affiliations and/or of our relationship with you as necessary to enable us to meet applicable laws and regulations.

We will also collect device and session data when you are visiting our website, such as the IP address of the requesting device, date and time of access, name and URL of the retrieved file, website from which access is made (referrer URL), used browser and if applicable, the operating system of your computer as well as the name of your access provider. Further, we will collect details on the device you are browsing from, its operating system, and your browsing behaviour on the website.

The legal basis for using your personal information

We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

• our use of your personal information is in our legitimate interest as a commercial organisation (for example to respond to new or existing customers queries, to manage our relationship with our clients and connected parties etc.) – in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing;
• where necessary to establish, exercise or defend legal rights or for the purpose of legal proceedings; and
• our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example for anti-money laundering checks and monitoring).Generally we do not rely on consent as a legal basis for processing your personal data. Where we do so we will clearly request, obtain and document your consent.

  If you would like to find out more about the legal basis for which we process personal information please contact us.

3. DISCLOSURE OF YOUR PERSONAL DATA

We share your information in the manner and for the purposes described below:

1. within Aergo and other companies within our group, where such disclosure is necessary to provide you with our services or to manage our business;
2. with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include our IT service providers, tax advisors, legal advisors and auditors; and
3. with government organisations and agencies, law enforcement, regulators to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.

If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.

4. EXPLAINING MORE ABOUT DIRECT MARKETING

We may send you email marketing communications about Aergo services from time to time that we believe will be of interest to you. If you no longer want to receive such emails from us, please contact us.

5. TRANSFERRING PERSONAL INFORMATION GLOBALLY

Aergo operates on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the UK and European Economic Union, that are subject to different standards of data protection. Aergo will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.

For more information about the safeguards we have put in place relating to transfers, please contact us.

6. HOW WE PROTECT AND STORE YOUR INFORMATION

Security

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned. Measures we take include placing confidentiality requirements on our staff members and service providers; destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected.

Storing your personal information

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

7. YOUR RIGHTS AS A DATA SUBJECT

In certain jurisdictions, you have a number of rights in relation to your personal information, including the right of access, to ask us to correct inaccurate data; to ask us to restrict or delete data in certain circumstances; to object to particular processing based on legitimate interest grounds; to withdraw consent in the limited circumstances where we may rely on consent; and to complain to the relevant supervisory authority.

8. CONTACT US

If you have any questions or queries relating to this privacy notice, please contact us at: notices@aergocapital.com
or

Aergo Capital Limited
2nd Floor, Embassy House Herbert Park Lane Ballsbridge
Dublin 4
Ireland
+353 1 676 1077

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

Last updated: 26 May 2021