Privacy notice

About this notice

This Privacy Notice ("Notice") will apply to any personal information Campbell Lutyens & Co. Limited, CL & Co. Management Services Ltd, Campbell Lutyens & Co. Inc (together with their respective subsidiaries and affiliates, "Campbell Lutyens" or "us") collects or otherwise receives about its clients, investors and other third parties ("you"), including in connection with its business dealings, when you access our website 'www.campbell-lutyens.com' ("Website") or otherwise engage with us.

Campbell Lutyens is committed to ensuring that information which is provided to us, or otherwise obtained by us, from which you can be identified or that reasonably relates to you ("Personal Information") is kept safe and handled in compliance with this Notice and the "Data Protection Legislation" (meaning any law applicable from time to time relating to the processing of Personal Information, including without limitation, UK GDPR, the Data Protection Act 2018, General Data Protection Regulation (EU) 2016/679, and the Privacy and Electronic Communications (EC Directive) Regulations 2003).

By using and/or contacting Campbell Lutyens through the Website (or otherwise engaging with us), you acknowledge that Campbell Lutyens may collect, use and transfer your Personal Information as set out in this Notice. Campbell Lutyens reserves the right to change this Notice from time to time and you should therefore check this page frequently to ensure that you are happy with any changes.

Individual California Residents must submit requests to us either by email at cl-dataprivacy@campbell-lutyens.com or by mail or telephone at the following address: Campbell Lutyens & Co. Ltd, 64 North Row, London W1S 3EP Attn: Legal Department +1 (212) 223-8448 or +44 (0)20 7439 7191.

Who we are

In this Notice, "Campbell Lutyens", "we", "us" and "our" refer to the foregoing entities and their respective subsidiaries and affiliates:

• Campbell Lutyens & Co. Limited (company registration number 4112016), a limited company having its registered office at 64 North Row, London W1S 3EP, United Kingdom; Authorised and regulated in the United Kingdom by the Financial Conduct Authority (Ref # 196462). Securities offered through Campbell Lutyens & Co. Inc., Member FINRA; and
• CL & Co. Management Services Ltd (company registration number 2071658), a limited company having its registered office at 64 North Row, London W1S 3EP, United Kingdom; and
• Campbell Lutyens & Co. Inc., a Delaware company that is a registered broker dealer with the Securities and Exchange Commission (SEC regulated n. 8-66720) and a member of the Financial Industry Regulatory Association (FINRA CRD # 133376).
• CAMPBELL LUTYENS ASIA PACIFIC LTD (company registration number 1489582) a limited company having its registered office at Suite 1918 – 1919, Jardine House, 1 Connaught Place, Central, Hong Kong. Licensed and regulated by Hong Kong the Securities and Futures Commission (Ref # AWZ314); and
• CAMPBELL LUTYENS (SINGAPORE) PTE LTD (company registration 201724749C) a limited company having its registered office at 10 Collyer Quay, #37-06/10 Ocean Financial Centre, Singapore, 049315. Regulated by the Monetary Authority of Singapore. Securities offered through Campbell Lutyens & Co. Inc., Member FINRA
• CAMPBELL LUTYENS & CO (FRANCE) SA (company registration number 892001090) a Société anonyme having its registered office at 10, avenue Franklin Delano Roosevelt, 75008, PARIS, France. CAMPBELL LUTYENS & CO (FRANCE) SA is authorised and regulated by the Autorité de Contrôle Prudentiel et de Résolution (“ACPR”). Licence number 15183D.
• CAMPBELL LUTYENS & CO. LIMITED (TRADING AS CAMPBELL LUTYENS & CO. LTD. (DIFC BRANCH)) (company registration number 8443), a Recognised Company under the Companies Law, DIFC Law No. 5 of 2018, having its registered office at Unit GV-00-03-01-BC-07-0, Level 1, Gate Village Building 3, DIFC, UAE and regulated by the Dubai International Financial Centre and the Dubai Financial Services Authority (Ref# F009271).

For the purpose of the Data Protection Legislation, we are deemed to be a "data controller" in respect of any Personal Information that you provide to us or we otherwise obtain about you.

The Personal Information we collect and use

Campbell Lutyens may, via the Website and in connection with its business dealings (including potential business opportunities), collect certain Personal Information about you. Examples of Personal Information collected may include your name, position, work e-mail address and a telephone number. We will not collect any Personal Information from you that we do not need.

How we use your Personal Information

Campbell Lutyens will collect and hold Personal Information for use in connection with:

1. our legitimate business interests;
2. conducting our financial services business and performing internal business processes;
3. providing the services you (or another individual on your behalf) have requested and to provide you with information relating to the provision of such services;
4. continually improving our Website and the services that we provide; and
5. complying with our legal obligations.

We will not use or disclose your Personal Information for any purpose other than those described above without your consent, unless required or authorised by law.

Who we share your Personal Information with

We may share your Personal Information internally with any member of the Campbell Lutyens group or other selected third parties where we have your explicit consent or it is necessary for, (i) the performance or provision of the services you have requested; (ii) us to comply with our legal obligations; or (iii) our legitimate business interests.

This will include Campbell Lutyens' IT providers, who have the capacity to access data held on our systems, and certain third party providers used by Campbell Lutyens for offshore data storage services. Contractual safeguards are in place with third parties who may have access to your Personal Information to ensure that your information is kept confidential and is handled in accordance with this Notice.

We may also share the Personal Information of investors with our clients, including clients which are located outside of the EEA (as defined below), in order to allow us to fulfil our obligations under certain client mandates. Investor Personal Information will only be shared in this way where, (i) there has been a clear dialogue between the relevant investor and the Campbell Lutyens relationship manager regarding the nature of the Personal Information which Campbell Lutyens intends to transfer and the identity of the client which is the intended recipient; and (ii) appropriate obligations have been imposed on the client with respect to maintaining the security and confidentiality of the Personal Information.

How long your Personal Information will be kept

The Personal Information that Campbell Lutyens collects or you otherwise provide to us will be retained for only as long as is necessary for the purpose for which it was collected. When we no longer need it, we will securely delete or anonymise your Personal Information unless we are required to retain a copy under applicable law, including any regulations imposed from time to time by the Financial Conduct Authority.

Recruitment

This section describes how Campbell Lutyens collects and uses Personal Information about you during the application and recruitment process.

The Personal Information we hold about you

We may collect store and use the following categories of Personal Information about you:

• information relevant to our recruitment decision, including CVs, application forms, interview notes, results of pre-employment checks, references, criminal record checks;
• information relating to your right to work: including passport information, visa details, immigration permissions, travel information; and
• information relating to reasonable adjustments which may be required to accommodate a disability.

We collect this Personal Information either directly from you or from third parties including employment agencies, former employers, other referees, qualifications bodies, or background check agencies or publicly available sources e.g. LinkedIn.

How we use your Personal Information

We process your Personal Information for the following purposes:

• recruiting employees who have the appropriate skills, qualification and experience for each role;
• ensuring employees have the right to work in the relevant jurisdiction; and
• complying with our duty to make reasonable adjustments.

We process your Personal Information because it is necessary for our legitimate interests of operating our business efficiently, maintaining standards of service to our clients, or because it is necessary for us to comply with our legal obligations.

In addition, where we process any information which falls within "special categories" (which may include health information, criminal record details and information about race, ethnic origin, religion or sexual orientation), this is because it is necessary for (i) complying with our legal or regulatory obligations and requirements; (ii) complying with our employment law obligations; or (iii) exercising our employment law rights. In certain circumstances we may process special categories of Personal Information where it is needed in relation to legal claims, or in order to protect your interests where you are not capable of giving consent.

If you fail to provide certain Personal Information when requested, in some circumstances we may not be able to continue with the recruitment process.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your personal information changes during the recruitment process.

Automated means

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Who we share your information with

We share your Personal Information with third party service providers who assist with our recruitment process. These providers include pre-employment screening specialists and immigration advisors (as necessary).

How long we keep personal information

For successful candidates, we retain Personal Information from the recruitment process for the periods outlined in our staff data collection notice which we give to new staff on joining.

For unsuccessful candidates we would usually retain recruitment information for a maximum of a year, but we may hold the information for longer if we agree with the candidate that their details will be kept on file for future vacancies, or where we have a business reason for doing so (for example, where we may need information in case of legal proceedings).

Storage and transfer of your Personal Information

The Personal Information you provide to us will be transferred to and stored on our servers and we take all steps reasonably necessary to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.

In processing your Personal Information it may be transferred outside of the European Economic Area ("EEA") and the UK and made available on a group wide basis where it is relevant to the group’s business activities. Therefore, additional steps have been taken to ensure your Personal Information will be treated securely and in accordance with this Notice and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the EEA and the UK. This means that Campbell Lutyens will only transfer your Personal Information to third parties outside the EEA and the UK 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 way of written contract incorporating the "model clauses" as approved by the European Commission or by some other form of data transfer mechanism approved by the European Commission) to provide all protections to your Personal Information as required by the Data Protection Legislation; or (c) we have your explicit consent to do so.

Where any transfer takes place under a written contract, you have the right to request a copy of the relevant parts of that contract and may do so by contacting us at cl-dataprivacy@campbell-lutyens.com.

By submitting your Personal Information to Campbell Lutyens, you acknowledge this transfer, storing or processing of your Personal Information.

What are your rights as a data subject?

You are entitled to know some details about the Personal Information Campbell Lutyens holds about you and how that information is processed. If you would like to request this please contact us via the details set out at the end of this Notice.

You are also able to access and update the Personal Information we hold about you at any time and ask us to, (a) make changes to ensure that any Personal Information we hold about you is accurate, complete and up-to-date; (b) erase or stop processing any Personal Information we hold about you where there is no longer a legal ground for us to hold it; or (c) in some cases, transfer any information we hold about you to a third party. If you wish to exercise any of these rights, please contact us via the details set out at the end of this Notice.

Keeping your Personal Information secure

We have appropriate security measures in place to prevent your Personal Information from being accidentally lost, used, or accessed in an unauthorised way, and to ensure that your Personal Information is handled in accordance with this Notice.

Whilst we strive to protect your Personal Information as outlined above, we cannot ensure the security of any Personal Information that you transmit to us over the internet (including via our Website) and you do so at your own risk. However, once we receive your transmission, we take steps to ensure that your Personal Information is secure on our systems.

Cookies

We use cookies on our Website to distinguish you from other users. Cookies are small files which are stored on your device when you visit a website so that it can remember something about you at a later time. Cookies cannot be used to identify you personally and are not harmful to your device.

We are constantly improving our Website based on information recorded by cookies regarding how visitors interact with our Website. These cookies record anonymous information about visits and clicks on each web page and measure any errors that occur whilst you are using our Website.

The Website uses persistent cookies. Persistent cookies are stored on your device in between browser sessions and allow your preferences or actions across a website site to be remembered.

If you would like to restrict or block the cookies which are set by us, or any other website, you can do this through your browser settings. Please be aware that restricting cookies may impact on the functionality of the Website. You can find out more information about the specific cookies we use and the purposes for which we use them in the table at the end of this Notice. You can find more information about cookies generally here: http://www.allaboutcookies.org/.

Our Cookies

Linked sites

Our Website may, from time to time, contain links to and from third party websites. Links are provided only as a convenience. The inclusion of any link is not and does not imply any affiliation, endorsement, approval, verification or monitoring by Campbell Lutyens of any information on the third party website. Campbell Lutyens is not responsible for the content of any site linked or linking to our Website.  Your linking to any other websites is at your own risk, and you should review the privacy notices of these websites before you submit any Personal Information to them.

Questions and complaints

If you have a query or complaint regarding the way in which your Personal Information is being handled by us, please contact us in the first instance via email at cl-dataprivacy@campbell-lutyens.com and we will investigate the matter. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner's Officer regarding such issues.

Changes to this Notice

We may change our Privacy Notice from time to time and any changes we make will be posted on our Website and, where appropriate, notified to you when you next access our Website. It is your responsibility to ensure that you are aware of the latest version of this Notice and by continuing to use our Website or otherwise engage with us, you will be deemed to have accepted any revised terms.

Notice Specific to Residents of the State of California, United States

Pursuant to the California Consumer Privacy Act of 2018 ("CCPA"), Campbell Lutyens is providing the following additional details regarding the collection of Personal Information with respect to California residents who are not employees, independent contractors, owners, directors, officers, or job applicants of Campbell Lutyens, or emergency contacts or benefits beneficiaries of the foregoing ("California Residents").

Specific types of Personal Information that California Residents may have provided us, or that may have been provided to us with respect to California Residents, during the creation of, or during, our business activities or as necessary to fulfil our legal and regulatory obligations, include: (i) personal information categories listed in the California Customer Records statute, such as name, contact information and financial information, (ii) personal identifiers, such as name, online identifier, IP address, and government-issued identifier, (iii) characteristics of protected classifications under California or federal law, such as sex, age, national origin, citizenship, immigration status and marital status, (iv) commercial information, including records of financial products invested in, (v) professional or employment-related information, such as work history and prior employers, and (vi) inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

We may disclose Personal Information to members of the Campbell Lutyens group or other third parties (e.g., our affiliates, service providers and/or clients), which may use this information for all purposes outlined in this Notice.  For instance, we (and other members of the Campbell Lutyens group) may use Personal Information for the purposes of operating, managing, and maintaining our business, and otherwise accomplishing our business purposes and objectives, including, for example, using Personal Information to:

• Fulfill or meet the reason you provided the information or otherwise fulfill the transactions or advice requested by our clients;
• Provide you or your company with products and services that may be of interest, such as investment vehicle interests;
• Manage and maintain our relationships with industry contacts;
• Conduct anti-money laundering, know-your-client, and other diligence on prospective and current clients;
• Conduct due diligence on companies and employees of such companies that Campbell Lutyens is considering advising or engaging in other business with;
• Send subscription materials, private placement memoranda, prospectuses, term sheets, purchase and sale agreements and other research and information requested;
• Refer potential clients or service providers to individuals; and
• Comply with law, legal process, internal policies and other requirements such as income tax filings, monitoring, record-keeping and reporting obligations, and exercise and defend legal claims.

Consistent with the CCPA, individual California Residents may request information about our disclosure of certain categories of Personal Information to third parties, for information about Personal Information we have collected about you or for the deletion of Personal Information that we have collected about you.

Individual California Residents must submit requests to us either by email at cl-dataprivacy@campbell-lutyens.com or by mail or telephone at the following address:

Campbell Lutyens & Co. Ltd
64 North Row, London W1K 7DA
Attn: Legal Department
+1 (212) 223-8448 or +44 (0)20 7439 7191

We will respond to your request consistent with applicable law. Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.  This request may be made no more than once per calendar year.  We reserve our right not to respond to requests submitted other than to the email or mailing address specified in this section of our Notice.  We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Contact us

Questions, comments and requests regarding this Notice are welcomed and should be addressed via email to cl-dataprivacy@campbell-lutyens.com.

General notice

Acceptance of terms

By using this Website, you are accepting the practices and consenting to the terms herein and below. If you do not consent to all of the terms below, then you should immediately discontinue your use of and access to this website.

Ownership and Trademarks

“Campbell Lutyens” is the trade name for Campbell Lutyens & Co. Ltd and its affiliates. The trademarks, logos and service marks used on the Website are registered trademarks of Campbell Lutyens. Nothing on the Website shall be interpreted as granting any licence or right to use any image, trademark, logo or service mark on the Website. Campbell Lutyens reserves all rights with respect to copyright and trademark ownership of all material on the Website, and will enforce such rights to the full extent permissible by law.