Privacy notice

Introduction

“We”, “us”, “our” and “GreenHearth Capital” for the purposes of this notice mean GreenHearth Capital Limited, a limited liability company incorporated in England and Wales with registered number 16686160 and a data controller for the purposes of data protection law.

About this privacy notice

GreenHearth Capital is committed to protecting the privacy and security of your personal information.

GreenHearth Capital finances, owns, operates and maintains energy transition assets for commercial and industrial companies. We need to collect personal data from potential clients, clients, introducers, lenders, suppliers, visitors to our website and other third parties to ensure we can provide these services and discharge our obligations to clients, lenders and others.

This privacy notice sets out the basis on which any personal information about you will be processed by us. This privacy notice may be updated from time to time.

Data protection principles

We will comply with data protection law. This means that the personal data we hold about you must be:

• used lawfully and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as necessary for the purposes we have told you about; and
• kept securely.

Personal information we collect about you

We will collect and process various types of personal information about you.

This includes information that you provide to us by communicating with us, whether face-to-face, by phone, email or otherwise; information we collect or generate about you, such as call recordings or information relating to your use of our technology platforms; information that we obtain from other sources, for example publicly available sources such as the press, electoral register, company registers, online search engines and social media; or information provided by third parties, such as credit reference, fraud prevention or government agencies.

This information may include:

• contact details such as your name, address and email address;
• profile data including your date of birth, gender, social media profiles, marital status, dependants and general lifestyle information;
• identification and official documents such as a driving licence or passport;
• your income or financial statements, assets and liabilities, payment history, bank details and credit history;
• communications to and from us;
• information stored or processed on our IT systems, website, databases and document management systems;
• technical information about your computing devices and internet usage, including use of our website, IP addresses, browser, operating system and antivirus software; and
• marketing and communications preferences.

Where permitted by law, the information may also include the following more sensitive types of personal data:

• any public or political positions you hold, or those held by people close to you, for the purposes of assessing whether you are a politically exposed person;
• criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as performing checks to prevent and detect crime and complying with laws relating to money laundering, fraud, terrorist financing, bribery, corruption and international sanctions; and
• information about vulnerability.

If you provide us with personal data relating to a third party, for example information about your spouse, children, parents or referees, you represent to us that you have obtained that person’s prior consent to provide the data to us.

For prospective clients, lenders, introducers and other third parties, our processing is also necessary for our legitimate interests because we need to collect this information to contact individuals in these organisations before entering into a contract or providing our services.

For example, we may collect information from online enquiries, quotes and referrals. Some of this information may also be collected from publicly available information, market research and purchased data.

Uses of your personal information

Your personal information may be processed in the following ways and for the following purposes:

• for the day-to-day management of our business and our relationship with you;
• with your permission, to market to you;
• to check your identity and background and process and manage the activities we carry out, including assessing suitability;
• to carry out screening against external databases, company records and sanctions lists and to establish connections to politically exposed persons, including adverse media checks. This may include information relating to criminal offences obtained from screening;
• with your explicit permission, to carry out credit checks to support the preparation of lending proposals;
• to monitor and record communications of any nature for or with the company. We will comply with applicable laws and regulations when doing so. Such recordings may be used for training and development and as evidence in the event of a dispute with you or a third party;
• to monitor and record your use of technology to protect the company, our employees, our customers and their data; and
• for analysis of our business and the creation of reports and research.

We are entitled to use your personal information in these ways because:

• it is necessary for the performance of our contract with you, for example for the provision of our services;
• we have legal and regulatory obligations to prevent and detect crime, money laundering, fraud, terrorist financing, bribery and corruption and to comply with international sanctions;
• the use of your personal information is necessary for our legitimate business interests in the course of running our business or to establish, exercise and defend our legal rights;
• in relation to processing information about criminal convictions or offences, it is necessary to comply with relevant laws and regulations, prevent or detect unlawful acts, exercise or defend our legal rights or act in connection with legal proceedings; or
• we have obtained your explicit consent.

Disclosure of your information to third parties

We may need to share your personal information with third parties including:

• other entities in our group structure;
• credit reference and fraud prevention agencies for the purposes of confirming your identity and complying with regulatory obligations to prevent and detect crime, money laundering and fraud;
• third-party lenders, suppliers, agents or vendors for the purposes of providing services to us, including third parties carrying out due diligence and screening checks on our behalf;
• a prospective buyer if we sell or finance any of our business or assets or if we are acquired by a third party, for due diligence purposes;
• courts, regulators such as the Financial Conduct Authority, government bodies and similar organisations as required by law;
• compliance departments of third parties with whom we both have relationships where they reasonably request it;
• corporate auditors and legal or other advisers; and
• other parties where necessary to comply with a legal obligation or to establish, exercise or defend our legal rights.

Safeguards when sharing information

Where we share your data with third parties, we ensure that they are subject to confidentiality requirements and are authorised to use your personal information only as described in this privacy notice.

No searches with credit reference agencies that leave a record on your personal credit file will be carried out without your explicit consent.

Your personal information may be transferred outside the United Kingdom and processed by us or third parties. We require anyone to whom we pass it to protect it in the same way we would and in accordance with applicable laws.

Data security

We use appropriate security measures to prevent personal data from being accidentally lost, used, accessed, altered or disclosed without authorisation.

Access is limited to employees, agents, contractors and other third parties with a business need to know. They act on our instructions and are subject to confidentiality duties.

Retention of personal information

Your information will be retained in line with our internal records management policies and retention schedules.

How long we hold your personal information will vary according to the type of record, the purpose for which we use it and any minimum period required by law or regulation. The retention period will typically be seven years after the end of your relationship with us.

We may exceptionally retain information for longer, particularly where destruction or disposal must be withheld because of a court order or an investigation by a law enforcement agency or regulator.

In some circumstances we may anonymise your personal data so it can no longer be associated with you, in which case we may use it without further notice.

Duty to inform us of changes

It is important that the personal data we hold about you is accurate and current.

Your rights

You have a number of legal rights in relation to the personal information that we hold about you. These include:

• the right to be informed about how we use your data;
• the right to obtain information about our processing and access the personal information we hold about you;
• where we rely on consent, the right to withdraw that consent at any time;
• in some circumstances, the right to receive certain personal information in a structured, commonly used and machine-readable format and ask us to transmit it to a third party where technically feasible;
• the right to ask us to correct personal information that is inaccurate or incomplete;
• the right to ask us to erase personal information in certain circumstances, subject to any right or obligation we have to retain it;
• the right to object to or ask us to restrict processing in certain circumstances; and
• rights relating to automated decision-making and profiling, including the right not to be subject to automated decisions that adversely affect your legal rights.

You can read more in the ICO guide to individual rights.

In some cases, exercising your rights may mean that we are no longer able to offer you our services.

Changes

We will use your personal data only for the purposes for which we collected it, unless we reasonably consider that we need to use it for a compatible reason.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We may update this privacy notice at any time and will notify you of material changes where appropriate.

Complaints

If you have a concern about our privacy practices, please contact us using the details below. We will act on your complaint promptly.

If you are not satisfied with our response, you may complain to the Information Commissioner’s Office. Details are available on the ICO complaints page, or you can call its helpline on 0303 123 1113.

Contact us

For information about how we collect, use, disclose, transfer or process personal information, or to exercise any of the rights above, contact us: