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Cookie and Privacy Policy

Cookie Policy

This website uses Cookies to track the pages you visit via Google Analytics. Cookies are small amounts of information that are stored on your computer to enable our server to collect certain information from your web browser. Cookies in themselves do not identify the individual, just the computer used. Cookies and other similar technology make it easier for you to log on to and use the website during future visits. Our cookies are used to keep track of your online session, they are maintained throughout multiple sessions on the site. Our cookies do not collect any personal identifying information or confidential information such as passwords or policy numbers. Most browsers are initially set to accept cookies, but you can alter this if you prefer. However, if you disable session cookies some parts of our website will not function as designed. Please visit http://www.allaboutcookies.org/manage-cookies

Privacy Policy

We are committed to protecting your privacy. This privacy policy sets out the basis on which your personal data will be processed by us for the purposes of the General Data Protection Regulation (GDPR).

GDPR is a new law coming into force on 25 May 2018, which addresses what organisations can and cannot do with your personal data. ‘Personal data’ is information that identifies individuals directly or from which individuals can be identified indirectly. Goldlake Capital (“the firm”) is the ‘data controller’ in relation to your personal data that we hold because we control the storage and use of that personal data.

One of the requirements of GDPR is that we provide you with details about how we process your personal data. ‘Processing’ includes obtaining, recording or storing personal data and carrying out any tasks using the personal data. This notice also describes your data protection rights, including a right to object to some of the processing which we carry out.

Your rights

Under the GDPR you have the following rights:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To require that we cease processing your personal data if the processing is causing you damage or distress;
  • To require us not to send you marketing communications;
  • To require us to erase your personal data;
  • To require us to restrict our data processing activities;
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
  • To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Compliance Officer at 67 Grosvenor Street, London W1K 3JN, Tel: +44 (0)20 3603 2535, Email: info@goldlakecapital.com.

Data Processing

We process your personal data for a number of different purposes such as:

  • Managing your investments and providing periodic performance reports;
  • Understanding your investment objectives and financial situation;
  • Verifying your identity and carrying out regulatory checks;
  • Compiling regulatory returns;
  • Complying with various laws and regulations to which we are subject;
  • Keeping in contact with you and inviting you to events or meetings which may be of interest to you and
  • Obtaining information in relation to your use of our website.

Lawful grounds

Managing your investments and providing periodic performance reports

There are a number of reasons why we process your personal data. Our primary objective for doing so is that it enables the firm to manage your investments and to provide you with periodic performance reports.The lawful grounds for the firm to process your data is that it is necessary for the performance of our contract with you, it is necessary for compliance with a legal obligation and it is necessary for the purpose of our legitimate interests. Our specific legitimate interests served by the processing include ensuring our services are compliant with our regulatory obligations and ensuring that we provide the best possible client service.

Understanding your investment objectives and financial situation

The lawful grounds for processing are that it is necessary for the performance of our contract with you and it is necessary for compliance with a legal obligation therefore it is necessary for the purpose of our legitimate interests. Our specific legitimate interests served by the processing include ensuring that your investments are suitable for your needs and that you are provided with the best possible client service.

Verifying your identity and carrying out regulatory checks

The lawful grounds for processing are that it is necessary for compliance with a legal obligation and it is necessary for the purpose of our legitimate interests. Our specific legitimate interests served by the processing include the prevention of fraud and other financial crime and for ensuring that our services comply with the relevant regulatory requirements.

Compiling regulatory returns

The lawful grounds for processing are that it is necessary for the performance of our contract with you and enables us to comply with our regulatory obligations and it is necessary for the purpose of our legitimate interests. We have a legitimate interest in ensuring our services are delivered in a regulatory compliant manner.

Adherence to regulatory requirements

The lawful grounds for processing are that it is necessary for the performance of our contract with you and for compliance with a legal obligation and regulatory requirements and therefore it is necessary for the purpose of our legitimate interests. We have a legitimate interest in ensuring our services are delivered in a regulatory compliant manner.

Inviting you to meetings and other events which we think may be of interest to you

The lawful ground for processing is that it is necessary for the purpose of our legitimate interests. Our specific legitimate interests served by the processing include ensuring that you receive the best possible client service from us.

Obtaining information in relation to your use of our website

The lawful ground for processing is that it is necessary for the purpose of our legitimate interests. Our specific legitimate interests served by the processing include understanding how our website is used in order that we can improve its content and for enhancing our network and information security.

Providing and withdrawing consent

We may use and process your personal information where you have consented for us to do so in connection with our marketing activities. You may withdraw your consent for us to use your information in this way at any time. To do so please contact our Compliance Officer at 67 Grosvenor Street, London W1K 3JN, Tel: +44 (0)20 3603 2535, Email: info@goldlakecapital.com.

Recording of phone calls and Voice over IP calls

We normally record telephone calls including mobile calls and Voice over IP calls for regulatory purposes.

Sharing of Personal data

The firm may pass your personal data to third parties on whose services we rely in order to be able to provide services to you. These include: custodians, market counterparties, brokers, banks, fund operators, administrators, software providers, professional advisers, lawyers, auditors, registrars, regulatory or tax authorities.

Transfer of information outside of the EU

Third parties whose services we use may also transfer your personal data to other third parties who in turn they use to provide their services to us. We ask such third parties to put in place appropriate safeguards where this involves a transfer of personal data outside the EU.

Data retention periods

We will retain your personal data for the duration of our contractual relationship and, as required by our regulators, for a period of time thereafter.

Automated decision making

The firm does not use automated decision-making applications.

Right to complain

If you wish to make a complaint in relation to the use of your personal data, please contact our Compliance Officer at 67 Grosvenor Street, London W1K 3JN, Tel: +44 (0)20 3603 2535, Email: info@goldlakecapital.com. You have a right to lodge a complaint in relation to our processing of your personal data with the Information Commissioner’s Office.  The helpline number is 0303 123 1113.

If you require any further information in relation to this Privacy Notice, please contact our Compliance Officer at 67 Grosvenor Street, London W1K 3JN, Tel: +44 (0)20 3603 2535, Email: info@goldlakecapital.com. By using this website you agree to the use of your information as set out in this statement.