PRIVACY POLICY
Athla Capital Management Limited, its subsidiaries and associated businesses (‘Athla’ and ‘we’) are committed to protecting your personal data and your privacy.  We endeavour to ensure that any personal data we collect about you will be held and processed strictly in accordance with the Data Protection Act 1998 (DPA) and, on and from 25 May 2018, the European General Data Protection Regulation (GDPR). The terms Personal Data, Data Controller and processing have the meanings given to them in the GDPR (which can be accessed here), unless otherwise indicated.
At Athla we collect and process Personal Data in a number of ways.  For instance, please see the below:
a. You are browsing our website, enquiring about our services; receiving our marketing communications, responding to one of our surveys or otherwise interacting with us as a prospective, current or former customer other than in connection with ongoing services we are providing to you or your organisation;
b. You are a client of Athla;
d. You are applying for or enquiring about a job at Athla
e. You are an employee or contractor of Athla
f. You are a supplier or service provider to Athla

1. Scope

This Privacy Policy demonstrates how Athla handles the Personal Data you provide to us, or which we collect about you, in the following ways (Your Data):

• by you submitting information to us through our website www.athlacapitalmanagement.com or when you subscribe to our newsletter and or blog (Website User Data);
• through your use of our other marketing resources, such as events or webinars which we run or sponsor (Marketing Data);
• from what we learn about you from your visit to our websites (Website Background Data); and/or
• by you otherwise interacting with us a prospective, current or former customer, (for example, where you provide your business card to us) other than in connection with ongoing services we are providing to you or your organisation (Prospect Data).

This statement does not apply to:

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  • the collection and processing of Personal Data in the course of providing investment or regulatory or other services to our clients. For information about privacy in the context of services provided to our clients, please contact the relevant Athla person responsible for your matter.
  • the collection and processing of Personal Data about our employees or contractors. For information about privacy in the context of doing work for Athla please contact us.
  • the collection and processing of Personal Data in relation to job candidates or applications for roles advertised on this website. For information about privacy in this context, please contact Athla.
  • the collection and processing of Personal Data on our suppliers or service providers. For information about privacy in this context, please contact Athla.

2. Identity and Contact Details of Data Controller
For the purposes of the DPA and the GDPR, Athla is the controller of Your Data.  If you have any queries regarding this policy or complaints about our use of Your Data, please contact us at info@athlacapitalmanagement.com or at the address below and we will do our best to deal with your complaint or query as soon as possible.
Athla Capital Management Limited
107 North Street, Martock, Somerset, TA12 6EJ
FAO: Data Processing
3. What we use Your Data for
The table below sets out the purposes for which we may process Your Data and the legal basis for the processing:

Data	Purpose	Legal Basis
Website User Data Marketing Data Prospect Data	To keep you informed of any activities undertaken by us which we believe may be of interest to you and this use may include sending you email and postal marketing from time to time or requests to respond to a survey	Consent – this will be requested either when you submit Your Data to us or, if we have received Your Data indirectly, by way of an email sent prior to us sending you any marketing communications.
Website User Data Website Background Data	Website analytic purposes.  For further details on the technology we use in order to analyse our website’s performance, please see our cookies policy here.	Consent – this will be obtained when you click on the banner at the top of our website to accept certain cookies. Legitimate interest of LOTIUC (see our cookies policy for further information)
Website User Data Marketing Data Prospect Data	To provide you with the newsletter(s) or information you have requested	Performance of a contract
Website User Data Marketing Data Prospect Data Website Background Data Prospect Data Survey Data	To respond to requests for information from regulated bodies or government agencies	Compliance with a legal obligation
Website User Data Prospect Data	To respond to an enquiry you have submitted	Legitimate interest of Athla – it may be necessary for us to process Your Data in order to reply or respond to your enquiry

4. Who we share Your Data with
Please note that we may on occasion be required to share your information with the following categories of recipients:

• We will be a data controller in respect of any such personal information about you.  In certain circumstance we may need to share your personal information with our Principal Firm, Frank Investments Limited. Our Principal Firm will also be a data controller in respect of any such personal information about you, and they will process such information in order to meet their requirements under the rules of the FCA.

• Third parties who provide services on our behalf. For example, we use third parties such as MailChimp https://support.squarespace.com/hc/en-us/articles/360000851908-GDPR-and-Squarespaceand to provide marketing automation services.  Our A full list of all our third-party service providers is available on request.

We have taken steps to ensure that all such entities keep Your Data confidential and secure and only use it for the purposes that we have specified and have informed you of.  Our service providers are subject to data processing agreements which are, or are in the process of being updated to become, compliant with the requirements set out in the GDPR.  Further details regarding any third parties who are located outside the EEA are set out in paragraph 5 below.
In relation to any other third parties, we will only disclose your information in the following circumstances:

• where you have given your consent;
• where we are required to do so by law or enforceable request by a regulatory body;
• where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights; and
• if we sell our company, go out of business, or merge with another company.

5. International Transfers
In certain circumstances, we may transfer Your Data to countries outside the EEA, which may not adhere to the same levels of data protection to which countries within the EEA are subject.  Any such transfers are, at all times, made in accordance with the DPA and the GDPR.  Details of the circumstances and mechanisms in place to ensure compliance are set out below:
6. Retention Period
Your Data will be stored for a maximum period of 6 years, after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained. If you consent to marketing, any information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information. unless we request your consent to store it for a longer period.
7. Your Rights in Relation to Your Data

• Under the GDPR, you will have the following rights in relation to how we process Your Data:
  • Right to request access – you may obtain confirmation from us as to whether or not Your Data is being processed and, where that is the case, access to Your Data.
  • Right to rectification and erasure – you have the right to obtain rectification of inaccurate personal data we hold concerning you and to obtain the erasure of Your Data without undue delay in certain circumstances.
  • Right to restriction of processing or to object to processing – you may require us to restrict the processing we carry out on Your Data in certain circumstances or to object to us processing Your Data.
  • Right to data portability – you have the right to receive Your Data in a structured, commonly used and machine-readable format.
  • Right to withdraw consent – where you have provided your consent to us processing Your Data, you have the right to withdraw your consent at any time. This can be done by emailing info@athlacapitalmanagement.com at any time or by clicking the “unsubscribe” link on any marketing communications you receive from us.
  • Right to lodge a complaint – you may lodge a complaint with any supervisory authority in the EU. The supervisory authority for the United Kingdom is the Information Commissioner’s Office.

For further information on your rights, please see the Information Commissioner’s website here.
8. Additional Information

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  • There is no statutory or contractual requirement for you to provide Your Data to us and you are not obliged to do so. Please note, however, that we may not be able to provide you with the services you have requested, such as to receive our newsletter and or blog, if you do not provide your contact details.  As set out in our cookies policy, our website may not be able to function fully if you do not agree to certain cookies being set on your computer.
  • We do not undertake automated decision-making or profiling on Your Data.
  • We keep our privacy policy under constant review and may change it from time to time to reflect our practices or to remain compliant with relevant legislation. We will notify you of any material changes to our privacy policy via a notification on our website. Your continued use of this website or our other marketing services, following the posting of changes to these terms, will mean you accept these changes

9. Security of Personal Information
We recognise the need to ensure that personal information gathered via this website remains secure. Our site has security measures in place to protect against the loss, misuse and alteration of the personal information under our control. Our security measures include the use of a hardware firewall to prevent unauthorised access. You acknowledge that although we exercise adequate care and security there remains a risk that information transmitted over the Internet and stored by computer may be intercepted or accessed by an unauthorised third party.
11. Data Obtained Indirectly
In some circumstances, we may obtain Personal Data about you from other sources.  This information may include your name, contact details and job title, which we obtain from third party sources such as organisers of events we sponsor or other publicly available sources, such as your company’s website.
12. Links
Our website contains links to other websites belonging to third parties. We do not control the privacy practices of these other websites. You should therefore make sure when you leave our website that you have read that website’s privacy policy.
The Information Commissioners Officer (‘ICO’) is the supervisory authority in the UK for data protection.  You may contact them should you have a complaint to make regarding the treatment of your personal data.
Website: https://ico.org.uk/global/contact-us/
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113