1. INTRODUCTION

Legatus is committed to protecting and respecting privacy. We wish to be transparent on how we process information.

In this Privacy Notice, information is sometimes called “personal data”. We may also sometimes collectively refer to handling, collecting, protecting, and storing personal data as “processing” such personal data.

In this Privacy Notice the term “Data Protection Legislation” means the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR); together with all applicable legislation relating to privacy or data protection within the United Kingdom.
It is the intention of this Privacy Notice to set out the reasons why we collect, use, process and / or disclose personal data when we are the controller of your personal data.

2. WHO WE ARE

We are Legatus Holdings Limited (Legatus).
Legatus is registered in England and Wales with registered office at:

C/O Brabners LLP
100 Barbirolli Square
Manchester
M2 3AB
Our ICO – ZB824499 

The website (https://legatusholdings.co.uk) is owned and operated by Legatus.

Legatus is the holding company for our Group which includes subsidiaries, as defined in section 1159 of the UK Companies Act 2006. Collectively referred to as “our Group”, “we” or “us” in this policy. Within our Group there are companies which have their own responsibilities for managing separate aspects of your personal data.

The following companies are the ‘data controllers’ within our Group that collects and use personal data:

Asertis – https://asertis.co.uk/privacy-notice/
KP Law – https://www.kpl.co.uk/privacy-policy/
Toremis – https://www.toremis.com/privacy-policy
Cavis – https://cavis.co.uk/privacy/

3. LEGAL BASES FOR PROCESSING PERSONAL DATA

The Data Protection Legislation sets out a number of reasons for which a company may collect and process personal data.

Legatus will only process personal data in line with the relevant regulations and law. Where Legatus is a data controller, the Data Protection Legislation allows us to use the following grounds for processing personal data:

• Legitimate interests;
• Compliance with our legal obligations;
• Fulfilment of a contract;
• Consent; and / or
• Performance of a task carried out in the public interest, such as assisting a regulatory authority’s investigation of a criminal offence.

Legatus’ primary grounds for handling data is to pursue its legitimate interests in a way which might be reasonably expected as part of our running our business. Data Protection Legislation allows the use of personal data where our legitimate interests are not outweighed by your interests, fundamental rights, or freedoms as the data subject.

Additionally, Legatus may use personal data to comply with its contractual obligations, or to enforce agreements.

Whenever you have given your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. However, please note that this will not affect the lawfulness of any processing conducted before you withdrew your consent.

Whenever Legatus acts as processor, we process personal data under the explicit authority of the data controller, the data controller is the organisation that decides how to use the personal data collected from you. In these cases, it is their privacy notice which will provide details of the data processing activities.

4. WHY WE PROCESS PERSONAL DATA

Legatus processes personal data to run and administer the business, and business within our Group.

A. TYPES OF PERSONAL DATA WE MAY PROCESS

Types of personal data that we process may include:

• Individual details – Name, address, other contact details (e.g., email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you.
• Financial detail – details on any debts or assets you may have. Details available from Credit Reference Agencies.
• Court judgments, decrees, and administration orders
• Bankruptcies, Individual Voluntary Arrangements, and similar events
• Identification details – Identification numbers issued by government bodies or agencies, including your passport number, tax identification number.

B. SPECIAL CATEGORIES OF PERSONAL DATA

Some personal data that we hold (such as details relating to physical or mental health or condition, ethnicity, criminal or alleged criminal offences) is special categories of personal data for the purposes of Data Protection Legislation. We may seek your consent to process special categories of personal data; however certain special categories of personal data (such as that relating to alleged offences) may be processed where it is necessary for us to comply with our legal obligations.

Where we process special category personal data, we take additional measures to protect the data.

C. WHERE WE COLLECT PERSONAL DATA FROM

We may collect your personal data from various sources, including but not limited to:

• Law firms, agencies, consultancy firms, financial services, investment, asset management companies, and other financial institutions and/or other third parties related to them
• Companies within our Group
• Information you have provided to us
• Publicly available data sources
• Credit Reference Agencies
• Other companies, commercial partners, agents and professionals who offer products, services and admin support to us.

D. WHO WE SHARE PERSONAL DATA WITH

To conduct our business and to comply with our legal obligations, we may share your personal data with third party companies, agents, contractors, service providers or related companies.

We may also share your personal data with any member of our Group. We will share your personal data within our Group, only to the extent required and with the appropriate agreements in place, so that we can provide you with the relevant services.

We may also use third parties to perform tasks on our behalf, for example IT service providers.

Where personal data is shared with an IT service provider, other service provider or other third-party suppliers, we work closely with them to ensure that your personal data is secure and protected at all times. Our contracts with third parties make it clear that they must hold personal data securely, abide by the principles and provisions of Data Protection Legislation, and only use information as we instruct them to. In all instances where we disclose your information to third parties, we will ensure that your information is appropriately protected. If we stop using their services, any of your personal data held by them will either be deleted or rendered anonymous.
If we are required to do so by law, or in performance of our legal obligations, we may share your data with courts, law enforcement agencies or other governmental agencies.

5. WEBSITE USERS

We do not normally collect personal data through your use of our website.

A. HOW WE USE COOKIES

A cookie is a small file which asks permission to be placed on your computer’s hard drive.

Some cookies are essential and do not require consent. Essential Cookies are cookies that make our website work and remain secure.
For optional cookies we will ask for your consent before we place them on your device or browser. We may update the cookies we use and their purpose, if we do this, we will let you know.

We may use traffic log cookies to show us which pages are being used. This may help us analyse data about web page traffic and in the future, potential help us improve our website to tailor it to client’s needs. We will only use this information for statistical analysis purposes and then the data is removed from the system.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer – however this may prevent you from taking full advantage of the website.

B. LINKS TO OTHER WEBSITES

Our website may have links to other websites of interest. However, once you have used these links to leave our website, you should note that we do not have any control over that other website. We cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this privacy notice.

You should exercise caution when you leave our website and look at the privacy statement applicable to the website in question.

6. BUSINESS CONTACTS

For us to run our business, we develop business relationships with a range of individuals across various industries which includes but not limited to individuals at law firms, agencies, consultancy firms, financial services, investment, asset management companies, and other financial institutions.

A. TYPES OF PERSONAL DATA WE MAY PROCESS

Types of personal data that we process for Business Contacts may include name, address, contact details (e.g., email and telephone numbers), gender, employer, job title and employment history.

B. WHERE WE COLLECT PERSONAL DATA FROM

We may collect personal data from various sources, including:

• Law firms, agencies, consultancy firms, financial services, investment, asset management and other financial institutions and/or other third parties related to them
• Information you have provided to us
• Companies within our Group
• Publicly available data sources

C. WHO WE SHARE PERSONAL DATA WITH

To conduct our business, we may share information with third party companies, agents, contractors, service providers or related companies.

We may also share your personal data with any member of our Group. We will share your personal data within our Group, only to the extent required and with the appropriate agreements in place, so that we can provide you with the relevant services. We may use third party processors to perform tasks on our behalf, for example IT service providers.

7. CANDIDATE PRIVACY

A. When applying for employment at Legatus, whether as an employee, consultant, or contractor, Legatus, acting as a Data Controller will collect and process your personal data for the purposes of recruitment.

B. Legatus collects your personal data for the recruitment process either directly from you or from a third party. Legatus may engage a recruitment agency, background check provider, credit reference agency, your referees, and where appropriate, the Disclosure and Barring Services during the recruitment process.

C. Legatus uses the personal data collected during the recruitment process to evaluate applicants, including but not limited to assess skills, qualifications, suitability for the role, carry out background, credit and reference checks, communicate with you about the recruitment process, keep records related the hiring processes and to comply with legal or regulatory requirements.

D. Legatus will only disclose your personal data to third parties where required by law or to relevant employees, contractors, designated agents, a Legatus subsidiary, or third-party service providers who require such information to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf.

E. If you are a past or present employee, consultant or contractor, Legatus may also hold personal data about you. For further details please email contact@legatusholdings.co.uk

F. This information does not form part of any contract that you may have with Legatus. It is provided for information purposes only.

8. HOW WE STORE YOUR DATA

Legatus stores your personal data securely within the UK.

9. HOW LONG WE KEEP PERSONAL DATA

Legatus will only keep personal data and other information for as long as it is necessary either to perform its obligations or to comply with any legal obligations. Personal data found to be irrelevant or excessive will be removed or destroyed at the earliest opportunity. When personal data is deleted, this will be done safely such that the data is irrecoverable.

As a rule, for legal and best practice reasons we are required to keep your information for 6 years after the date on which our relationship with you ends.

10. YOUR DATA PROTECTION RIGHTS

A. RIGHT TO ACCESS

You have the right to access a copy of the personal data we hold. Any requests made to Legatus will be carefully considered; dealt with promptly and, unless special circumstances apply, a response will be provided in not more than a month from the request. If we are unable to provide the data you require in this time period (e.g., due to the complexity) we may extend the period to provide the data but will explain the reason. There is no charge for the request to access your data.

B. RIGHT TO RECTIFICATION

We aim to ensure the accuracy of all personal data that we hold. You have the right to have your personal data corrected or completed if you feel we have incorrect data. If you would like to correct data, please contact us.

C. RIGHTS TO OBJECT OR REQUEST ERASURE

You have the right to object to our use of your personal data, or to ask us to delete, remove, or stop using your personal data if there is no need for us to keep it. This is known as the ‘right to object’ and the ‘right to erasure’, or the ‘right to be forgotten’

Section 3 of this notice explains our lawful bases for processing your data and why we need to process your personal data in relation to the activities we undertake. This is why your right to object doesn’t automatically lead to deletion of your information, but we will carefully consider every request we receive and if we can’t delete your information, we shall inform you and explain why we cannot.

D. RIGHT TO RESTRICT PROCESSING

In some circumstances, you can ask us to restrict how we use your personal data. This is not an absolute right, and your personal data may still be processed where certain grounds exist. These grounds include:

• With your consent;
• For the establishment, exercise, or defence of legal claims;
• For the protection of the rights of another natural or legal person;
• For reasons of important public interest.

Only one of these grounds needs to be shown to continue data processing. We will carefully consider and respond to requests we receive, including assessing the applicability of these exemptions. If we believe an exemption applies, we shall inform you and explain.

E. RIGHTS RELATED TO AUTOMATED DECISION MAKING

Legatus does not currently use your personal data to make solely automated decisions.

11. SECURITY

We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the personal data we process.

12. CHANGES TO THIS PRIVACY NOTICE

If our Privacy Notice changes in any way, Legatus will place an updated version on this page. Regularly reviewing this page will ensure that you are always aware of how we process personal data. The current version fully replaces all earlier Privacy Notices.

13. HOW CAN WE HELP

If you have any questions about Legatus’ Privacy Notice, or you would like to exercise one of your data protection rights, please do not hesitate to contact us at our registered office:

100 Barbirolli Square
Manchester
M2 3AB

T: +44 (0)161 820 7111
E: contact@legatusholdings.co.uk

For further information on data protection legislation, please visit the Information Commissioner Office (ICO). The ICO regulates data protection.

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the ICO.

You can contact them by calling 0303 123 1113 or visit the website at https://ico.org.uk/.