Privacy Policy

  1. Important information and who we are
  2. Glebe Asset Management Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

    Purpose of this privacy notice

    This privacy notice aims to give you information on how Glebe Asset Management Ltd collects and processes your personal data through your use of this website, including any data you may provide to us.

    Controller

    Glebe Asset Management Ltd is made up of different legal entities, details of which can be found here, collectively referred to as “we", “us" or “our" in this privacy notice. Glebe Asset Management Ltd is responsible for this website and the controller responsible for your personal data when you purchase a product, service or make contact with us

    Contact Details

    Glebe Asset Management Ltd 
    63a South Audley Street 
    London W1K 2QS

    E [email protected]
    T +44 (0)20 7409 3740
    F +44 (0)20 7409 3750

    If you have any questions about this privacy notice, including any requests to exercise all the rights afforded to you under the General Data Protection Regulation, please contact us using the details set out above.

  3. The data we collect about you
  4. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    Identity Data includes first name, last name

    Contact Data includes billing address, delivery address, email address and telephone numbers

    Financial Data includes bank account and payment card details

    Transaction Data includes details about payments to and from you

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health or genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  5. How is your personal data collected?
  6. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, or email.

  7. How we use your personal data
  8. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    • Where we need to perform the contract we are about to enter into or have entered into with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal or regulatory obligation.

    Purposes for which we will use your personal data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
    To register you as a new employee and or customer (a) Identity
    (b) Contact
    Performance of a contract with you
    To process salary, dividends and or deliver your order including:

    (a) Manage payments, fees and charges
    (b) Collect and recover money owed to us
    (a) Identity
    (b) Contact
    (c) Financial
    (d) Transaction
    (e) Marketing and Communications
    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (to recover debts due to us)
    To manage our relationship with you which will include:

    (a) Notifying you about changes to our terms or privacy policy
    (a) Identity
    (b) Contact
    (a) Performance of a contract with you

    (b) Necessary to comply with a legal obligation
    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
    (b) Contact
    (c) Technical
    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

    (b) Necessary to comply with a legal obligation
    To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications
    (f) Technical
    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

    Cookies

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  9. Disclosures of your personal data
  10. We only share your personal data within the Glebe Asset Management Ltd group or when required by law.

  11. Data security
  12. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  13. Data retention
  14. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

  15. Your legal rights
  16. Under certain circumstances, you have rights under data protection laws in relation to your personal data:

    • Request access to your personal data
    • Request correction of your personal data
    • Request erasure of your personal data
    • Object to processing of your personal data
    • Request restriction of processing your personal data
    • Request transfer of your personal data
    • Right to withdraw consent

    If you wish to exercise any of the rights set out above, please contact us so that we may respond to your request.

    No fee usually required

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    What we may need from you

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

    Time limit to respond

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  17. Glossary
  18. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.