Privacy Policy

Sphera Partners LLP (“Sphera”, “we” or “us”) is committed to protecting the privacy and security of your personal information in accordance with applicable UK data protection laws, including the General Data Protection Regulation (the “GDPR”).

This Privacy Notice sets out the basis on which we may process your personal data during the course of our business relationship, including through your use of our website, when you contact or request information from us, when you engage with us professionally or as a result of your relationship with one or more of our staff.

PURPOSE OF THIS PRIVACY NOTICE

This Privacy Notice describes how Sphera collects and uses your personal data.

Sphera is a “Data Controller”. This means that we are responsible for deciding how we collect and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.

We have appointed a person responsible for Sphera’s compliance with the applicable data protection legislation. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact:

Nicki Boyd
nicki@spherapartners.com
One St Peter's Square, Manchester, United Kingdom, M2 3DE

THE DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Basic information: such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person.

Contact information: such as your postal address, email address and phone number(s).

Financial information: such as payment-related information.

Technical information: such as information from your visits to our website such as internet protocol (IP) addresses, 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.

Identification and background information: provided by you or collected as part of our business acceptance processes.

Marketing and communications information: such as your preferences in receiving marketing from us and your communication preferences.

Any other information: relating to you which you may provide to us.

HOW WE USE YOUR PERSONAL DATA

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

Where we need to perform our contractual obligations towards you.

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.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a lawful basis for processing your personal data.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data under more than one lawful ground, depending on the specific purpose for which we are using your data.

Provision of services to you: providing you with services that you have requested; providing you with promotional items at your request; and communicating with you in relation to those services. Lawful ground: performance of a contract.

Compliance checks: fulfilling our compliance obligations, including ‘Know Your Client’ checks; confirming and verifying your identity; and screening against government and/or law enforcement agency sanctions lists and other legal restrictions. Lawful ground: compliance with a legal obligation.

Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person), news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. Lawful ground: legitimate business interests.

Communications and IT operations: management of our communications systems; operation of IT security systems; and IT security audits. Lawful ground: legitimate business interests.

Financial management: sales; finance; corporate audit; and vendor management. Lawful ground: legitimate business interests.

Please note that 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.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of our business relationship.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with third parties such as our agents and service providers; our regulators, including the Financial Conduct Authority; and law enforcement agencies in connection with any investigation to help prevent unlawful activity.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We may need to transfer your personal data outside the European Economic Area. We will ensure that any transfer of your data will be subject to appropriate safeguards, and we will ensure you have appropriate remedies in the unlikely event of a security breach.

DATA SECURITY

Sphera has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner’s Officer (the “ICO”), the UK supervisory authority for data protection issues, of a breach where we are legally required to do so.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred via the internet. If you have any particular concerns about your information, please contact us at info@spherapartners.com.

DATA RETENTION

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, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we process your personal data and whether we can achieve those purposes through other means; and the applicable legal requirements.

YOUR LEGAL RIGHTS

Under certain circumstances, by law you have the right to request access to your personal information; request correction of the personal information that we hold about you; request erasure of your personal information; object to processing of your personal information; and request the restriction of processing of your personal information.

NO FEES USUALLY REQUIRED

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

RIGHT TO COMPLAIN

If we have not dealt with your concerns appropriately, you have the right to make a complaint at any time to the ICO (www.ico.org.uk).