Thank you for using Gore Street Capital’s Website at https://gorestreetcap.com/. Gore Street Capital Limited is an entity authorised and regulated by the Financial Conduct Authority, to act as the Alternative Investment Fund Manager (“AIFM”) to the Gore Street Energy Storage Fund PLC.

We are committed to handling your personal data carefully and in accordance with applicable privacy laws. We have prepared this notice to explain how we collect, use, and share information you provide to us when you use the Website. This Privacy Policy does not apply to websites, applications, or services that do not display or link to this notice or that display or link to different privacy statements.

By using the Website you consent to this Privacy Policy. If you object to the collection, use, and sharing practices described in this Privacy Policy, you should not use the Website.

Definitions

“We”, “us”, “our”, “company” and “Gore Street Capital”, means Gore Street Capital Limited. “Website” means our main domain which is https://gorestreetcap.com/

“Affiliates”, “third parties”, “partners” means other companies that are not part of nor owned by or controlled by Gore Street Capital Limited.

“Personal data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, including by reference to an identifier such as a name, email address, phone number, an identification number, location data, an online identifier or to one or more factors relating that person.

Scope

This Privacy Policy sets out how Gore Street Capital Limited uses and protects any information that you give to us when you use this Website or engage in any of our services. Our use of your personal data will be in accordance with this Privacy Policy and in line with data protection laws and policies.

Lawful Bases for Processing

In order to collect and use your personal data, we required to rely on one or more of the lawful bases for processing laid out under Article 6(1) of the UK GDPR. Namely, we are relying on:

  • Consent, under Article 6(1)(a) UK GDPR
    • Consent is granted by the data subjects through their use of this Website.
  • Legitimate interests, under Article 6(1)(f)
    • These include compliance with our legal obligations and with our regulatory requirements, as well as where processing may be required in the substantial public interest.

Information We Collect

(a) Information you voluntarily provide to us:

When you sign up for and use our services, send us an email, or communicate with us in any way, you are voluntarily giving us information that we collect. That information may include any of the personal data described above. By giving us your personal data, you consent to this information being collected, used, disclosed, and stored by us, as described in this Privacy Policy.

(b) Information we collect automatically:

When you use our services or visit the Website, we may collect information about your visit to, your use of the services, and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with the Website. We may collect this information as part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is described below.

(c) Information from your use of our services:

We may receive information about how and when you use our services, store it in log files or other types of files associated with your use. This information may include personal data depending on what you disclose and other information such as your IP address, time, date, browser used, and actions you have taken on the Website. This information helps us to improve our services for our users.

(d) Cookies and tracking:

We may use various technologies to collect and store information when you use our services, including third party services such as Google Analytics, or other Google products in addition to using cookies and similar tracking technologies on the Website, such as pixels and web beacons, to analyze trends, administer the Website and track users’ movements around the Website,

YCookies are text files containing a unique ID that are transferred to the user’s computer’s hard drive through their web browser. They are saved to the user’s computer, and they store information about the user’s interaction with the website, enabling the website to personalise user experience. You can control the use of cookies at the individual browser level. We partner with third parties to display advertising on our website or to manage and serve our advertising on other sites. Our third party partners may use cookies or similar tracking technologies in order to provide you advertising or other content based upon your browsing activities and interests. If you wish to opt out of interest-based advertising, click www.youronlinechoices.eu.

(e) Information from other sources:

From time to time we may obtain information about you from third party sources, such as public databases, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including sometimes personal data where relevant) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.

Our Use of Your Personal Data

We may use and share your personal data for the following purposes:

  • Where we need information to perform the contract we have entered into with you or where we are using the information in advance of performing a contract with you (for example to provide you with our services, or if you enquire about or apply for employment with us)
  • Where we need to comply with a legal obligation
    • Where the processing is necessary for us to carry out activities for which it is in our legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:Processing that is necessary for us to promote our business and brand and services and measure the reach and effectiveness of our services – this may include sending you marketing information from time to time after you have engaged with us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time
    • Processing that is necessary to improve our knowledge of the sector we operate in – this will include undertaking market analysis and research so that we better understand trends in the sector and provide better knowledge along with more tailored and relevant services for our customers in the future.
  • In the case of a sale, merger, consolidation, liquidation, reorganisation, or acquisition we may share your personal data with any potential acquirer, which will be subject to our obligations under this Privacy Policy.

Legal Obligations

Your personal data are collected and used in accordance with the General Data Protection Regulation (GDPR), which has been retained in domestic law after Brexit as the UK GDPR (sitting alongside Data Protection Act (DPA) 2018). The UK GDPR sets out data protection principles, which require personal information to be:

  • Used lawfully, fairly and in a transparent manner
  • Collected only for specified, explicit and legitimate purposes
  • Adequate, relevant and limited to what is necessary
  • Accurate and up to date
  • Stored only for as long as necessary
  • Processed in a manner that ensures security and confidentiality

The Website may have links to other websites. If you submit personal data to any of those sites, your information is governed by their privacy policies. Therefore, we cannot be responsible for the protection of information provided when interacting with these sites, which are not governed by this privacy policy. We encourage you to carefully read the privacy policy of any website you visit.

How We Share Your Personal Data

We may share your personal data for the purposes described throughout this Privacy Policy:

  • With Gore Street Energy Storage Fund, on behalf of which we manage investments.
  • With our third party service providers and affiliates, who help us provide and support our services. For example, if it is necessary to provide you something you have requested we may share your and your personal data with such third parties and affiliates for that purpose. Examples of third parties, service providers and affiliates include but are not limited to hosting services and content delivery services.
  • With our regulators, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations.
  • With third party lenders as necessary to allow us to fulfil our obligations to you, to raise finance for you and to properly manage and advise you on your investments.
  • To maintain a register of investment holdings in order to comply with our legal and regulatory requirements.

Security

We take reasonable and appropriate measures to protect personal data from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the risks involved in the processing and nature of the personal data.

Location of Servers

Our website servers are located in the United Kingdom. When you use the Website, your personal data is stored and processed in the United Kingdom.

Accuracy and Retention of Personal Data

We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address) you are responsible for notifying us of those changes.

We will retain your information for as long as needed to provide you with our services.

In order to determine for how long to retain your data, the amount, nature and sensitivity of the data will be considered, as well as compliance with our legal obligations, resolution of any disputes and enforcement of our agreements.

Your Rights In Relation To Your Personal Data

You have a number of rights in relation to your personal data, including the right to:

  • To be informed about how we use your personal data
  • To obtain access to your personal data that we hold
  • To request that your personal data is corrected if you believe it is incorrect, incomplete or inaccurate
  • To request that we erase your personal data where:
    • We process your personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected
    • If we rely on consent as the legal basis for processing and you withdraw consent
    • If we rely on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing
    • If the personal data has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
    • If it is necessary to delete the personal data to comply with a legal obligation
  • To ask us to restrict our data processing activities where you consider that:
    • Your personal data is inaccurate
    • Our processing of your personal data is unlawful
    • Where we no longer need the personal data but you require us to keep it to enable you to establish, exercise or defend a legal claim
    • Where you have raised an objection to our use of your personal data.
  • To request a copy of certain personal data that you have provided to us in a commonly used electronic format.
    • This right relates to personal data that you have provided to us that we need in order to perform our agreement with you and personal data where we are relying on consent to process your personal data
  • To object to our processing of your personal data where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful.
    • If you raise an objection, we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal data; and
  • Not to be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.
If you would like to exercise any of these rights, please contact us using the details below.

 

Complaints

If we cannot resolve any concerns you have about the way in which we use your personal data, you have the right to complain to the data protection regulator (the Information Commissioner in the UK).

Changes To This Privacy Policy

We may change this Privacy Policy from time to time by updating this page. These changes will supersede any previous policies or agreements and the latest version published here will apply. You should check this page from time to time to ensure that you are happy with any changes. All updates and amendments are effective immediately upon posting a revised version of this Privacy Policy on the Website.

Contact Us

If you have any questions, comments or concerns, or exercise any of your rights in relation to your personal data or you have a concern about the way in which we have handled any privacy issue, please contact us via [email protected].  You can also directly contact our Compliance/Data Protection Officer via [email protected]