Therium respects your privacy and is committed to protecting your personal data. This privacy notice tells you how we look after your personal data we receive when you visit our website https://www.therium.com/ and gives you information about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how Therium collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter.
This website is not intended for children and we do not knowingly collect personal data relating to children. Please do not send children’s data to us.
It is important that you read this privacy notice together with any other privacy notice we may provide to you, so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices we give you and is not intended to override them.
The Therium Group is made up of different legal entities. This privacy notice is issued on behalf of the Therium Group so when we mention “Therium”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Therium Group responsible for processing your data. Therium Capital Management Limited is the controller of your personal data and is responsible for this website.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice or your personal data, including any requests to exercise your legal rights, please contact the data privacy manager using the details below.
Our full details are:
Full name of legal entity: Therium Capital Management Limited
Privacy manager contact email address: email@example.com
Postal address: 11 Staple Inn, London WC1V 7QH
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of other websites you visit.
We use different methods to collect data from and about you, including through direct interactions. You may give us your Identity and Contact Data (defined below) by filling in forms or by corresponding with us by post, phone, email or otherwise. We also process the personal data you provide when you:
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which an individual cannot be identified (anonymous data).
We will only process and use your personal data where we have a legal basis for doing so. It’s important to us to explain the legal bases we rely on, which are:
Primarily our legitimate interests are to provide our services to you or other users of our services. The other legitimate interests on which we rely are:
• To ensure that the content on our website is presented in the most effective manner for you and your device and provide you with a safe, efficient and customised experience.
• To allow you to participate in any features on our website when you choose to do so.
• For our own marketing and research interests in promoting our services.
• To deliver our services efficiently.
• To manage and administer your or your organisation’s business relationship with us.
• To make sure we are following our own internal procedures including improving efficiency, training and quality control.
• To protect trade secrets and other commercially valuable information.
• To prevent and detect unauthorised access and modification, criminal activity and minimise fraud that could be damaging for you and/or us.
• To maintain, establish or enforce our legal rights.
• To obtain professional advice or services in relation to our business.
• To identify persons authorised to instruct us and sign any relevant documentation.
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at firstname.lastname@example.org.
This table explains all the ways in which we use your personal data collected through our website, the purpose of collection, and which are the applicable legal bases we rely on to do so. We have also identified the relevant legitimate interests.
|Category of personal data collected||Purpose for collection||Legal basis for processing|
|Identity Data (first name, last name and title)||· To provide services to you.|
· To conduct checks to identify the users of our services and verify their identity.
· To identify persons authorised to instruct us and sign any relevant documentation.
To understand what we think may be of interest to you.
|Contractual obligationLegal obligationLegitimate interests:To deliver our services efficiently;To make sure we are following our own internal procedures;To prevent and detect criminal activity and minimise fraud that could be damaging for you and/or us;To manage and administer our relationship with you;To allow you to participate in any features on our website when you choose to do so; andTo maintain, establish or enforce our legal rights.|
|Contact Data (postal address, email address and telephone numbers)||To ensure our service meets your expectations.To understand what we think may be of interest to you.||Legal obligationContractual obligationLegitimate interests:To deliver our services efficiently;For our own marketing and research interests in promoting our services;To make sure we are following our own internal procedures;To prevent and detect criminal activity and minimise fraud that could be damaging for you and/or us; To maintain, establish or enforce our legal rights; To manage and administer our relationship with you; andTo allow you to participate in any features on our website when you choose to do so.|
|Technical Data (internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website)||To provide statistical analysis to help us manage our business and deliver our services efficiently.To understand what we think may be of interest to you.||Legitimate interests:To ensure that the content on our website is presented in the most effective manner for you and your device and provide you with a safe, efficient and customised experience;To allow you to participate in any features on our website when you choose to do so; For our own marketing and research interests in promoting our services; andTo manage and administer our relationship with you.|
|Profile Data (your interests, preferences, feedback and survey responses)||To analyse and improve our services and communications including through training and quality control.To understand what we think may be of interest to you.||Legitimate interests:To ensure that the content on our website is presented in the most effective manner for you and your device and provide you with a safe, efficient and customised experience;To make sure we are following our own internal procedures including improving efficiency, training and quality control.; To manage and administer our relationship with you;To allow you to participate in any features on our website when you choose to do so; andFor our own marketing and research interests in promoting our services.|
|Usage Data (information about how you use our website)||To create a user profile to personalise our communication and interaction with you.To allow you to participate in features on our website.To make sure we are following internal procedures including improving efficiency, training and quality control.To understand what we think may be of interest of you.||Legitimate interests:To ensure that the content on our website is presented in the most effective manner for you and your device and provide you with a safe, efficient and customised experience;To allow you to participate in any features on our website when you choose to do so; andTo manage and administer our relationship with you.|
|Marketing and Communications Data (your preferences in receiving marketing from us and your communication preferences)||· To provide general direct marketing for mailing list subscription.|
· To keep you up to date on the latest news, announcements, events and other information which we feel would be of interest to you.
Sharing for marketing purposes with third parties.
We may also collect and use aggregated data, such as statistical or demographic data, for various purposes. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. Where aggregated data does not directly or indirectly reveal your identity, we do not treat it as personal data. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data. This will be used as set out in this privacy notice.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We also do not undertake any automated decision-making about you using your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive marketing communications from us if you have requested information from us or if you otherwise provided us with your details and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Therium group of companies for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at email@example.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for a different purpose.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data in the following ways for the purposes set out in the table above.
We require all third parties (within and outside the Therium Group) to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data within the Therium Group. In certain circumstances, this may involve transferring your data outside the United Kingdom (“UK“) or European Economic Area (“EEA“).
We will only transfer your personal data outside of the UK or EEA where:
Whenever we transfer your personal data out of the UK or EEA, we follow the requirements of applicable data protection legislation, case law and mandatory codes of practice. This means that we apply safeguards whenever personal data is transferred outside of the UK or EEA. These safeguards include contractual obligations on the recipients of your data, to protect your personal data to the standard required in the UK or EEA. Recipients may also be required to subscribe to international frameworks designed to enable secure data sharing.
Please contact us at email@example.com if you want further information on the specific mechanisms used by us when transferring your personal data out of the UK or EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it. These purposes are those set out in section 3 above.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Please contact us at firstname.lastname@example.org for details of retention periods for different aspects of your personal data.
In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information without further notice to you.
Under certain circumstances, you have the following rights under applicable data protection law in relation to your personal data.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee, as permitted by applicable data protection law, if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month, if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.