WILDSTONE PRIVACY NOTICE

We respect the privacy of every person who visits Wildstone Capital’s website and/or uses the services made available by us from the Wildstone Capital website (the “Wildstone Service”) and we are committed to ensuring a safe online experience.

1 PURPOSE OF THIS NOTICE
This privacy notice explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of the Wildstone Service and sets out your rights in respect of Wildstone’s processing of your personal information.
This privacy notice will inform you how you can verify which of your personal information is collected by us through the Wildstone Service and how you can request that we delete, update or transfer it.
This privacy notice is intended to assist you in making informed decisions when using the Wildstone Service. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Website Terms of Use.
Please also note that this privacy notice only applies to the use of personal information collected by us from your use of the Wildstone Service or during your communications with us. It does not apply to personal information collected during your communications with third parties.
2 WHO ARE WE AND WHAT DO WE DO?
The Wildstone Service is operated by Wildstone Capital Ltd (“Wildstone”) whose principal activities include planning consultancy services.
Wildstone is the data controller responsible for your personal information. Wildstone Capital Ltd is registered at the UK Information Commissioner’s Office with registration number: ZA305207 Wildstone Capital Ltd is an English company with registered company number: 07275191 and whose principal address is 22 Berghem Mews, Blythe Road, London
3 HOW TO CONTACT US?
If you have any questions about this privacy notice or want to exercise your rights, please contact us by:
• sending an email to info@wildstone.co.uk;
• calling us on 020 7313 9571; or
• writing to us at 22 Berghem Mews, Blythe Road , marking your letter for the attention of Philip Allard, COO and Data Protection Officer.
4 WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
Our primary goal in collecting personal information from you is to give you a customised experience while allowing us to provide services and features that most likely meet your needs. In order to do so personal information may be collected from you in the following ways:
• Information you voluntarily provide to us.

We collect and maintain personal information that you voluntarily submit to us during your use of the Wildstone Service (e.g. during the course of email exchanges with us or as part of any customer support interactions).
In particular, in order to sign up and create an account we require the following personal information from you:
• name;
• e-mail address;
• postal address;
• mobile number
You have the flexibility to provide us with as little or as much of this information as possible. However, the more information you provide, the more you will get out of the Wildstone Service.
If you contact us, we may collect additional information from you.
• Information we collect through your use of the Wildstone Service.

We may collect through our use of cookies, pixels, beacons, log files and other technologies personal information regarding your mobile device, computer hardware and software used to access the Wildstone Service. This may include the following:
• IP address of device(s) used;
• browser type;
• operating system and device type;
• approximate location (e.g. London);
• access times and dates; and
• referring website addresses.
We may also collect personal information regarding your use of and activity on the Wildstone Service.
This personal information allows us to deliver more helpful information, services and tools. Please see our cookie policy for further information.
• Information we collect from third parties.

We may also combine personal information that we collect through your use of the Wildstone Service with personal information that: a) you have provided to third parties and in respect of which you have given the third party permission to share with Wildstone; and/or b) we have obtained from a public record.
How do we use your personal information?
We collect and use your personal information to operate the Wildstone Service efficiently and to deliver you the very best service. In particular, we may use your personal information for the following purposes:
• Provision of the Wildstone Service.

to decide what information is provided to you via the website.

What is our legal basis?

Wildstone’s legitimate interests

• Service administration.
We may use your personal information to:
o develop and improve the Wildstone Service;
o send you administrative e-mails about the Wildstone Service; and
o contact you to answer any queries you may have.

What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.

• Internal record keeping and legal compliance.

We may use your personal information for internal record keeping purposes and to check you comply with the Website and Portal Terms of Use.

What is our legal basis?

It is in our legitimate interest to ensure that we keep our records up-to-date in order to monitor who uses the Wildstone Service, to comply with our legal obligations and to monitor your compliance with the Terms of Use.

• Marketing by us.

By email
By post
By phone
By text

What is our legal basis?

Your consent.

• Sharing information with third party processors.

We may share your personal information with third party processors in order to provide the Wildstone Service and associated products and services to you.

What is our legal basis?

It is in our legitimate interest to share your personal information in such a way to ensure that we provide the very best service we can to you. Where we share your sensitive personal data, we shall be relying on your consent to do so.

• Sharing information with professional advisors & potential purchasers.

We may share your personal information with professional advisers or regulatory authorities:
o to enable them to process your personal information on our behalf in a manner consistent with this privacy notice;
o to comply with our legal obligations;
o to enforce our legal rights; or
o protect rights of third parties.

Your personal information may also be shared with prospective buyers if we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
What is our legal basis?
It is in our legitimate interest to share your personal information with such third parties to enable them to process your information on our behalf, to comply with and/or enforce our legal rights and obligations, to protect the rights of third parties and to facilitate business transitions. Where we share your sensitive personal data, we shall be relying on your consent to do so.

Any other purposes for which we wish to use your personal information will be notified to you either by updating our privacy notice or otherwise from time to time including the legal basis of such use.
5 HOW DO WE OBTAIN YOUR CONSENT?

Where use of your personal information by us requires your consent, you can provide such consent:
• at the time we collect your personal information following the instructions provided; or
• by informing Wildstone by e-mail, post or phone using the contact details set out in this privacy notice.
6 USE OF COOKIES
The Wildstone Service may use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.
7 THIRD PARTY LINKS
The Wildstone Service may contain links to third party websites and services. Please remember that when you use a link to go from Wildstone to another website or you request a service from a third party, this privacy notice no longer applies.
Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
This privacy notice applies solely to personal information collected by us through the Wildstone Service and does not apply to these third party websites and third party service providers.
8 TRANSFERS OUTSIDE THE EEA
We may transfer your personal data outside the EEA to servers in Ashburn Virginia, United States of America in connection with our business or for legal reasons. We will ensure that the transfer is lawful and that there are appropriate security arrangements.
The European Commission has decided that United States of America provides an adequate level of protection in relation to data that is transferred there.
9 HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes.
In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.
10 CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
o unauthorised access;
o improper use or disclosure;
o unauthorised modification; and
o unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Wildstone Service.

11 HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?
You have the following rights in relation to the personal information we hold about you:
• Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability.

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.

• Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we’re:
o relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
o processing your personal information for direct marketing; or
o processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.

• Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling in necessary for entering into, or the performance of, a contract between you and Wildstone.

• Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
• Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
12 CHANGE TO THIS PRIVACY NOTICE
We may make changes to this privacy notice from time to time.
To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how Wildstone uses your personal information.

Last Updated January 2018

1 INTRODUCTION
1.1 Welcome to “Wildstone Capital” which is provided to you by Wildstone Capital Limited (“Wildstone Capital”, “us”, “we” or “our”). Our registered office is at 17 Gresse Street, London, W1T 1QL and our registered number is 07275191. Our VAT number is 992475767
1.2 Please read these Terms of Use (“Terms”) carefully. They set out the basis on which you are allowed to use the Wildstone Capital website (the “Service”) and the services and products available through the Service.
1.3 In addition to these Terms, your use of the Service may also be subject to other terms and conditions and policies which are referred to below.
2 ACCEPTANCE OF OUR TERMS
2.1 In order for us to provide the Service to you, you must agree to be bound by these Terms. These Terms govern the provision and use of the Service and will form a legally binding contract between Wildstone Capital and you so please do take the time to read these Terms and make sure you understand them.
2.2 By using the Service, you agree to accept and be bound by these Terms. If you do not agree to accept these Terms you must not use the Service.
2.3 We recommend you review these Terms each time you use the Service and print a copy of them for your future reference.
3 WILDSTONE CAPITAL’S RIGHT TO AMEND THESE TERMS
3.1 Wildstone Capital reserves the right to change, modify, add to, or delete portions of these Terms at any time including to reflect changes affecting the Service, our technology, our licensing arrangements, our payment methods, relevant laws and/or regulatory requirements.
3.2 If Wildstone Capital do change the Terms, we will post the changes on this page and will indicate the effective date at the top. We may also communicate changes to you by email. You are responsible for regularly reviewing these Terms so that you are aware of any changes. Your continued use of the Service after any such changes constitutes your acceptance of the new Terms. If you do not agree to (or cannot comply with) the Terms as amended, please do not use the Service.
4 USING THE WEBSITE
Access to our website at www.wildstonecapital.co.uk (the “Website”) is permitted on a temporary basis and we reserve the right to withdraw or amend the Website without notice. You are responsible for making all arrangements necessary to access our Website. You are also responsible for ensuring that all persons accessing our Website through your internet connection are aware of these Terms.
5 AVAILABILITY OF THE SERVICE
5.1 You acknowledge that we cannot guarantee that the Service will:
(a) stay the same (as we might change the Service or remove it altogether);
(b) be compatible with all or any hardware or software which you may use;
(c) be available all the time or at any specific time;
(d) be accurate and up-to-date; or
(e) be error-free or free of viruses, electronic bugs, Trojan horses or other harmful components and you must take your own precautions accordingly.
5.2 You also acknowledge that:
(a) we cannot guarantee the performance or security of our Website; and
(b) we will not be responsible for any damage or loss you may suffer directly or indirectly as a result of any virus attack that can be traced to our Website to the fullest extent permissible by law.
5.3 You must not:
(a) interfere with, or disrupt, the Service or any servers or networks connected to the Service, including by transmitting any worms, viruses, malware, spyware or any other code of a destructive, malicious or disruptive nature. You may not inject content or code or otherwise alter or interfere with the way any page of the Service is rendered or displayed in a user’s browser or device;
(b) access the Service via a means not authorised in writing in advance by Wildstone Capital, including but not limited to, automated devices, scripts, bots, spiders, crawlers or scrapers (except for standard search engine technologies);
(c) attempt to restrict another user of the Service from using or enjoying the Service and you must not encourage or facilitate the breach of these Terms by others;
(d) use the Service for any illegal or unauthorised purpose; or
(e) change, modify, adapt or alter the Service or change, modify or alter another website so as to inaccurately imply an association with the Service or with Wildstone Capital.
6 YOUR PRIVACY AND COOKIES
The privacy of your personal data is important to us. Please see our Privacy Notice and Cookie Policy for details of how we will process your personal data and how we use cookies and similar technologies.
7 REGISTRATION, USER ACCOUNT, PASSWORD AND SECURITY
7.1 Registration and use of the Service – By registering and using the Service, you represent that:
(a) you are at least 18 years old; and
(b) you have provided us with accurate and truthful information during the registration process.
7.2 Password Security – In order to use parts of the Service, you will be required to open an account and you will be required to complete the registration process by providing certain information and registering a username and password for your use of the Service. You are responsible for maintaining the confidentiality of the username and password. You agree that we will be entitled to assume that any person logging into the Service or using the Service using your username and password is either you or someone doing so with your permission. You are responsible for any use of the Service under your username and password, including all financial charges and legal liability. We recommend that you change your password from time to time to assist with security.
7.3 Unauthorised Access – If you believe someone has accessed the Service using your username and password without your authorisation, it is your responsibility to set up a new password. You agree to immediately notify us of any unauthorised use of your password or username or any other breach of security.
8 CONTENT AVAILABLE THROUGH THE SERVICE
8.1 Access – Your access to any information, data, images, photographs, videos and other content displayed on the Service (“Content”) is permitted in accordance with, and subject to your compliance with, these Terms.
8.2 Restriction on use – You must not:
(a) use, or cause others to use, any automated system or software to extract Content from the Service except in cases where you or any applicable third party has entered into a written agreement with us that expressly permits such activity; and
(b) use the Content for any illegal or unauthorised purpose.
9 INTELLECTUAL PROPERTY IN OUR WEBSITE AND THE CONTENT
9.1 The design of the Website and all software contained within the Website and the Content are protected by copyright, trade marks, patents and other intellectual property rights and laws. Neither the design of the Website nor the Content may be copied, reproduced, transmitted, stored, sold or distributed without the prior written consent of Wildstone Capital.
10 LINKING TO OUR WEBSITE
10.1 We will permit you to link to the home page of the Website provided you comply with the following:
(a) you only do so in a way that is fair and legal and does not take advantage of or damage our reputation;
(b) you do not suggest any form of association, approval or endorsement by us unless we have otherwise permitted; and
(c) you do not link to any other page of the Website other than the home page.
10.2 We reserve our right to withdraw our permission to link in section 10.1 at any time without notice.
11 IF YOU BREACH THESE TERMS
11.1 If you are in breach of, or we suspect you are in breach of, these Terms then we may take any/all of the following actions:
(a) issue a warning to you;
(b) effect an immediate, temporary or permanent withdrawal of your access to your account and/or the Service. However you will remain responsible for all outstanding amounts on your account;
(c) take legal action against you; and/or
(d) disclose such information to law enforcement authorities as we reasonably feel is necessary.
11.2 The responses described above at section 11.1 are not limited and we may take any other actions we reasonably deem appropriate.
12 TERMINATION
We have the right to terminate your access to any or all of the Service at any time, without notice, for any reason, including without limitation, breach of these Terms. We may also at any time, at our sole discretion, discontinue the Service or any part thereof without prior notice and you agree that we shall not be liable to you or any third party for any termination of your access to the Service.
13 WARRANTIES, DISCLAIMER AND LIMITATION ON LIABILITY
PLEASE READ THIS SECTION CAREFULLY AS IT SETS OUT IMPORTANT INFORMATION CONCERNING OUR LIABILTY TO YOU AND YOUR LIABILTY TO WILDSTONE CAPITAL:
Warranties
13.1 Wildstone Capital warrants that it will provide the Service with reasonable skill and care and substantially as described in these Terms.
13.2 Other than the express warranty in this clause, the Service is provided on an “AS IS” and “AS AVAILABLE” basis without any representation or endorsement made and without further warranty of any kind whether express or implied, including but not limited to the implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security and accuracy.
13.3 Wildstone Capital makes no warranty that the Service will meet your requirements, that Content will be accurate or reliable, that the functionality of the Service will be uninterrupted or error free, that defects will be corrected or that the Service or the server that makes it available are free of viruses or anything else which may be harmful or destructive.
Our liability to you
13.4 Wildstone Capital will not be liable under these Terms for any loss or damage caused by Wildstone Capital or any of its employees or agents in circumstances where:
(a) there has been no breach of a legal duty of care which is owed by Wildstone Capital or any of its employees or agents; and/or
(b) the loss or damage is not a reasonably foreseeable result of any breach of these Terms.
13.5 You agree you will have no claim against us, in respect of any decision to remove the Service or any decision to suspend or terminate your access to the Service.
13.6 In the absence of any negligence or other breach of duty by us, the use by you of the Service is entirely at your risk.
13.7 Nothing in these Terms shall affect your statutory rights as a consumer.
Your liability to us
13.8 You will be responsible for all claims, liabilities, damages, costs and expenses suffered or incurred by us as a result of your breach of these Terms or default in the discharge of your obligations.
13.9 Nothing in this section 13 shall have the effect of excluding or limiting either Wildstone Capital’s liability or your liability for fraud or for death or personal injury caused by our/your negligence (as applicable).
14 LINKS TO THIRD PARTY WEBSITES
The Service may include links to third party websites that are controlled and maintained by others. Any link to other websites is not an endorsement of such websites and you acknowledge and agree that Wildstone Capital is not responsible for the content or availability of any such websites. We recommend you review those websites’ terms and conditions and privacy policies to ensure you are happy to use them.
15 TRANSFER OF RIGHTS AND OBLIGATIONS
15.1 You may not transfer, assign, charge or otherwise dispose of any rights or obligations arising under or in connection with your use of the Service, without Wildstone Capital’s prior written consent.
15.2 You agree that Wildstone Capital may transfer, assign, charge or otherwise dispose of any rights or obligations arising under or in connection with the Service.
15.3 You also agree that Wildstone Capital may use third parties and sub-contract our obligations provided that we remain responsible to you for the performance of these Terms.
16 SEVERENCE
If any of these Terms should be found to be invalid, illegal or unenforceable for any reason by any court of competent jurisdiction then such term shall be removed and the remaining terms shall survive and remain in full force and effect and continue to be binding on and enforceable by both of us.
17 THIRD PARTY RIGHTS
A person who is not a party to these Terms has no rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any of these Terms but this section does not affect a right or remedy of a third party which exists or is available apart from that Act.
18 GOVERNING LAW
These Terms and the use of the Service generally and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) will be governed by English law. Any dispute or claim arising out of or in connection with such contracts or their formation (including non-contractual disputes or claims) shall be subject to the non-exclusive jurisdiction of the courts of England.
19 NOTICE
All notices given by you to us must be given to Wildstone Capital at 22 Berghem Mews, Blythe Road, London, W14 0HN or via e-mail at info@wildstone.co.uk.
We will give notice to you via the Service or using the contact information you provided to us as part of your registration.
Notice will be deemed received and properly served immediately when posted to the Service, 24 hours after an e-mail is sent, or three days after the date of posting any letter. In proving the service of any notice, it will be sufficient to prove, in the case of a letter, that such letter was properly addressed, stamped and placed in the post and, in the case of an e-mail, that such e-mail was sent to, and received by, the e-mail address provided by the addressee.
20 QUESTIONS OR COMPLAINTS?
20.1 If you have any queries at all regarding the Service, the items featured on the Service or any of the Terms, please contact us by:
(a) sending an e-mail to info@wildstone.co.uk
(b) calling us on 020 7313 9571 or
(c) writing to us at 22 Berghem Mews, Blythe Road, London W14 0HN, marking your letter for the attention of Philip Allard, Chief Operating Officer

Last Updated January 2018

COOKIE POLICY
1 INTRODUCTION
1.1 This Cookie Policy (“Policy “) is intended to inform you about how Wildstone Capital Ltd (“us, “we”, “our”) uses a technology called “cookies” and web server logs. This Policy is intended to assist you in making informed decisions when using our website www.wildstonecapital.co.uk and our services (“Wildstone Service”). Please take a minute to read and understand this cookie policy.
1.2 This cookie policy should also be read in conjunction with our Privacy Notice and our Website Terms of Use.
2 WHAT ARE COOKIES AND WHAT DO THEY DO?
2.1 A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, a computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies.
2.2 Information gathered through cookies may include the date and time of the visits made to a website, the pages viewed and the time spent at a website.
2.3 For further details on cookies, please visit All About Cookies where you can find comprehensive information on cookies and similar technologies.
3 CONSENT TO THE USE OF COOKIES
3.1 By continuing to use the Wildstone Service, you are deemed to consent to our use of the cookies described in this cookie policy. If you do not consent to us using cookies then please read the next section of this cookie policy entitled “Blocking our Use of Cookies”.
4 BLOCKING OUR USE OF COOKIES
4.1 You can block our use of cookies by activating the settings in your browser. Please visit All About Cookies where you can find comprehensive information on cookie management and blocking for a wide variety of browsers.
5 HOW WE USE COOKIES
Analytics
5.1 We use “analytics” cookies which, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our Website and which parts of our Website are most popular. This helps us gather feedback so that we can improve our Website and better serve our users. We do not generally store any personal information that you provide to us in a cookie.
5.2 Most of our cookies expire within 30 days, although some may persist for 2 years.