Peak Capital Management S.à.r.l (”We”) is committed to protecting and respecting your privacy. We may use your personal information together with other information for providing consultancy services, anti-money laundering, marketing, administration and training, and we may disclose information to our service providers and agents for these purposes.
This policy (together with our Terms and Conditions of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.peak-cap.com (“our site”) you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Peak Capital Management S.à.r.l. If you have any queries, complaints or request please contact us at info@toro-capital.com
Information we collect from you
We will collect and process the following data about you:
- Information you give us. This includes information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph and demographic information such as preferences and interests.
- Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information (where applicable):
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
Why do we collect this information
We use this information in the following ways:
- Information you give to us. We use this information for the following purposes:
- in order to take steps necessary to assess whether we can enter into a contract with you and in order to perform our contract with you. This includes carrying out our obligations to you providing you with our services;
- to help us in providing our services to you;
- for the purpose of improving our service to you and to ensure that content from our sites is presented in the most effective manner for you and for your device;
- to carry out market research, statistical analysis and customer profiling to establish investment interests;
- to deal with any queries relating to your use of our service;
- to provide you with service communications so that you receive a full and functional service and so we can perform our obligations to you. These may be sent by email or post or, if the circumstances require it, we may contact you by phone. These will include notifications about changes to our services;
- to provide you with marketing communications including, with your permission, information about services we offer that are similar to those that you have already purchased or enquired about;
- to deal with any complaints or claims.
- Information we collect about you. We will use this information for the following purposes:
- to administer our sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our sites and portal to ensure that content is presented in the most effective manner for you and for your device;
- as part of our efforts to keep our sites and portal safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- Information we receive from other sources. See the ‘Who might we share your information with?’ section below for details of how we use information in conjunction with our associated third parties.
- Monitoring of communication. We may monitor communications with you for the purposes of quality assurance, training and fraud prevention and compliance.
How long do we keep hold of your records
We will keep information about you for a maximum of 6 years after the end of our relationship with you unless, the law or obligations to our regulators require otherwise or we are required remove such data from our records.
Who might we share your information with
You agree that for the purposes set out in the ‘Why do we collect this information?’ section above, we have the right to share your personal information with:
- Selected associated third parties, some of whom we appoint to provide services, including: business partners, subsidiaries, suppliers and sub-contractors for the performance of any contract we enter into with you; analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Any member of our group;
- Your appointed agents, advisers or providers.
Additionally, we will disclose your personal information to the relevant third party:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
- If we are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
- Law enforcement agencies in connection with any investigation to help prevent unlawful activity;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our customers, our regulator, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention of money laundering and credit risk reduction.
How is your data stored and kept secure
We take your safety and security very seriously and we are committed to protecting your personal and financial information. All information kept by us is stored on our secure servers.
We may transfer your data outside the European Economic Area (“EEA”). We will only do so if adequate protection measures are in place in compliance with data protection legislation.
We use Google Drive, as our document management system. Google Drive is signed up to the Privacy Shield certification which aims to ensure the protection and privacy of your data.
From time to time, third parties will be overseas and we may need to pass on your information to enable us to do business. This applies to any special categories of information you give us. If we cannot provide this information to such third parties, we cannot provide our services. We will only transfer information outside the EEA if appropriate safeguards are in place.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
What are your rights
Where processing of your personal data is based on consent, you can withdraw that consent at any time. You have the following rights. You can exercise these rights at any time by contacting us at info@toro-capital.com
You have the right:
- to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes;
- to ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
- to request from us access to personal information held about you;
- to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
- to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation;
- to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing);
- to ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract.
Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above. In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority, which is the Information Commissioner’s Office (ICO) in the UK, at any time.
Changes to the privacy policy
This policy may be updated from time to time. Please check back frequently to see any updates or changes to our privacy policy.