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers.

We will otherwise only disclose your personal data when you direct us or give us permission to do so, when we are required by applicable law or regulation to do so, or as required to investigate actual or suspected criminal of fraudulent activities.

We will not share your personal data with any company outside the SCML group of companies for marketing purposes unless we first obtain your express opt-in consent.

6.  International transfers of personal data

We do not transfer your personal data outside the European Economic Area unless required to do so by applicable law or regulation.

7.  Keeping personal data secure

We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data. Personal data may be kept on our IT systems, those of our contractors and service providers or in paper files.

8.  For how long will we retain personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory accounting, or reporting requirements, or until you withdraw your consent (where applicable), and provided that in each case we are not legally required or otherwise permitted to continue storing such data.

9.  Your right

Under certain circumstances and subject to certain legal conditions, you have the right:

  • to request a copy of the personal data about you which we hold;
  • to have any inaccurate personal data corrected;
  • to request erasure of your personal data; and
  • to object to or restrict our processing of your personal data.

You may also make a complaint if you have a concern about our handling of your personal data.

If you wish to exercise any of the rights set out above or make a complaint, please send an email to [email protected]. We may request specific information from you to confirm your identity, in order for us to comply with our security obligations and to prevent unauthorised disclosure of data. You will not usually have to pay a fee to access your personal data, but we reserve the right to charge you a reasonable administrative fee for (or we may refuse to comply with) any manifestly unfounded or excessive requests or any additional copies of the personal data you request from us.We will respond to all legitimate requests in a timely manner. If you are not satisfied with our response, you may take your complaint to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).

10.  Changes to this Privacy Policy and Updating Your Personal Data

This Privacy Policy was last updated in May 2018. We reserve the right to update and change this Privacy Policy from time to time in order to reflect any new legal requirements or any changes to the way in which we process your personal data, by publishing the updated Privacy Policy either on our website or in some other way. The changes will take effect as soon as they are published.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data (including your email address) changes during your relationship with us or if you wish to cancel any request you have made of us, by sending an email to [email protected]  We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

LEGAL NOTICE

These terms and conditions apply to the access to and use of this website (the “Website”). Please read these terms and conditions carefully. Your use of the Website is confirmation that you have understood and agreed to be bound by all of these terms and conditions.

Who We Are

The Website is communicated by and is the property of Stage Capital Management Limited (“Stage”). Stage is a company incorporated in England with limited liability (registered no. 10024328, registered office 25 Eccleston Place, London, SW1W 9NF) and is authorised and regulated by the Financial Conduct Authority (FCA no. 742511).

Stage is a subsidiary of Stage Capital LLP. Stage Capital LLP is a limited liability partnership incorporated in England (registered no.OC396661), registered office 25 Eccleston Place, London, SW1W 9NF.

Use of the Website

The information on this Website is primarily intended for owners and managers of companies incorporated in the UK and Europe who may be seeking sources of potential financing, as well as financial institutions seeking a potential partner for investment in UK and European companies.

Information on this Website is directed at persons who have professional experience in matters relating to investments and Stage does not offer investment advice to, or conduct business with “retail clients” as defined under the Rules of the FCA. Generally, a “retail client” is a private individual who does not have relevant sufficient experience of the types of investment under consideration.

Please note that Stage will not regard any user of this Website as its client for any purposes relating to the Financial Services and Markets Act 2000 (FSMA) and will not owe any duties to such person in accordance with the provisions of the FCA rules that regulate the relationship between a regulated firm and its clients. Therefore, the protections afforded to customers under the UK regulatory system will not be available to users of this Website.

Persons resident in territories other than the UK should consult their professional advisers as to whether they require any governmental or other consents, licences or approvals or need to observe any formalities (including registration or filing formalities) to enable them to invest in the products described on the Website and prior to them viewing or using this Website in jurisdictions other than the UK.

No Offer and No Advice

The Website is for information purposes only. Nothing in the Website should be construed as an offer, invitation or general solicitation to: subscribe for or participate in any investments or securities or is otherwise intended to constitute a financial promotion for the purposes of section 21 of FSMA; provide investment advisory services; make personal recommendations; or to engage in any other transaction, and must not be relied upon in connection with any investment decision.

Further, the information contained on the Website, including all opinions or other content is not intended to and does not constitute the provision of financial, accounting, tax, legal, investment, consulting or other professional advice or services. Professional advice should be taken before any course of action is pursued.

No Representation or Warranty

This Website is subject to regular update and revision. While we use reasonable efforts to ensure the correctness and timeliness of all material posted on the Website, we take no responsibility for errors or omissions which are the result of technical causes, or otherwise. We maintain the right to delete or modify in part or in full any information on this Website without prior notice. You must in any event conduct your own due diligence and investigations, rather than relying on the information on the Website.

You are solely liable for any use you may make of this information. Stage makes no representation, warranty, condition, undertaking or term either express or implied as to the condition, quality, performance, accuracy, suitability, fitness for purpose, completeness or freedom from viruses of the content contained on the Website or that such content will be accurate, up to date, uninterrupted or error free. Whilst we use reasonable efforts to ensure that the standard of the Website remains high and to maintain the continuity of it, the internet is not always a stable medium and errors, omissions, interruptions of service and delays may occur at any time, for which Stage accepts no responsibility. If the need arises, we may suspend access to the Website or close it indefinitely. To the extent permitted by law, we do not warrant that this website will be available at all times.

Save in respect of liability for death or personal injury arising out of negligence or for fraudulent misrepresentation, we and all contributors to the Website hereby disclaim to the fullest extent permitted by law all liability for any loss or damage including any consequential or indirect loss or damage incurred by you, whether arising in tort, contract or otherwise, and arising out of or in relation to or in connection with your access to or use of or inability to use the Website.

Stage does not guarantee that material on this Website will be free from computer viruses or malicious programs that have contaminating and disruptive properties. It is your responsibility to take protective steps such as having up-to-date internet security programs.

Intellectual Property Rights

This Website is owned by Stage and any and all intellectual property rights in the Website including, but not limited to, copyright and database rights and any logos or trademarks (whether registered or unregistered) are owned by and remain the property of Stage (or its third party licensors as applicable) at all times.

The content of the Website is subject to copyright with all rights reserved. The copyright and all other rights in all of the material on the Website are owned by Stage unless stated otherwise. You may download and/or print out a hard copy of individual pages and/or sections of the Website provided that this is for private or domestic use only and that you do not remove any copyright or other proprietary notices. Any downloading or other copying from the Website will not transfer title to any software or material to you. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use for any public or commercial purpose the Website without our prior written permission. Any unauthorised reproduction or use of the Website or the information presented therein, may be the subject of prosecution, particularly for infringement of copyright. Any rights not expressly granted in these terms are reserved by Stage or its licensors.

Stage does not give persons accessing the Website permission to use any trade mark used in the Website. Unauthorised use may constitute an infringement of the relevant owner’s rights.

Third Party Websites

Any links provided will allow you to leave this Website. The linked sites are not under the control of Stage and Stage is not responsible for the contents of any linked site or any link contained in a linked site. Stage is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement or approval by Stage of the site.

Changes to the Terms

Changes are periodically made to the information on the Website and to these terms and conditions and these changes will be incorporated in new editions of this site. Stage reserves the right to alter or amend any information set out in the Website and these terms and conditions without notice. If you use the Website after Stage has posted the changes you will be bound by the new terms. You should therefore ensure that you read the terms and conditions each time you use the Website.

If you have any queries about the Website or any information contained on it, please contact us by telephone on 0207 661 5678.

Important Information

Past performance should not be seen as a guide to future performance. The value of an investment and any income from it can go down as well as up and you may not get back the amount originally invested. The levels of taxation will depend on the individual circumstances of the investor from time to time.

Governing Law and Jurisdiction

These terms and conditions, your use of the Website, and all matters connected with them, are governed by and shall be construed in accordance with the law of England and Wales and shall be subject to the exclusive jurisdiction of the English courts. Disputes arising in connection with these terms shall accordingly be subject to the exclusive jurisdiction of the courts of England and Wales. If you access the Website from outside the UK, you are responsible for ensuring compliance with any local laws relating to access.

Invalidity

If any provision contained in these terms and conditions is found by any competent authority or a court of law to be invalid or unenforceable for any reason, the remainder of these conditions shall continue in full force and effect.

Use of Cookies by Stage

A cookie is a piece of data stored on your hard drive containing information about you as the user. Once you close your browser, the cookie is deactivated. You have the right to refuse our use of cookies containing information about you on your hard drive.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Phone calls

Please be aware that phone calls to Stage Capital may be recorded for training, monitoring and compliance purposes.