Privacy Policy.

Last updated 02/02/2022

Leela Capital Limited (registered number 12110593) (“us”, “our”, “we”, “Leela Capital”) is the controller of your personal data collected through https://www.leelacapital.com/ (“Website”). Leela Capital is committed to protecting and respecting your privacy. 

This privacy policy (the “Policy” or “Privacy Policy”) sets out the types of personal data we collect and use when you access and visit the Website and how we may use that data.

1.   Introduction

This Privacy Policy explains who we are, why and how we process personal data collected through your use of the Website and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to. 

For ease of reading, we have divided this Policy into several sections:

1.   Introduction

2.   What personal data do we collect?

3.   How is your personal data collected?

4.   How and why do we use and share your personal data?  

5.   For how long do we keep your personal data?

6.   Security

7.   International Data Transfers

8.   Your Rights

9.   Contact Details

It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Website at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.  

This Policy supplements other notices on the Website and is not intended to override or replace them. 

By visiting or otherwise using the Website, you confirm that you have read and understood this Privacy Policy. If, for any reason, you do not agree with this Privacy Policy, please stop using the Website.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law.  Where these changes are significant, we will endeavour to let users of the Website know. However, it is your responsibility to check this Privacy Policy before each use of the Website. For ease of reference the top of this Policy indicates the date on which it was last updated.

This Website is not intended for children, and we do not knowingly collect data relating to children. 

2. What personal data do we collect? 

What is personal data?

Where this Policy refers to ‘personal data,’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address. It does not include data where the identity has been removed (anonymous data).

What types of data we collect from you when you use the Website?

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

• Identity Data which includes your name.

• Contact Data which includes your e-mail address and phone number.

• Technical Data which includes your IP address and browser type and version. 

• Usage Data which includes information about how you use the Website.

• Marketing and Communications Data which includes your preferences in receiving marketing from us and our associated third parties.

3.   How is your personal data collected? 

Direct interactions

We will collect your personal data when you use the Website to complete a form, contact us by email or by post, request marketing be sent to you, browse from page to page, or otherwise  offer your personal data to us through the Website. 

Automated technologies or interactions

As you interact with our Website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. [Please see our cookie policy for further details.]

Third parties or publicly available sources

We may receive personal data about you from various third parties which might include technical support and delivery of services, analytics providers and search information providers).

Updating your information

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you want to update the information you have previously given to us, please contact us. 

4.   How and why do we use/share your personal data?

Lawful basis for processing your information

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 you have asked us to do so, or consented to us doing so (although consent is not necessarily required for us to process your personal data);

• Where we need to perform the contract we are about to enter into or have entered into with you;

• Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and

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

Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so. 

Activity

Examples of the types of personal data we may collect

Lawful basis for processing

To deliver the Website to you.

Identity data, technical data and usage data. 

Performance of a contract with you.

To manage our relationship with you including notifying you of any changes to the Website or services provided on the Website. 

Identity data, contact data and marketing communications data. 

We have a legitimate interest in doing this (to ensure a positive and informed user experience). 

To administer and protect our business and this Website (including troubleshooting, data analysis and system testing.)

Identity data, contacts, marketing communications data, technical data and usage data.

We have a legitimate interest in doing this (to ensure the safety of the Website and our business).

To use data analytics to improve the Website, services, marketing, customer relationships and experiences. 

Technical data and usage data.

We have a legitimate interest in doing this to ensure a positive and informed user experience).

Marketing and Communications 

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you.  This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 Opting Out of Marketing 

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us or the third party directly if you do not wish to receive any marketing materials from us or them. 

Sharing your personal data

Depending on how and why you provide us with your personal data we may share it in the following ways:

• we may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;

• with selected third parties to which we sub-contract to provide various services and/or aspects of the Website’s functionality, such as where third party plugins provide functionality such as message boards or image hosting services (see “Service Providers” below); and 

• with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above. 

We may also disclose your personal data to third parties in the following events: 

• if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that transaction; 

• if Leela Capital or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers and contacts will be one of the transferred assets; 

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or 

• in order to enforce or apply the terms of use or terms and conditions of sale of our products and services; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers (Data Processors)

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of the types of service providers we use:

• Website Analytics Providers: Square Space

• Website Developers: Square Space and Think Small Do Big

• Website Maintenance Providers: Square Space

• Website Security Providers: Square Space

Links to third party sites 

We may provide links to third party websites, plug-ins and applications that are not affiliated with Leela Capital on the Website. These third party sites are not controlled by us and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies.  Please check these policies before you submit any personal data to those websites. 

Change of purpose

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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5.   For how long do we keep your personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information, although this may not always be possible if we are obliged to retain the data for compliance purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

6.   Security

Leela Capital takes the protection of your personal data very seriously. We have put in place technological and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  

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 any applicable regulator of a breach where we are legally required to do so. 

7.   International Data Transfers

We do not currently transfer your personal data outside the UK. 

In the unlikely event we do transfer your personal data outside the, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or 

• We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

8.   Your Rights

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access

You may, request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Your Right to Correction 

You may request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Your Right to Restrict Processing

You may request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Your Right to Portability

You may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Your Right to object to processing

You may object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you. 

Withdraw consent, where consent is the lawful basis for processing

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

9.   Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, you can contact us by: 

• emailing us at: info[@]leelacapital.com

• Writing to us at: 2 Portman Street, London, W1H 6DU.