Privacy Notice | PM Alpha

Last updated: November 17, 2023

PM Alpha Privacy Notice

6.4 You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise this right at any time by contacting us.

6.5 Where you have opted in to receive such information, we may use your data to provide you with information from carefully selected third parties within the financial sector (associates or affiliates of PM Alpha) with whom we have partnered. Information will include resources such as white papers, research and insights. You have the right to unsubscribe to these email communications at any time by changing your account preferences via the Platform or by following opt-out links provided within the communications received.

7. WHEN WE DISCLOSE YOUR PERSONAL DATA

We may share your personal data with third party entities (for example, general partners) in the instances detailed below:

(a) with your permission.

(b) to perform our obligations under our agreement with you.

(c) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements or to protect the rights, property, or safety of PM Alpha, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction, or with law enforcement or regulatory agencies.

(d) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

(e) if PM Alpha or substantially all of its assets are acquired by a third party, as the personal data we hold about our clients will be one of the transferred assets.

(f) with our auditors, advisors, service providers and our regulator, the FCA in the course of their normal duties.

8. WHERE AND HOW WE STORE YOUR DATA

8.1 We will take all steps that are reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

8.2 We maintain strict security standards and procedures with a view to preventing unauthorised access to your data by anyone, including our staff. We use technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your data. All our staff and any third parties that we engage, are required to observe our privacy standards and must allow us to audit them for compliance.

8.3 Where we have provided you access to the Platform, you acknowledge that the transmission of information via the internet cannot be entirely secure. You are solely responsible for maintaining the confidentiality of your username and password to the Platform.

8.4 We will implement and adhere to information retention policies relating to your information and will ensure that your personal data is securely disposed of at the end of the appropriate retention period.

9. INTERNATIONAL TRANSFERS OF YOUR DATA

9.1 Whenever we transfer your personal data out of the UK, we take steps to ensure that it is protected to a similar standard as that under UK data protection law.

9.2 Where we use service providers, we use specific contracts that requires the service provider to protect personal data to a similar standard of protection as in the UK.

10. COOKIES

10.1 Our websites use cookies to distinguish you from other users of our website. This allows us to improve our website and provide an enhanced experience for our clients.

10.2 For detailed information on the cookies we use and purposes for which we use them, please refer to our Cookie Policy.

11. YOUR LEGAL RIGHTS

11.1 Right of access: You have the right to access information we hold about you in written or electronic form.

11.2 Right to rectification: If you believe the data we hold is inaccurate or incomplete you are entitled to have this rectified, typically within one month. Where this data has been passed to a third party the rectification should also include the data passed to that third party.

11.3 Right to erasure: Where your personal data is no longer needed for the purpose for which it was collected you may request that the data be erased provided that the data is no longer needed to comply with legal or regulatory obligations (see Retention Period).

11.4 Restriction on processing: You have the right to ask us not to process your personal data in the following circumstances:

(a) you believe the data held is inaccurate;

(b) you object to the processing on the grounds that there is no legitimate purpose;

(d) you require the data to be held to defend a legal claim, but require that it is no longer processed.

11.5 Right to object: You can request any direct marketing activity to cease at any time. You also have the right to object to any other form of processing if you have compelling grounds relating to your particular situation. Such requests may however, be refused if there is a regulatory requirement or if required for the defence of legal claims. Please note, however, you cannot opt-out of receiving regulatory or legal updates (e.g., information about a change in the product terms and conditions) by email.

11.6 Fees: There is no charge for you exercising your right to access your personal data and the other rights listed above. However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in those circumstances. In any event, we will inform you of the action we decide to take and why.

12. COMPLAINTS

If you believe that we have processed your data in a way that does not comply with the UK GDPR, you have the right to make a complaint directly to the Information Commissioners Office (the “ICO”), the UK regulator for data protection issues. See the ICO’s website at https://ico.org.uk/concerns or telephone on 0303 123 1113.

13. THIRD PARTY LINKS

13.1 We may occasionally provide weblinks, also known as “hyperlinks” or simply “links” to other companies’ websites.

13.2 We provide these links when we think that the information on other websites may be of interest to you.

13.3 Such websites may have their own privacy policies.

13.4 PM Alpha does not accept responsibility for or liability in relation to such policies.

13.5 Please review these policies before you submit any personal data to such websites.

14. CHANGES TO THE POLICY

14.1 We know that you are concerned with how your personal data is dealt with.

14.2 Any future changes to our Privacy Policy or to other policies found on this site and / or the Platform will be posted to the relevant pages, and where appropriate, notified to you by email.

14.3 This Privacy Notice sets out our current policies and demonstrates our commitment to your financial privacy.

14.4 We may change the content or services found on our Site at any time without notice, and consequently our Privacy Notice may change at any time in the future.

15. CONTACT DETAILS

If you have any questions, comments and request in relation to this Privacy Notice, please contact PM Alpha at support@pmalpha.co.uk.

1. INTRODUCTION

1.1 Private Markets Alpha Limited (“PM Alpha”) is an appointed representative (Firm reference number: 970004) and can act on behalf of its principal firm, Blackheath Capital Limited. PM Alpha is incorporated in England and Wales (Company Number: 13704424) with its registered office address at 11 Blackheath Village, London, United Kingdom, SE3 9LA.

1.2 In these terms, references to “us” and “we” refer to PM Alpha and references to “you” and “your” refer to any person accessing (or attempting to access) or using the Private Markets Alpha Limited Platform (the “Platform”).

1.3 PM Alpha is committed to protecting your privacy as the controller and ensuring you are fully aware of the information we may hold on you and how that information may be used in the course of providing products and services to you. This Privacy Notice (together with our Terms) explains how we collect, process and safeguard your personal data.

1.4 By accepting our Terms and / or by using the Platform, you are acknowledging and accepting the practices described below.

2.INFORMATION WE COLLECT

2.1 We collect, use, store and transfer personal data. This includes gathering information from publicly available sources (for example, LinkedIn and company websites for client verification) and the collection of physical forms of identity and address verification from you such as copies of passports, driving license or other legal documents.

2.2 You may provide additional information by corresponding with us via phone, email, or other means including interactions with our Platform, to which we have granted you access.

2.3 The information we collect may include your (or your client’s) name, address, email address, phone number, financial information, IP address or other relevant personal details. We will avoid requesting or holding sensitive personal data (racial or ethnic origin; political opinions; religious beliefs; trade union membership; physical or mental health or condition; sexual life; criminal offences) except where necessary to comply with our regulatory obligations.

2.4 By sharing these details with us, you confirm that you are entitled to share personal information, and where you are acting in a third-party capacity that you have received the necessary authorisations to share information on behalf of the underlying client.

2.5 Where we need to collect personal data by law, to enter into a contract with you, 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 goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. INFORMATION WE GATHER FROM OTHER SOURCES

3.1 In the process of gathering information about you as a prospective client or providing services to you, we may engage with a range of third-party providers such as credit and fraud prevention agencies in order to gather relevant data about you and your circumstances. These agencies may also give us additional details and information from the Electoral Register in order to aid identify verification.

3.2 If you have authorised a third party to contact us, or authorised us to contact a third party on your behalf, you acknowledge we may receive and store additional information they provide to us. When dealing with any third party in relation to your details we will always undertake a thorough security check prior to any discussion.

4. RETENTION PERIOD

4.1 The period we keep information for is often linked to the amount of time it would take for a legal claim to be made by or against us, which in many cases is six or seven years after you stop being our client.

4.2 We will keep your personal data after this time if we have to do so to keep to the law, if there are existing claims or complaints that will reasonably require us to keep your information, or for regulatory or technical reasons.

4.3 If we do need to keep your information for a longer period, we will continue to protect that information. In some circumstances you may ask us to delete your data (see Your Legal Rights).

5. ELECTRONIC COMMUNICATIONS

5.1 We may monitor or record phone calls, video calls, emails and chat applications in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of products and services, and to help detect or prevent fraud or other crimes.

5.2 Conversations may also be monitored or reviewed for staff training purposes.

6. HOW WE USE YOUR INFORMATION

6.1 We will continually review and assess the quality and quantity of personal data we hold, and observe your rights under applicable privacy and data protection laws.

6.2 Information you give us may be used as set out in the table below, which includes the legal basis we rely on to do so. Please note that depending on the purpose, we may process your personal data for more than one lawful basis. If you would like specific details about the lawful basis on which we rely to process your personal data where more than one ground has been set out below, please contact us using the contact details at the end of this Privacy Notice.

6.3 Generally, we do not rely on consent as a legal basis for processing your personal data although we will obtain your consent before sending third party direct marketing communications to you via email or text message or when you participate in interactive features on the Platform. You have the right to withdraw consent to marketing at any time by contacting us or by following opt-out links within the messages received.

Purpose	Lawful Basis for processing
to allow you to participate in any interactive features on the Platform, which we may make available, should you choose to do so.	where you have provided clear consent and opted into participating in the interactive features on the Platform. • necessary for our legitimate interest (to study how clients interact with the Platform / use our products and services).
to notify you about changes to this Privacy Notice (which will be kept under regular review).	necessary to comply with a legal obligation
to ensure that content of our website or the Platform is presented in the most efficient manner for you and your computer.	necessary for our legitimate interest (for running the Platform efficiently and ensuring you have access to information required with regards to our products and services).
for research and development into improving our products and services that we provide to you e.g., reviewing how you use the Platform and how you participate in the forums on the Platform.	necessary for our legitimate interest (to develop our business and improve our products and services that we provide to you).
to provide you with access to the Platform, information (by various means including but not limited to post, email and phone), products and services that you have requested from us or which we may reasonably believe would be of interest to you.	performance of our contract with you.
to comply with our legal and regulatory obligations.	necessary to comply with a legal obligation.