Isthmus Capital Management is responsible for ensuring that it uses your personal data in compliance with data protection law. The purpose of this notice (the “Privacy Notice”) is to explain what personal data Isthmus Capital Management collects and how Isthmus Capital Management uses it. For the purposes of data protection law, Isthmus Capital Management is a data controller in respect of your personal data. “Personal data” is any data that can be used to identify you or that Isthmus Capital Management can link to you and which Isthmus Capital Management has in its possession or control.
In this Privacy Notice when we refer to “Isthmus Capital Management” or “we”/“us”/“our” we mean Isthmus Capital Management and our Associates. You can find contact details for our Associates, and the details of the data controllers within Isthmus Capital Management, by contacting us on data.protection@IsthmusCap.com.
Personal data that Isthmus Capital Management collects
Isthmus Capital Management will collect and process the following personal data:
Information that you or someone acting on your behalf provides to Isthmus Capital Management or its Associates. This includes information about you that you give Isthmus Capital Management by filling in forms, signing up for services on our website or by communicating with Isthmus Capital Management, whether face-to-face, by phone, e-mail or otherwise. If you are a client or are connected with one of our client’s matters, this may include personal data about you or others that is provided to Isthmus Capital Management in connection with the provision of services to that client.
Information Isthmus Capital Management collects or generates about you. We will also collect information about you when you use our services or when we otherwise interact or correspond with you. We use various technologies to collect and store information when you visit our websites. We may, for example, collect information about the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our websites. For information about how we use Cookies and the choices you may have, you can request a copy of our Cookies Policy by emailing data.protection@isthmiscap.com.
If you are a client, or are connected with one of our client’s matters, this information may include:
information about you, your transactions, financial information and relationship to others;
data that Isthmus Capital Management collects about your use of Isthmus Capital Management’s IT systems;
reports and information for tax reporting (e.g. FATCA) or compliance with legal or regulatory obligations (e.g. insider lists, regulator information requests);
(where required by legal or regulatory obligations or otherwise where we have a specific legal basis) recordings of telephone calls between you and Isthmus Capital Management.
Information Isthmus Capital Management obtains from other sources. If we collect or receive your personal data in the context of our provision of services, we might receive information from third parties such as your employer, other parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the services that we are providing to our client.
Uses of your personal data
Personal data may be stored and processed by Isthmus Capital Management in the following ways and for the following purposes:
to provide Isthmus Capital Management’s products and services, including processing instructions and providing confirmations, advice and statements to our clients;
verify your identity (including for fraud prevention purposes), assess your ability to meet your financial commitments (if any) and manage Isthmus Capital Management’s relationship with you and/or the client to whom you are connected;
to contact you in connection with your work with Isthmus Capital Management and the products and services that Isthmus Capital Management provides to you or a client to whom you are connected;
to perform the contract with you or a client/supplier to whom you are connected (including performing Isthmus Capital Management’s obligations and exercising Isthmus Capital Management’s rights);
to engage in marketing and business development activity and to advise you or a client to whom you are connected of other products and services similar to those which you or a client to whom you are connected receive from Isthmus Capital Management and/or its Associates;
to engage in Community Investment projects where you choose to participate;
to notify you about changes to Isthmus Capital Management’s service;
to carry out financial risk assessments, risk mitigation activities and for risk reporting and risk management;
to comply with Isthmus Capital Management’s legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations and tax reporting obligations;
to use it to prevent and respond to actual and potential fraud or illegal activities; or
to use it to look into any complaints or queries you or a client/supplier to whom you are connected may have.
Isthmus Capital Management is entitled to use personal data in these ways because:
Consent - we may (but usually do not) need your consent to use your personal data. You can withdraw your consent by contacting us (see below).
Performance of a contract - we may need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you or a client to whom you are connected.
Legitimate interest - we may use your personal data for our legitimate interests, some examples of which are given above.
Compliance with law or regulation - we may use your personal data as necessary to comply with applicable law/regulation.
Disclosure of personal data to third parties
Isthmus Capital Management may disclose personal data to its Associates in the circumstances described below:
to provide the services or perform its obligations in connection with your contract or the contract of a client/supplier with whom you are connected;
for the management and administration of the Isthmus Capital Management business;
for the management and administration of internal policies and procedures within Isthmus Capital Management.
Where personal data is disclosed to its Associates, Isthmus Capital Management will take steps to ensure that the personal data is accessed only by those persons who need to do so for the purposes described in this Privacy Notice.
Isthmus Capital Management may also disclose personal data outside of Isthmus Capital Management and its Associates, as follows:
to third party agents, service providers or contractors, bound by obligations of confidentiality, who will only use personal data on Isthmus Capital Management’s behalf for the purposes described in this Privacy Notice;
to third parties relevant to the services outlined in the contract with you or the contract of a client/supplier with whom you are connected. This may include for example counterparties to transactions, professional advisers, stock exchanges or regulators;
to the prospective counterparty, for due diligence purposes, if Isthmus Capital Management and/ or Isthmus Capital Management’s Associates restructure or sell any of its or their business or assets (for the avoidance of doubt, your personal data would only be transferred in such circumstances to the extent that such a transfer was required for the purposes of due diligence and was subject to appropriate security protections e.g. anonymisation and/or confidentiality restrictions);
to the extent required by law, regulation or court order for example if Isthmus Capital Management is under a duty to disclose personal data in order to comply with any legal or regulatory obligation; and
in order to establish, exercise or defend Rothschild & Co’s legal rights, for example if Isthmus Capital Management needs to obtain external legal advice or provide personal data in connection with judicial proceedings.
Transfers of personal data outside the European Economic Area
Personal data may be transferred to, and stored at, a destination outside the UK or the European Economic Area (“EEA”). It may also be stored and processed by staff operating outside of the UK or the EEA, who work for Isthmus Capital Management’s Associates or Isthmus Capital Management’s third party agents, service providers or contractors.
Where Isthmus Capital Management transfers personal data outside the UK or the EEA, Isthmus Capital Management will ensure that it is protected in a manner that is consistent with how personal data will be protected by Isthmus Capital Management tin the UK and the EEA. This may be achieved in one of the following ways:
the country that Isthmus Capital Management sends the data to might be approved by the European Commission or by a relevant data protection authority; or
the recipient might have signed a contract based on “model contractual clauses” approved by the European Commission or by a relevant data protection authority, obliging them to protect the personal data that they receive.
In other circumstances the law may permit Isthmus Capital Management to otherwise transfer personal data outside the UK or the EEA. In all cases, however, Isthmus Capital Management will ensure that any transfer of personal data is compliant with applicable data protection law.
You can obtain further details of the protection given to your personal data when it is transferred outside the UK or the EEA by contacting Isthmus Capital Management in accordance with the “Contacting Isthmus Capital Management” section below.
Retention of personal data
How long Isthmus Capital Management holds personal data for will vary. The retention period will be determined by various criteria including:
the purpose for which Isthmus Capital Management is using it - Isthmus Capital Management will need to keep the data for as long as is necessary for that purpose; and
legal obligations - laws or regulation may set a minimum period for which Isthmus Capital Management has to retain personal data.
Rights in relation to personal data
You have a number of legal rights in relation to the personal data that Isthmus Capital Management holds about you. These rights include:
the right to obtain information regarding the processing of your personal data and access to the personal data which Isthmus Capital Management holds about you;
the right to request that Isthmus Capital Management rectify your personal data if it is inaccurate or incomplete;
the right to request that Isthmus Capital Management erase your personal data in certain circumstances. Please note that there may be circumstances where you ask Isthmus Capital Management to erase your personal data but Isthmus Capital Management is legally entitled to retain it;
the right to object to, and the right to request that Isthmus Capital Management restrict, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask Isthmus Capital Management to restrict, its processing of your personal data but Isthmus Capital Management is legally entitled to continue processing your personal data and / or to refuse that request;
in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that Isthmus Capital Management transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to Isthmus Capital Management;
the right to withdraw your consent, although in certain circumstance it may be lawful for Isthmus Capital Management to continue processing your data where Isthmus Capital Management has another legitimate reason (other than consent) for doing so. Isthmus Capital Management is not relying on your consent in order to process your personal data for the purposes and in the manner set out in this Privacy Notice; and
the right to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by Isthmus Capital Management.
You can exercise your rights by contacting Isthmus Capital Management using the details set out in the "Contacting Isthmus Capital Management " section below.
You can find out more information about your rights by contacting the relevant data protection authority. We can, on request, tell you which data protection authority is relevant to the processing of your personal data.
Contacting Isthmus Capital Management
If you would like further information about Isthmus Capital Management’s processing of your personal data or the exercise of any of the rights referred to above, please address questions, comments and requests to
data.protection@Isthmus Cap.com.