ASHBOURNE CAPITAL SOLUTIONS – PRIVACY NOTICE

This privacy notice explains how and why Ashbourne Capital Solutions (“ACS”) collects, processes and protects your personal data. Please be assured that we are committed to protecting your privacy.

If you have any queries regarding this privacy notice then you can contact us by email at[email protected] or by post at:

Ashbourne Capital Solutions
6th Floor, 9 Argyll Street, London W1F 7TG

1. Why we process your data, the lawful basis for processing your data and who we share it with

For our clients, and in the case of clients who are organisations for the people who we interact with, we process data:

in order to provide you with trust and company service provider services to include filing relevant forms with the Companies Registration Office;
to provide you with accounting services including liasing with your Auditors;
to provide you with administration services including filing Vat returns with the Revenue Commissioners;
to provide you with payroll services including filing PAYE returns with the Revenue Commissioners;
to respond to your query when sent through our ‘contact us’ form;
or for purposes related or ancillary to any of the

The data we collect and process includes information you give us and this may include:

your name, address, email address and/or telephone number;
your employer details;
identification documents such as a copy of your passport, driving licence and/or utility bills;
financial information such as source of funds, source of wealth, bank records and tax information;
salary details; or
information relating to your circumstances that you provide as part of your instructions.

If any such information changes then you should let us know so that we can keep our records accurate and up date.

The legal basis for the processing of this data is processing necessary for the performance of a contract to which you are a party. Without doing so we would not be able to provide you with the services for which you have engaged us.

Further, we process your personal data where it is in our legitimate interests to do so and this includes:

to properly provide the services that have been requested;
to carry out conflict checks;
to manage our relationship with you or the organisation of which you are a part;
to protect our own legal rights; or
to comply with our legal and regulatory obligations, e.g. anti-money laundering legislation.

There may also be limited circumstances where our legal basis for processing is your consent (where we have sought it and you have provided it to us), in which case you can withdraw your consent at any time.

We share this data within our business relationship team. We may also send you emails through our email service provider. They may only process this data for the purpose of providing us with their services, and no other purpose.

We may also share certain parts of this data with third parties including regulators, suppliers and service providers, government agencies and public bodies.

We will retain this data for as long as required for the purposes set out above or as long as required to comply with any legal obligations to which we are subject.

For our potential, current and past clients, we may also process data:

in order to market the services of our firm;
to provide you with updates and newsletters to which you have subscribed;
to invite you to events, seminars and meetings

The legal basis for this processing is our legitimate interest in the administration and operation of our services as well as our legitimate interest in marketing and promoting our firm’s services. We always include an unsubscribe button in our communications, so you can opt out of receiving such communications at any time.

We will retain this data for no longer than seven years from collection.

2. Information received from third parties and the source of that data

We may collect information about you from sources such as other third parties you have engaged in relation to the services and publicly available information about you including public registers, media publications.

3. Transfers of data outside the European Economic Area

We do not presently transfer any data outside of the European Economic Area but in the event that we are required to do so for any of the purposes set out above then the safeguard we will put in place for this transfer will be to enter into European Commission approved standard contractual clauses with the provider.

4. Your rights relating to personal data

You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:

right to access the data – you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal
right to rectification- you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is
right to erasure – you have the right to request us to delete personal data that we hold about This is sometimes referred to as the right to be forgotten.
right to restriction of processing or to object to processing – you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
Right to data portability – you have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable

In order to exercise any of the rights set out above, please contact us at the contact details at the start of this privacy notice.

If we are processing personal data based on your consent only, you may withdraw that consent at any time. This does not affect the lawfulness of processing which took place prior to its withdrawal.

If you are unhappy with how we process personal data, we ask you to contact us so that we can rectify the situation.

You may lodge a complaint with a supervisory authority. The Irish supervisory authority is the Data Protection Commission.

5. Protection of your personal data

We use technological and operational measures in order to keep your data secure, accurate and up to date.

Although we use appropriate security measures the transmission of data over the internet, including via email, is never completely secure. While we endeavour to protect personal data we cannot guarantee the security of data transmitted by us or to us over the internet and any such transmission is at your own risk.

6. Requirement to process personal data

If you do not provide us with your information for the purposes described above, we cannot provide you with any of our services or comply with our legal and regulatory obligations.

7. Automated decision-making and profiling

We do not use any personal data for the purpose of automated decision-making or profiling.

Cookies

Cookies and how we use them

Cookies are small files which may be placed on your computer hard drive or other device used to access a website and are widely used in order to make websites work or work more efficiently and to provide information to the operator of the website.

The cookies used by the site are divided into three categories:

Necessary Cookies

These cookies are required for the operation of the site and to enable you to move around the site and use its features. These cookies do not collect information that identifies individual users.

Performance/Analytical Cookies

These cookies collect information (including the IP address of the computer or device used to access the site) about how visitors use the site, for example, the pages that are visited most often, where visitors have come from and the pages they have visited. The information is used to improve the way the website works. We sometimes use third parties to perform these services for us and when this is the case, the cookies may be set by the third party. This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.

Functionality Cookies

These cookies recognise you when you return to the site. This enables us to remember your preferences (for example, fields in webforms) and improve your user experience. These cookies do not collect information that identifies individual users.

How to Control Cookies The Help menu of most web browsers will tell you how to control cookies – for example, how to refuse cookies and how to delete cookies that have already been set. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org or www.aboutcookies.org. Please Note: restricting cookies will impact your use and/or the functionality of the site.