Privacy Policy

1. Introduction

SBlocPortM Limited ("we," "our," or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website sblocportm.com or engage with our legal investment advisory services.

This Privacy Policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are registered with the Information Commissioner's Office (ICO) under registration number [Registration Number].

Data Controller

SBlocPortM Limited is the data controller for the purposes of UK data protection legislation. Our registered office is at:

2. Information We Collect

We collect information about you in various ways when you use our services:

2.1 Information You Provide Directly

• Contact Information: Name, email address, phone number, postal address
• Professional Information: Company name, job title, industry, investment interests
• Communication Records: Records of correspondence, meeting notes, consultation details
• Financial Information: Investment capacity, portfolio details (where relevant to our services)
• Identity Verification: Documentation required for know-your-customer (KYC) and anti-money laundering (AML) compliance

2.2 Information Collected Automatically

• Website Usage Data: IP address, browser type, pages visited, time stamps, referring URLs
• Device Information: Device type, operating system, unique device identifiers
• Location Data: General geographic location based on IP address
• Cookies and Tracking Technologies: As described in our Cookie Policy

2.3 Information from Third Parties

• Professional Networks: Information from business networking platforms (with your consent)
• Public Sources: Publicly available information relevant to our professional relationship
• Service Providers: Information from technology providers supporting our services

3. How We Use Your Information

We use your personal information for the following purposes, based on legitimate legal grounds:

3.1 Service Provision (Contract Performance)

• Providing legal investment advisory services
• Conducting due diligence and compliance checks
• Preparing investment documentation and agreements
• Managing client relationships and communications

3.2 Legal Obligations

• Compliance with financial services regulations
• Anti-money laundering and counter-terrorism financing checks
• Record keeping requirements under legal and professional standards
• Tax reporting obligations

3.3 Legitimate Interests

• Business development and marketing communications
• Website analytics and improvement
• Security monitoring and fraud prevention
• Research and analysis for market insights

3.4 Consent

• Newsletter subscriptions and marketing communications
• Optional cookies and tracking technologies
• Special category data processing (where applicable)

4. Information Sharing

We may share your personal information in the following circumstances:

4.1 Professional Service Providers

• Legal Counsel: External barristers and solicitors supporting our services
• Technical Advisors: Specialist consultants for due diligence and technical assessments
• Financial Institutions: Banks and financial service providers facilitating transactions
• Regulatory Bodies: Where required for compliance or investigation purposes

4.2 Technology Service Providers

• Cloud hosting and data storage providers
• Email and communication platform providers
• Website analytics and marketing technology providers
• Cybersecurity and data protection service providers

4.3 Legal Requirements

• Government agencies and regulatory authorities
• Law enforcement agencies (where legally required)
• Courts and tribunal proceedings
• Professional conduct investigations

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to appropriate data protection safeguards.

5. Data Security

We implement comprehensive security measures to protect your personal information:

5.1 Technical Safeguards

• Encryption of data in transit and at rest
• Multi-factor authentication for system access
• Regular security updates and patch management
• Intrusion detection and monitoring systems

5.2 Organizational Measures

• Staff training on data protection and confidentiality
• Access controls and privilege management
• Regular security audits and assessments
• Incident response and breach notification procedures

5.3 Physical Security

• Secure office premises with access controls
• Locked storage for physical documents
• Secure disposal of confidential information
• Clean desk and clear screen policies

6. Your Rights

Under UK data protection law, you have the following rights regarding your personal information:

6.1 Right of Access

You can request a copy of the personal information we hold about you, along with information about how we process it.

6.2 Right to Rectification

You can ask us to correct any inaccurate or incomplete personal information we hold about you.

6.3 Right to Erasure

In certain circumstances, you can request that we delete your personal information, subject to legal and professional obligations.

6.4 Right to Restrict Processing

You can ask us to limit how we use your personal information in specific circumstances.

6.5 Right to Data Portability

Where technically feasible, you can request a copy of your personal information in a structured, machine-readable format.

6.6 Right to Object

You can object to processing based on legitimate interests, including direct marketing.

6.7 Rights Related to Automated Decision-Making

You have rights regarding automated decision-making and profiling, though we generally do not engage in such activities.

6.8 Exercising Your Rights

To exercise any of these rights, please contact us using the details provided in Section 11. We will respond within one month of receiving your request.

7. Cookies and Tracking Technologies

Our website uses cookies and similar technologies. For detailed information about our use of cookies, please see our separate Cookie Policy.

7.1 Cookie Categories

• Necessary Cookies: Essential for website functionality
• Analytics Cookies: Help us understand website usage
• Marketing Cookies: Used for targeted advertising (with consent)

7.2 Managing Cookies

You can manage your cookie preferences through our cookie banner or your browser settings. Disabling certain cookies may affect website functionality.

8. Data Retention

We retain personal information only as long as necessary for the purposes outlined in this Privacy Policy:

8.1 Client Data

• Active Clients: Duration of the professional relationship plus 7 years
• Former Clients: 7 years from end of relationship (regulatory requirement)
• AML/KYC Data: 5 years from end of business relationship

8.2 Marketing Data

• Newsletter Subscribers: Until unsubscribed plus 2 years
• Website Analytics: 26 months (Google Analytics standard)
• Contact Inquiries: 3 years from last contact

8.3 Legal Holds

We may retain information longer if required for legal proceedings or regulatory investigations.

9. International Transfers

We primarily process personal information within the United Kingdom. When we transfer information internationally, we ensure appropriate safeguards:

9.1 Adequacy Decisions

We may transfer data to countries with UK adequacy decisions, providing equivalent protection to UK GDPR.

9.2 Standard Contractual Clauses

For transfers to other countries, we use Standard Contractual Clauses approved by UK authorities.

9.3 Certification and Codes

We may rely on approved certification schemes and codes of conduct for international transfers.

10. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will:

• Post the updated policy on our website
• Update the "last modified" date
• Notify you of material changes via email or website notice
• Obtain consent for material changes where required

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

11. Contact Information

If you have questions about this Privacy Policy or our data practices, please contact us:

Data Protection Officer

Email: [email protected]
Phone: +44 20 7946 0958

Supervisory Authority

You have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: ico.org.uk
Helpline: 0303 123 1113