PRIVACY POLICY
This privacy policy (the “Policy”) describes how Scion collects, uses and shares the personal information you provide to us and the information we collect in the course of operating our business and our website.
By using this website you will be deemed to accept the terms of the Policy.
In this Policy when we refer to Scion or “we”/“us”/“our” we mean Scion Investment Group LLP, Scion Films LLP, Scion Limited, Scion Investment Financing Limited or any of their affiliates (each individually and collectively “Scion”). Further details of each entity for the purposes of the Policy are set out in the table below. We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.
The information that we collect and where we get it from
"Personal Information" is any information that can be used to identify you or that we can link to you and which we have in our possession or control.
We will collect and process the following Personal Information about you:
Clients
We will collect Personal Information about you when you contact us about providing services to you (for example, your name, address, email contact details, telephone number, bank account details, UTR/tax reference number, details of your broker/financial/legal adviser, subscription details i.e. shareholdings for subscription to companies / contribution(s) to partnership (capital and loan amounts, as applicable) and methods of contribution).
We may require further Personal Information from you (for example, your passport or other ID) in order to comply with our regulatory requirements. We may also collect Personal Information about you from publicly accessible sources, e.g. Companies House or HM Land Registry for client due diligence purposes.
During the course of providing services to you, we may collect Personal Information about you and/or any other individuals you tell us about.
Depending on the nature of the work we carry out for you, we may collect and use special categories of Personal Information about you or a third party you tell us about (for example, Personal Information about health, race or ethnic origin, religious or philosophical beliefs, bankruptcy, and/or trade union membership).
Visitors to our website
We will collect Personal Information that you voluntarily provide to us if you contact us through our website. This information may include your contact details including name, address, email, telephone number.
We use a third-party data processor, Dijit New Media Ltd, to host our website and help maintain its security and performance. To deliver this service it processes the IP addresses of visitors to the Scion website.
People who contact us via social media
If you send us a private or direct message via social media viz. Linked In, we may share this information with Scion personnel (for example, in order to respond to a specific query or to pass on information).
Queries and complaints
If you send a query or complaint to us, we will use the Personal Information you provide to us (for example, your name and the name(s) of any other individuals involved) in order to process your query or complaint and respond to you.
How we use your information
We only ever use your Personal Information if we are satisfied that it is lawful and fair to do so because:
- it is necessary to enter into, or perform, a contract with you;
- in order to comply with a legal obligation;
- for our own legitimate interests provided your rights don’t override these interests.
We will never sell your personal data or share it with third parties who might use it for their own purposes.
Sharing your information
We will not disclose any Personal Information you provide to any third parties other than:
- where you have given us consent to share the information;
- it is necessary to enter into, or perform, a contract with you;
- where we instruct professional advisors on your behalf;
- where necessary to carry out your instructions;
- where information such as email addresses is passed to our third-party service providers, who provide operational and technical support in order to make the delivery of our services more efficient.;
- if we are under a legal or regulatory duty to disclose or share your personal information (for example, if required to do so by HM Revenue & Customs, a court order or for the purposes of prevention of fraud or other crime or in relation to audits, enquiries or investigations by regulatory bodies);
- in order to enforce any agreements or terms and conditions between us;
- as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation (we will always notify you in advance and we will aim to ensure that your privacy rights will continue to be protected);
- to protect our rights, property and safety, or the rights, property and safety of others (this includes exchanging information with our insurers, other companies, organisations and regulators for the purposes of fraud protection and credit risk reduction).
Data security
We have appropriate security measures in place to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We hold data electronically in a secure location and on our on-site file servers. Network infrastructure is protected using firewalls and anti-malware software. We also have back-up servers in secure locations.
We store papers which may contain Personal Information in lockable storage in our offices when not being actively used and we have a secure off-site document storage facility for archived papers. Our offices are secure and only personnel holding appropriate security passes can access areas where personal data are stored.
When necessary, we dispose of or delete your data securely.
We ensure that our employees, agents and contractors are aware of their privacy and data security obligations and we take reasonable steps to ensure that employees of third parties working on our behalf are aware of their privacy and data security obligations.
We limit access to your personal information to those employees, agents, contractors and other third parties who have a “need to know”.
We may give third parties access to the personal information we hold about you in order to comply with our regulatory obligations.
The transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your electronic information transmitted to us and any transmission is at your own risk.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Transferring your information outside the European Economic Area (EEA)
We do not transfer the information you give us to countries outside the EEA, except where the international transfer is necessary in connection with the services we are providing to you.
If we transfer your information outside of the EEA in this way, and the country in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.
If you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services. By submitting your personal information to us in this way you agree to the transfer and processing of your information outside the EEA.
Data retention
We have a Retention and Archiving Policy which sets out our approach to the retention and deletion of the personal information we hold about you either in computer or manual files.
We will hold the information for as long as required by law or our regulatory obligations. Our default retention period for personal data is the later of seven years from the collection of the Personal Information or the termination of any contract with you unless otherwise specified by law.
Please note that Personal Information held on our client files may be retained for longer periods as it may be necessary to retain this data in order to protect legal rights and claims. Personal Information retained for longer periods may be securely stored in archive, either physically or digitally. These archives will not be generally accessible by our staff unless it is necessary in the context of a legal claim or there is another overriding reason which justifies access to this data.
In relation to Personal Information that we receive through unsuccessful applications for job vacancies, our default retention period is for 12 months from the date of our last interaction with you. If your application is successful, the personal data that you provide during the application process will be retained by us as part of your employee file.
These retention periods may be extended or reduced if we deem it necessary (for example, to defend legal proceedings or if there is an on-going investigation relating to the information).
We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
Your rights
Under certain circumstances, by law you have the right to:
- request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
- ask us to correct any information that we hold about you which is incorrect, incomplete or inaccurate;
- ask us to erase your personal information from our files and systems where there is no good reason for us continuing to hold it;
- object to us using your personal information to further our legitimate interests (or those of a third party) or where we are using your personal information for direct marketing purposes
- ask us to restrict or suspend the use of your personal information, for example, if you want us to establish its accuracy or our reasons for using it;
- ask us to transfer your personal information to another person or organisation.
Table of Scion data controllers
| Data controllers | ICO registration Numbers |
|---|---|
| Scion Investment Group LLP | Z1451005 |
| Scion Solar LLP | ZA012530 |
| Scion Hotel Operations (Liverpool) LLP | ZA013523 |
| Scion Hotel (Liverpool) LP | ZA365552 |
| Scion Partnership Services Limited | ZA433161 |
| Scion Hotel Operations (Glasgow) LLP | ZA057909 |
| Scion Hotel (Glasgow) LP | ZA365543 |
| Scion Hotel Operations Limited | ZA433165 |
| Scion Films Consultants Limited | Z877937X |
| Scion Films LLP | Z877943X |
| Scion Financial Partners Limited | Z8779335 |
| Scion Investment Financing Limited | Z8779397 |
| Scion Administrative Services Limited | ZA383042 |
| SIF UK Limited | ZA383115 |
| Scion Productions (Uk) Limited | ZA604474 |
If you have any questions about this privacy notice or how we handle your personal information, please contact support@scionadmin.com or call us on 0207 851 5740.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
Policy last updated: 25 May 2018