We are committed to protecting and respecting your privacy and personal data, and to complying with our legal obligations.
When we refer to our “website” we mean https://globacap.com including the investment, administration and management platform available through the website or any of its sub-domains or pages. References to “we”, “our” or “us” is to Globacap Limited, operating under the name of Globacap.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as set out below, together with some examples of each type of data.
Globacap will be the ‘data controller’ of this personal data that it collects and processes.
We do not routinely collect any ‘sensitive’ information about you, such as about your race or ethnicity, religious or philosophical beliefs, health, sexual orientation, political opinions, and so on. Nor do we collect any information about criminal convictions and offences other than for the purposes of employee screening where permitted. If you do give us ‘sensitive’ information we will only use this information strictly in accordance with the law.
This website is not intended for children and we do not knowingly collect data relating to children.
We use different methods to collect data from and about you. These include”
You or persons acting on your behalf may give us your data including if you or they:
Our clients. Clients or customers of our products may provide your personal data to us. An example could be where we administer the share register of a company, that company may provide us with your personal data (e.g. your name, address, and/or bank details).
Third parties or publicly available sources. We will receive personal data about you from various third parties such as credit-reference agencies, fraud-prevention agencies, analytics providers, and partners who help us to provide our services. We may also obtain data from publicly available sources such as Companies House or electoral registers.
Where we need to collect personal data and you fail to provide that data when requested, we may not be able to provide services to you or perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In some circumstances we may have to cancel a product or service you have with us or cease providing a service we were providing to you.
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:
You will receive marketing communications from us if you have requested information from us, signed-up for our newsletter, created an account on our website, or otherwise have provided your information or data to us and you have not opted out of receiving that marketing.
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 products, services and offers may be relevant for you (we include this in marketing).
Communications that are required by law or that we are making on behalf of third parties (for instance a communication to you as a shareholder of a company who utilises our platform) are not considered “marketing” for these purposes. Any opt-out (see below) will not affect or restrict our ability to send those types of communications to you.
We will get your express opt-in consent before we share your personal data with any third party for their own marketing purposes (other than marketing agencies or consultants working for us to market our products or services).
You can ask us or third parties to stop sending you marketing at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will only apply to receipt of marketing messages and will not apply to personal data provided to us as a result of a product or service that we provide to you or other interactions with our website.
We may share your personal data as permitted by this policy or by law, including with
We might transfer and store the data we collect from you somewhere outside the European Economic Area (‘EEA’). People who work for us or our suppliers outside the EEA might also process your data. We may share data with organisations and countries that The European Commission say have adequate data protection, or with whom we’ve agreed standard data protection clauses with.
We have 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 comply notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for or to comply with our legal obligations.
Where you are a client, we will keep your data for as long as you are a client and for six (6) years after that to comply with our legal obligations (including regulatory, tax, accounting or reporting requirements) (or such longer period as may be required by law). 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.
In other circumstances, 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. Our standard retention period is six years. Details of retention periods for different aspects of your personal data are available on request.
In some circumstances we will 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.
You have a right among other things to:
Please note that there may be circumstances where we are entitled to refuse your requests, for instance where we have a legal obligation to retain information.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
We’re registered with the Information Commissioner’s Office (ICO) under number ZA559999.
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.