Privacy Policy

Bread Street Capital Partners is committed to protecting your personal information. Bread Street Capital Partners is a trading name of Bread Street Capital Ltd, and may periodically be abbreviated in this and other documentation or communications to ‘Bread Street’, ‘Bread Street Capital’ or ‘the Company’.

Our Privacy Policy contains important information about what personal details we collect or intend to collect; what we do with that information; who we might share it with and why; and your choices and rights when it comes to the personal information you may have given us.

We are committed to keeping this Policy updated. This Privacy Policy was created on 24 March 2021 and adopted by the Bread Street Capital Partners’ Executive Committee on 30 March 2021, with latest revisions dated 18 May 2021.

Who we are

We are Bread Street Capital Partners Ltd, a UK company that intends to offer specialist private equity and other niche investment management advisory services via an appointed Alternative Investment Fund Manager (‘AIFM’) to qualified professional and/or institutional investors domiciled (initially) in the UK, and subject to appropriate regulatory consents.

This Privacy Policy applies to Bread Street Capital Partners Ltd and other subsidiary undertakings that may be incorporated before the next version of this policy.

This Privacy Policy will apply to any investment companies or and funds advised by Bread Street Capital Partners unless stated otherwise.

How to contact us

If you have any questions about our Privacy Policy or the information we collect or use about you, please contact us:

By letter

FAO Data Protection Officer, Hamilton House, 1 Temple Avenue, LONDON, EC4Y 0HA

By Email

hello@breadstreetcapital.com

Information we collect and use

Information about you that we collect and use includes:
Information about who you are e.g., your name and contact details. We may ask for date of birth under certain circumstances.
Information connected to your product or service with us e.g., your bank account details
Information about your contact with us e.g., meetings, phone calls, emails / letters
Information that could be automatically collected e.g., via cookies when you visit our website

Where we collect and/or use any sensitive personal information, this information will only be collected and used where it is needed to provide the product or service you have requested or to comply with our legal obligations, and where we have also obtained your explicit consent to process such information.

Where we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

  • Phone conversations with us
  • Emails or letters you send to us
  • Via our website
  • Meetings with one of our Directors or Employees
  • Participating in research surveys to help us understand you better and improve our products and services

We may also collect personal information about you from places such as business directories and other commercially or publicly available sources e.g., to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.

Website

Our website is owned and operated by Bread Street Capital Partners Ltd. Please read this Privacy Policy in conjunction with our website Terms of Use.

By visiting the website and engaging with our systems, you are accepting and consenting to the practices described in this policy. If you have any questions, concerns or wish to discuss any of this please contact us via the contact details above.

Our website utilises two sources of your personal information:

Information we collect about you.

When you visit and browse our website, we will automatically collect technical information (such as your IP address and other information that your browser makes available to us) and information about your visit (such as pages you viewed, length of time on site, any items downloaded).

When you visit and browse our website.

The information you give us, or we collect, will be held in our analytics software, Google Analytics and our website development and hosting software, WordPress. We will use this information solely for the purposes of:

  • understanding which pages and features are useful and interesting
  • improving the website
  • understanding our website visitors and their use patterns

Cookies

We may use cookies, small files stored on your hard drive, to monitor your use of the site whilst you access it. They help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. To find out more about cookies and how to control them, visit https://ico.org.uk/for-the-public/online/cookies/.

Cookies that may be used by our website

  • Necessary cookies. These are essential for the website to function properly. This category only includes cookies that ensure basic functionalities and security features of the website. These cookies do not store any personal information.
  • Google Analytics cookies. These are used for performance, functionality and website performance monitoring. You can opt-out of Google Analytics by visiting this website https://tools.google.com/dlpage/gaoptout.
  • 3rd party analytics cookies. We do not currently use third-party cookies that are not be necessary for the website to function and which would be used specifically used to collect personal data via analytics, ads, and other embedded content. We would need your consent before running these cookies on our website.

Why we collect and use your information

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only if we are able to satisfy one of the lawful processing conditions set out in relevant data protection laws. We will, as our business develops, set out here examples where this might be the case. We would anticipate these being scenarios involving you where:

  • It is necessary to provide the product or service you have requested
  • It is necessary for us to meet our legal or regulatory obligations
  • It is in the legitimate interests of Bread Street Capital Ltd i.e., to deliver appropriate information or send you more relevant information about concept products or products in development

You have given us your consent to use your information in this way.

If you do not wish us to collect and use your personal information in these ways it may mean that we will be unable to provide you with certain services or future products.

Who we share your information with and why

We may share your information internally, and with third parties for the reasons outlined in ‘Why we collect and use your information’.

We might be obliged to share your information with:

  • Our AIFM
  • Our AIFM’s regulators; including the Financial Conduct Authority and the Information Commissioner’s Office (the ICO) in the UK
  • Law enforcement and other appointed agencies in the prevention and detection of crime

Where your information is processed

All your information is processed by us in the UK, other than we may periodically make records of telephone conversations, business meetings and/or the Company’s operating committees, whilst periodically in other countries. That data is never sent externally and only over ever kept within the Company’s secure digital infrastructure.

How we protect your information

We take information and system security seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our Directors (and employees) will also protect sensitive or confidential information when storing or transmitting information electronically and have undertaken past annual training on this as part of their regulated control functions, and will continue to undertake annual training.
Appropriate security controls are embedded within our operating architecture and employees maintain industry standards and good practice with regard to personal computers, filing and data destruction.

Bread Street Capital Partners strives at all times to effectively manages risks to the confidentiality, integrity and availability of your information.

How long we keep your information

To provide your product or investment, and meet our UK legal and regulatory obligations, we will keep your personal information and copies of records we create when you become (and while you are) a client or customer of ours.

Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary and we will regularly review our retention periods to make sure they comply with all laws and regulations.

Your rights

You have rights under data protection laws which may be exercised in certain circumstances.

These are:

  • the right to be informed about how and why we are processing your personal information
  • the right of access to personal information relating to you
  • the right to rectification of inaccurate or incomplete personal information
  • the right to request erasure of your personal information
  • the right to restrict processing of your personal information
  • the right to data portability
  • the right to object to processing of your personal information (e.g., profiling or direct marketing)
  • the right not to be subject to automated decision making (including profiling) which significantly or legally affects you

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in this Privacy Policy, please let us know immediately (see ‘How to contact us’ section) and we will do our best to fix the issue.
While we hope that we can resolve any complaints for you, you do have the option complain to your local data protection authority (e.g., the ICO in the UK). This is available to you whether or not you have exhausted our complaints procedure.

The UK data protection authority’s details are:

The Information Commissioner’s Office
Phone helpline (UK): 0303 123 1113
Phone helpline (outside UK): +44 1625 545 700
Email: casework@ico.org.uk
Website: https://ico.org.uk/concerns/

Postal address:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Contact Us

Bread Street Capital Partners is a founder owned investment partnership focussed on delivering and managing innovative, differentiated private market products. We help a full range of institutional and professional clients meet their investment needs.

Responsible | Client driven | Trusted

Bread Street Capital Partners Ltd
Hamilton House,
1 Temple Avenue,
London, EC4Y 0HA

Call us on +44 (0) 20 3727 6170


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