Aspen Capital is committed to protecting and respecting your privacy.
When we mention “Aspen”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Aspen Capital responsible for processing your personal data (sometimes referred to in this notice as “personal information”).
This privacy notice explains how and why Aspen uses personal data when you visit our website (www.afmcapital.com), regardless of where you visit from, purchase goods or services from us or otherwise communicate or engage with us.
Sources of personal information
Aspen collects and uses limited personal data about individuals save for its employees. Where it does use such personal data, this will normally be incidental to a corporate relationship with a customer or supplier or where we work with nominated contacts at such organisations who hold relevant positions, such as a contract manager, counterparty contact or key decision makers in respect of our business relationship. In this case we will use work based contact information about you to liaise and keep in touch with you, as a representative of your employer or organisation in relation to our business relationship with them.
Aspen cannot identify you personally as a user of its website and save for dealing with any cyber security incident investigation, will not try to identify you from any online identifiers like your IP address.
Aspen may obtain personal data about you otherwise where:
- you are a director or shareholder of a counterparty and your details are required for know your client/anti money laundering compliance;
- you are a director, shareholder or key person at a target which Aspen is considering buying or investing in;
- you wish to visit us (and if relevant your family members or work colleagues want to accompany you on that visit to us) and you have asked us to assist with obtaining your invitation letter or visas; or
- you make any request or enquiry to us.
The relationship we have with you will dictate what, if any, personal data we collect about you and why we use it.
We will sometimes obtain personal data from other sources, such as from your employer, other third parties or publicly available online sources or official records.
Uses of your personal information
We process your personal data for many different purposes when you visit our website, purchase goods or services from us, supply goods or services to us or otherwise communicate or engage with us.
We are required by law to always have a permitted reason or justification (called a “lawful basis”) for processing your personal data. You can read more about what we process your data for, and the lawful bases on which we rely for such processing, in the table below.
For some processing activities, we consider that more than one lawful basis may be relevant depending on the circumstances. Use on the basis of “legal obligation” means to comply with a legal obligation to which we are subject. Use on the basis of our legitimate interests means where we have a fair, proportionate and overriding lawful business reason to use your details. This will primarily be where by using the information, we learn about you or develop our relationship, so we can work together more closely and better, or make sound business decisions involving or affecting you.
We may convert your personal data into statistical or aggregated form, or de-identify it, to better protect your privacy, or so that you are not identified or identifiable from it. We may use it to conduct research and analysis, including to produce statistical research and reports.
We are required by law to treat certain categories of personal data with even more care than usual. These are called sensitive or special categories of personal data and additional different lawful bases apply to them. This is rarely relevant but unusually may arise where we handle your passport and visa details and they reveal information about your race or ethnicity, or where KYC/AML checks reveal any criminal issues, or where we learn health related information about you when organising events in which you wish to participate and where we need details to ensure you can take part.
How we keep your personal data secure
We take our security obligations seriously and we take specific steps (as required by applicable data protection laws) to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.
How long we keep your personal information
We will keep your personal data during the period of your relationship with us and then, after that period ends, for as long as is necessary in connection with both our and your legal rights and obligations. This may mean that we keep some types of personal data for longer than others but we will only retain your personal data for a limited period of time. This period will depend on a number of factors, including:
- any laws or regulations that we are required to follow;
- whether we are in a legal or other type of dispute with each other or any third party;
- the type of information that we hold about you; and
- whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.
Third party websites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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. Please check these policies before you submit any personal data to these websites.