Schulenburg Capital Limited (company number: SC463097), 15 Atholl Crescent, Edinburgh, EH3 8HA, UK (us or we) is committed to ensuring that your privacy is protected, and all data collected by us will be processed in accordance with this privacy and cookies policy. Please read this policy carefully to ensure you understand our views and practices regarding your personal data and how we will treat it.
For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR), the data controller is Schulenburg Capital Limited. We can be contacted at email@example.com or at +44 (0) 131 557 6644
By visiting our Site or by providing us with information you are accepting the practices described in this Privacy and Cookies Policy.
WHAT INFORMATION WE PROCESS
We may collect and process the following information from you:
information about you – including your name, email address, phone number, address, organization, and position – that you give us or a member of our staff. This information can be collected when you send us an email enquiry and provide this information, give us or a member of our staff your information in person (e.g. by providing a business card), or by filling in the contact form on our website https://www.schulenburgcapital.com/ (our Website).
information we may automatically collect such as technical information including the internet protocol (IP) address used to connect to the internet, and information about your visit including the full Uniform Resource Locators (URL) clickstream.
How do we use your personal data?
- When you provide us with your information we will use it for the purpose of administering your query and responding to you. We therefore have legitimate interests in processing your personal data in this way, since if we do not process your data we will be unable to do this.
- If we have sold, or negotiated to sell, our products to you in the past, then we may use your information to contact you for marketing purposes. We have a legitimate interest in processing your data in this way, since it helps us determine which of our products might be useful to you. You have the right to object to being contacted for such purposes; if you do, we will stop processing your data in this way unless you later ‘opt-in’ to receiving such materials (see 2.3).
- With the exception of condition 2.2, we will not further process your personal details to send you marketing information that you have not requested unless you provide your consent by ticking the opt-in box provided on our marketing consent form. Any consent that you provide can be withdrawn at any time by clicking the "Update my Contact Preferences" link on any marketing email we send to you, or emailing us at firstname.lastname@example.org. Withdrawing your consent does not affect the lawfulness of any processing which occurred prior to the withdrawal of consent.
- We may also use your personal information:
- to help us provide you with the best possible service;
- to notify you about changes to the services we offer;
- to ensure that the content from our Website is presented in the most effective manner for you and your computer;
- as part of our efforts to keep our Website safe and secure; and
- for analytical and statistical purposes.
Disclosure of Information
- We will only supply your personal information to a third party:
- where we need to share the information to provide a product or a service requested by you;
- where we need to send the information to persons or organisations who work on our behalf to provide a product or service to you, but such persons or organisations may only use this information in order to provide such product or service and not for any other purpose;
- companies which perform marketing services on our behalf or with whom we have joint marketing agreements, where we have your consent to share the information;
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
Where we store your information
- The data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers for the purposes set out above only. In order to ensure that any third party treats your personal data in a way which is consistent with the UK and EU's laws on data protection, we have put in place agreements with those third parties which contain provisions approved by the EU for protecting personal data.
- We will retain your information for six (6) years, after which time it will be destroyed.
IP addresses and cookies
- We may obtain information about your computer and general internet usage, including your IP address, operating system and browser type, for system administration purposes.
- Cookies contain information that is transferred to your computer's hard drive. Cookies allow us to tailor our Website to your needs by gathering and remembering information about your usage and preferences.
- In particular, cookies enable us:
- to gather information on IP addresses and pages visited;
- to analyse trends;
- to administer the website;
- to track users’ movements on the website; and
- to undertake statistical analysis.
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
- The table below provides more information about the cookies we use and why:
|Name of cookie
||Purpose for the cookie
|Session Cookies (JSESSIONID)
||Created when a new session is started (you connect to our website) and deleted when the session ends. Allows our server to temporarily identify your web browser to ensure that we are providing you with the content you are requesting.
- Most browsers allow you to refuse to accept cookies; for example:
in Firefox (version 51) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites";
in Chrome (version 55), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading; and
in Internet Explorer (11) you can turn “Cookies” off by opening Internet Explorer, click Internet options and select the “Privacy” tab. Under “Settings” move the slider to the top or bottom to decline or allow “Cookies” by selecting high or low and then press “apply”.
- You can delete cookies already stored on your computer; for example:
in Firefox (version 51), you can delete all cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history" from the drop-down menu, clicking "Show Cookies", and then clicking "Remove All Cookies";
in Chrome (version 55), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data"; and
- In Internet Explorer (11) you can select the safety button and then select Delete Browsing History. Then select the check box next to “Cookies”. Select the preserve favourites website data check box if you don’t want to delete the “Cookies” associated with website in their favourites list. Select delete.
Links to other websites
- This policy extends only to our Website and does not cover your use of, provision of data to and collection of your data on any other website.
- Our Website may from time to time contain links to and from other websites. If you follow a link to any of these websites please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You should always check these policies before you submit any personal data to any third party website.
your rights in respect of your information
The GDPR gives you a number of rights in respect of your data, including:
- Right to access
You have the right to access the information we hold about you. If you would like a copy of this information please contact email@example.com. We may request proof of your identity before sharing such information.
- Right to rectify your personal data
If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information. You can do so by clicking on the “Update my Contact Preferences” link at the bottom of any emails we send, or by contacting us at firstname.lastname@example.org
- Right to be forgotten
You may ask us to delete information we hold about you in certain circumstances. It may not be possible for us to delete all of the information we hold about you where we have an ongoing relationship, however please contact us at email@example.com and we will do our best to assist with your request.
- Other rights
In addition to the above, you may also ask us to stop or restrict processing of the information we have about you. You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any other information on these aspect of your rights, please contact us at firstname.lastname@example.org.
- If you have any questions, want to exercise any of your rights or make a complaint, please contact us using the details at the beginning of this policy.
- If we are unable to resolve your complaint you may contact the Information Commissioner's Office at the Exchange Tower, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tele: 0303 123 1113.
This policy may be reviewed and amended from time to time. As a result of improvements we make to our services, changes in the law or developments in technology, we may change the information we hold about you, the method and purposes for which we process such information. If we make any substantial change in the way in which we use your personal information we will notify you by email.
Law and Jurisdiction
Your use of the Website and the policy is subject to the laws of England and Wales and the exclusive jurisdiction of the English courts regarding any disputes that may arise under it.