We may hold your personal information, including sensitive personal information (being information concerning an individual’s (i) racial or ethnic origin, (ii) political opinions, (iii) religious beliefs or other beliefs of a similar nature, (iv) membership of a trade union, (v) physical or mental health or condition, (vi) sexual life or orientation, and/or the (vii) commission or alleged commission of any offence or any proceedings for any offence) because:

• you supplied it to us (e.g. sending us emails, contacting us via telephone or our website);
• we learned it from someone else, either in the context of providing services to our clients or in the context of our business more generally (e.g. a company that we are advising in relation to a transaction may provide your personal information to us for the purpose of enabling us to carry out due diligence on a business or advise on a transaction);
• it is publicly available.

The personal information will generally consist of your name, business to business contact information and your job title, but may from time to time include further information such as (depending on context), “know your client” and anti-money laundering information the law requires us to collect in relation to clients and CCTV footage, food allergy and access information in respect of visitors to our offices.

Where you apply for a job with us, we may collect from you and third parties (where relevant) additional personal information such as your CV, results of any pre-employment checks, information relating to your right to work and any references.

We will only use personal information which is provided to us, or otherwise obtained by us, as set out in this Privacy Statement, and in accordance with applicable data protection legislation. For the purposes of the data protection legislation, Eight Advisory is deemed to be the “data controller” in respect of any personal information that you provide to us or we otherwise obtain about you. Eight Advisory reserves the right to change this Privacy Statement from time to time and you should therefore check this page frequently to ensure that you are happy with any changes.

Where you provide personal information on behalf of another individual (for example, you may send ID data about a colleague for our “KYC” check purposes), you are responsible for notifying that individual that you have provided their personal information to us and directing them to this Privacy Statement so they can see how we will process their personal information.

Where we receive information from third parties who collect personal information from you and pass it on to us the third party is responsible for informing you that they have shared your personal information with us, directing you to this Privacy Statement and obtaining necessary consents (if any are needed) from you to ensure you are happy with the ways in which your personal information will be used.

We will only use your personal information in order to (a) carry out our obligations arising from any contracts; (b) maintain the quality of our website and analyse the use of our website in order to guide improvements; (c) provide our clients with information, products or services and correspond with them; (d) provide support to our clients in respect of our services and solutions; (e) where relevant, process your application for employment; (f) comply with our own legal and regulatory obligations; and (g) for our internal business processes.

We may also use your personal information to contact you in a business-to-business capacity in order to give you updates and information about our services. You may opt out of the business-to-business marketing emails that we occasionally send by following the instructions outlined in the email.

The legal basis on which we process your personal information is primarily for the purpose of pursuing our legitimate interests as a business which provides financial advice and services. In some instances we may rely on your express consent to use your personal information, but we will let you know (and give you the chance to withdraw consent) if we do. In some instances we may use your personal information in order to enable us to perform a contract which we have in place with you.

Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your personal information with our suppliers, contractors, affiliates, professional advisers, regulatory bodies, auditors, technology providers, a third party purchaser of all (or most) of our business and/or assets, and/or third party partners and any duly authorised agents or related, associated or affiliated companies of the foregoing.

Eight Advisory may also disclose your personal information where required to do so by applicable law, by a governmental body or by a law enforcement agency, or to enforce an agreement or protect the rights, property or safety of Eight Advisory, Eight Advisory’s group companies and our contractors, directors, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention.

In processing your personal information, it will sometimes be necessary for us to transfer your personal information to a destination outside of the European Economic Area (“EEA”) in connection with the above purposes. Where we do so, we will only transfer your personal information to third parties outside the EEA if that third party (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to personal information, (b) has agreed (by some form of data transfer mechanism approved by the European Commission) to provide all protections to your personal information as required by data protection legislation, (c) we have your explicit consent to do so or (d) we otherwise have a legal basis for such transfer. Where any transfer takes place under a written contract, you have the right to request a copy of the safeguards included in that contract and may do so by contacting us at UK@8advisory.com. For the avoidance of doubt, in the event that the UK is no longer a part of the EEA, references in this paragraph to the EEA shall mean the EEA and the UK.

We will only keep your personal information for as long as we reasonably require and, in any event, only for as long as data protection legislation allows.

You have the following rights:

• the right, subject to certain exemptions, to be provided with copies of personal information that Eight Advisory holds about you, together with information about how it is processed, free of charge;
• the right to ask us to correct or complete personal information which is inaccurate or incomplete;
• the right to ask us to delete or cease processing of the personal information that we hold about you in certain circumstances;
• the right to ask us to send you, or another organisation, certain types of personal information about you in a format that can be read by computer; and
• the right to opt out of any marketing communications that Eight Advisory (or any third party to whom they have disclosed your personal information with your consent) may send you.

If you wish to exercise any of the above rights, or should you have any queries or complaints in relation to how we use your personal information, please contact us at UK@8advisory.com. Should you wish to take any complaints or queries further, you have the right to contact your local data protection authority regarding such issues (such as the Information Commissioner’s Office in the UK).

A cookie is a small file that, if you consent to it, is sent to your browser from our web server and is stored on your computer. Cookies help us to analyse web traffic and identify which pages of our website are being used. Our website also uses cookies to respond to you as an individual so that it can tailor its operations to your needs by gathering and remembering information about your preferences. We only use this information for statistical analysis purposes and then the data is removed from our systems. A cookie in no way gives us access to your computer or any information about you, other than information about how you use the website and the data you choose to share with us (including data you automatically share with us by way of your browser settings).

In particular, we use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website.
• Analytical/performance cookies. These cookies collect information about how visitors use our website, for instance which pages visitors go to most often, and if they get error messages from web pages. Information collected by these cookies is aggregated and therefore anonymous. It is only used to improve how the website works.

You may see a message on our website before we store a cookie on your computer which describes the types of cookies we use and what information they might collect. We may also use banners and pop-ups from time to time to give you options around cookies use.

You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings. Note, however, that if you block all cookies (including essential cookies) via your browser settings you may not be able to access all or parts of our website.

You can find more information about cookies generally here: www.allaboutcookies.org.