BCP Privacy Policy 2024

This notice describes how and when Boutique Capital Partners Limited (“BCP”) uses personal data (including any data provide through this website or in other ways – see below). It outlines BCP data protection obligations and your data protection rights under the UK General Data Protection Regulation 2018 (“UK GDPR”) and Data Protection Act 2018 (“DPA”). It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Rodger Kennedy of BCP is a Consultant to GemCap UK. GemCap UK Limited (FRN 924419) is an appointed representative of Connexion Capital LLP (FRN 480006), which is authorised and regulated by the Financial Conduct Authority and provides Distribution Oversight to BCP which is acting as a Distributor and is responsible for the oversight of all distribution arrangement for the sub-funds it promotes.

Boutique Capital Partners Limited is a limited company registered in England and Wales (no. 15755691). Registered Office: 54 Lillieshall Road, London, SW4 0LP.

Our policy is to protect your privacy and your personal information. This Privacy Policy sets out the information we collect from you in order for you to use our services, how we manage that data and our reasons for holding it. We respect the confidentiality of your information and your right to privacy. We are bound by the UK GDPR and relevant laws and regulations.

From time to time, we may update this Privacy Policy and will notify you of these changes by posting the updated terms on our website www.boutiquecapitalpartners.co.uk

BCP is the data controller of your personal information, and this policy applies to the processing of activities by us.

Collection of your data

As part of providing our services, or information about our services, to you, and to ensure we do this in a compliant way, under the authorisation of our regulator and the UK GDPR, we must collect some personal information from our clients, potential clients, visitors to our website and service providers or suppliers. This may include third parties carrying out credit or identity checks on our behalf. The credit search is required to adhere to money laundering regulations.

We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our products and services which you might have expressed interest in. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have consented to them doing so. It is in our legitimate interest to use your personal information in such way. If you do not wish to receive this information, please contact us by emailing info@boutiquecapitalpartners.co.uk or by writing to us at the following address:

Boutique Capital Partners Limited,54 Lillieshall Road, London,SW4 0LP

Our web pages and emails may contain cookies, web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence.

Information collected

We may collect, use, store and transfer the following types of information from actual or potential customers:

Your full name, address and contact information including but not limited to phone number and email address.
Your date of birth and gender.
Your professional and employment details.
Your identification details such as your passport or driver’s licence.
Your tax residency and/or nationality.
Proof of address such as a bank statement or utility bill.
Your national insurance or tax identification number.
Criminal convictions data.
Corporate information.
Information about your income or the source of your funds and wealth including details about your assets and liabilities.
Your trading experience and transaction history.
Financial information including investment portfolio details, income levels, taxation details.
Information regarding relationships you have with banks and/or other financial institutions (including bank details).

We obtain this information through your use of our services or our websites, the onboarding process and from information provided in the course of ongoing customer communication.

This information is held by us on servers based in the United Kingdom. When you interact with our services, our servers may keep an activity log unique to you that collects certain administrative and traffic information including: the source of your IP address, the time of access, the date of access and the web pages you visited. We need this information to provide you with our services.

We are required to collect information about visitors to our premises. We may record information if you visit us, such as your name, the date and time you arrived and left, who you visited, your firm or employer name and your contact details.

We may record any communications, email, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and constitute evidence of the communications between us. Any telephone conversation may be recorded without the use of a warning tone or any other further notice.

We take care to ensure your personal information is safe, secure and is protected from misuse, interference, unauthorised access, loss, modification or disclosure. Your personal information is generally stored in our computer database. Any paper-based information is stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:

Passwords are required to access the system and passwords are routinely checked and are not shared.
Data ownership is clearly defined and data is only held where necessary.
Employees have restricted access to certain sections of the system.
The system automatically logs and reviews all unauthorised access attempts.
Unauthorised employees are barred from updating and editing personal information.
All computers which contain personal information are secured both physically and electronically.
Data is encrypted during transmission over the network; and
Print reporting of data containing personal information is limited.

We train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties where necessary.

When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records. We may need to hold some information and maintain certain records for up to 7 years after the end of us providing services to you. This is because we are subject to regulatory requirements and anti-money laundering laws which require us to retain, for a period of seven years after our business relationship with you has ended:

The length of time that we retain your personal data will depend on the specific type of information contained therein. However, BCP will not retain your personal data longer than is reasonably necessary to provide you with requisite services to meet your financial goals and needs, and to fulfil our obligations to you. We may also retain your personal data to the extent necessary to meet our legal obligations related to certain accounting, reporting and record keeping requirements.

Collection of personal information

We may collect personal information about you from a third party or parties or share information with a third party, such as identity verification services, regulators, an introducing broker, marketing agencies, online vendors and service providers. We may engage the services of third-party service providers to provide technical support, process your online transactions and maintain your account. We take steps to ensure that our arrangements with third-party service providers and online vendors protect your privacy and that any such party is subject to the General Data Protection Regulations. Any personal information will only be disclosed to third parties in accordance with this Privacy Policy. We will not sell, lend or rent your personal information.

We may be required to disclose your personal information if requested to do so by law, or if we believe in good faith that such action is necessary:

To comply with any legal process served on us or in circumstances where we are under a similar legal or regulatory obligation.
To protect and defend our rights or property; or
To act to protect the personal safety of users of the services or the public. If, in our sole determination, you are found to have cheated or attempted to defraud us, our Affiliates, or any other user of the Services in any way including, but not limited to, market or price manipulation, payment fraud, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering).

Where required to disclose information we reserve the right to share information, together with your identity with other financial services providers, banks, credit card companies, and appropriate regulatory and legal agencies.

Transfer of personal data abroad

We may on occasion need to transfer some of your information to other group companies or service providers in countries in or outside the EEA (European Economic Area). This may happen if our servers or suppliers and service providers are located elsewhere. When we transfer your personal data outside the EEA, we will ensure the data recipient is subject to the same data requirements under UK GDPR and DPA. By using our services and providing us with your information, you consent to the collection, transfer, storage and processing of your information outside of the EEA.

Your personal data rights

You have the right to be informed,
You have the right to check what personal information is held by us, at no cost,
You have the right to have wrongly recorded data amended,
You have the right to “be forgotten” I.e the removal of your data,
You have the right to “Opt out”,
You have the right to object to the processing of your personal information,
You have the right to request the restriction of the processing of your personal information,
You have the right to request the transfer of your personal information,
You have the right to withdraw your consent.

For your convenience, BCP provides allows you to opt out of sharing your information in the above circumstances and as permitted by law. You may send an email to us at: info@boutiquecapitalpartners.co.uk with your name requesting that your name be added to BCP’s “Opt Out” list.

European Union

Under the EU General Data Protection Regulation (“GDPR”), EU Data Subjects are entitled to certain additional rights with respect to their personal data, subject to certain restrictions and limitations. In addition to the “Opt out” rights described above, these rights include the following:

The right to object or restrict the processing of your personal data, including for marketing purposes;
The right to access, rectify or erase your personal data;
The right to request that a copy of your personal data be provided to you, or to a third party, in an electronic format; and
The right to file a complaint about the processing of your data with your local data protection authority.

EU Data Subjects may elect, at any time, to exercise any of the foregoing rights with respect to their data. You may do so by emailing us at: info@boutiquecapitalpartners.co.uk

Please note that our ability to maintain your account will be impacted if you exercise your right to object to the processing of your personal information. Further, if you request that your personal information be deleted, we will no longer be able to maintain your account. In addition, please note that our compliance with such a request will not extend to data that we are required to maintain as part of our legal and regulatory recordkeeping requirements. We will, however, delete all information subject to such a request once the term of those requirements has expired.

Concerns or complaints

If you are concerned about us any aspect of our conduct regarding your privacy, you can make a complaint. We will act upon it promptly. To make a complaint, please e-mail us at info@boutiquecapitalpartners.co.uk. We will respond and address, without delay, any request, question, complaint or enquiry you have about your personal information or our conduct in processing it. If you are not satisfied with the way we handled your response, or you believe we have not adequately resolved a matter, you have the right to complain to the Information Commissioner’s Officer (the ‘ICO’). You can find further details on the ICO website at https://ico.org.uk/

You also have the right, at any time, to complain to the ICO. As an independent UK authority, the ICO upholds information rights in the public interest, promotes openness by public bodies and data privacy for individuals.

Boutique Capital Partners Limited is registered with the Information Commissioner’s Office, Registration Number: C1560791. We can be contacted at our registered address:

Boutique Capital Partners Limited

54 Lillieshall Road, London, SW4 0LP