This privacy statement explains how and why Warren Private processes personal data we collect from and about you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how it will be treated.
Warren Private is an investment and advisory company that is responsible for your personal data. As part of our activities, we may establish nominee companies and Special Purpose Vehicles (“SPV’s”) to manage investments on your behalf. References in this privacy statement to “Warren Private”, “we”, “our” or “us” includes these nominee companies and SPV’s. Each of these entities is committed to protecting your privacy.
How we collect your data
When you or an organisation with which you are connected (e.g. your employer) engages us for investment, advisory or other services, we may collect certain personal data directly from you, your organisation and/or from publicly available resources (e.g. company filings).
Data we collect and process
We collect and process data that you provide to us. This is information about you that you give us by corresponding with us by phone, e-mail or otherwise. It includes the information you supply us with when you engage us to provide investment and advisory services. The information you give us may include, but is not limited to:
- Your name, address, e-mail address, phone number;
- Documents confirming your identity such as your passport or driving licence;
- Your employer, your job title and/or position;
- Financial information, including information necessary to make or receive payments to and from you and for the purposes of fraud prevention;
- Your status as a director of a company;
- Your status as a beneficial owner of a company.
Depending on the circumstances, we might also obtain personal data about you from other sources such as public registers, government and regulatory authorities, business partners, financial and insurance advisors, service providers, etc.
You are not obliged to provide us with your personal information. However, if you do not, we might not be able to carry out the services you have requested of us.
Why do we process your data
We process your data in order to comply with legal obligations to which we are subject, to perform the services you have requested of us or to take steps at your request prior to undertaking to provide services for you, because you have consented to our processing of your data or for the purposes of our legitimate interests, such as to inform you of changes to our services or to provide you with information about other investments or services we offer.
How do we use your data
- We gather and use your information to:
- allow us to provide you with the investment & advisory services you request from us;
- comply with legal obligations we might be subject to (such as anti-money laundering);
- provide you with information about other investments or services we offer that are similar to those you have already requested of us or enquired about;
- to notify you of changes to our services;
- to monitor and improve the quality of our services;
- to allow you to participate in events organised by us or our partners.
We may share your data with
We may share your information with agents, contractors or partners of Warren Private in connection with services that these individuals or entities perform for or with Warren Private. These include but are not limited to providers of archiving services, third party consultants, accountants, financial institutions, financial advisors, auditors, the Revenue Commissioners or the CRO.
We may disclose your data in the event that we sell or buy any property or assets, in which case we may disclose your personal data to the prospective seller or buyer of such property or assets.
We may disclose or share your data in order to comply with any legal obligation or in order to enforce or apply our General Terms and Conditions.
Our agents, contractors or partners are restricted from using your data in any way other than to provide services for Warren Private or services for the collaboration in which they and Warren Private are engaged. Warren Private requires that all such agents, contractors or partners enter into contractual guarantees to observe security and privacy obligations at least as stringent as those set forth in this privacy statement.
We take our data security responsibilities seriously, employing the most appropriate physical and technical measures, including staff training and awareness. We review our data security measures and procedures regularly. Unfortunately, the transmission of information by means of the internet, including through email, is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or from us by means of e-mail and any such transmission is at your own risk.
It is our aim to only hold your data for as long as this is necessary. Unless otherwise required under applicable law, we store your data for as long as we provide services to you and for a period of no less than six years beginning on the date we archive your file.
We may contact you by post, email and telephone about our investments and advisory services and other events involving or relating to Warren Private which may be of interest to you. You have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, please send an email to email@example.com with the header “Unsubscribe”.
Where we store your information
We might store your information in different places. Physical files are stored in our office and our archives. Electronic files are stored on our secure servers and in the cloud. We may transfer your data to, and store it at, a destination outside of the European Economic Area. Whenever we transfer your data in such a way, we will ensure appropriate safeguards are in place. You may contact us via post, e-mail or telephone in case you wish to find out more or to obtain a copy of the appropriate safeguards.
You have the right to request that we:
- inform you whether we process your data, provide you with details relating to our processing, and with a copy of your data;
- rectify any inaccurate data we might have about you without undue delay;
- complete any incomplete information about you;
- erase your personal data without undue delay,
- are restricted from processing your data;
- furnish you with the personal data which you provided to us in a structured, commonly used and machine readable format.
Where we process your data solely on the basis of your consent, you are entitled to withdraw your consent at any time. This will not affect the lawfulness of our processing before the withdrawal.
You may exercise your rights in relation to your personal data by contacting firstname.lastname@example.org. The exercise of your rights might be subject to certain conditions prescribed by law and we might require further information from you before we can respond to your request.
If, after contacting us, you are still not satisfied with our response, you have the right to lodge a complaint with the Data Protection Commission.
Amendments to this statement
We may amend this privacy statement on occasion, in whole or part, at our sole discretion. Any changes will be effective immediately, and we will publish such updated version on our website, as appropriate.
To contact us with any queries or comments in relation to your personal data, please: