This Privacy Notice explains what personal data (information) we hold about U.K. and EU contacts who are not clients, including where individuals register to receive Bramshill Investments Marketing Updates or request to be contacted via our website, how we collect it, and how we use and may share information about you.

We are required to notify you of this information under the EU General Data Protection Regulation (GDPR). Please ensure that you read this notice and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

Who Collects the Information

Bramshill Investments, LLC is the operator of the website and is a ‘data controller’ that gathers and uses information about individuals in certain circumstances.

Bramshill Investments, LLC is a Delaware incorporated limited liability company based at 411 Hackensack Ave 9th Floor, Hackensack NJ 07601, United States.

Bramshill Investments LLC has appointed its affiliate to as its EU Representative with Greyline Solutions Ltd respect to fulfilling its obligations under the EU General Data Protection Regulation and acting as a point of contact. Greyline Solutions Ltd, a private limited company incorporated in England and Wales with its registered address at Tower 42, 25 Old Broad Street, London, United Kingdom, EC2N 1HQ. Greyline Solutions Ltd acting in its capacity as the EU Representative of Bramshill Investments, LLC can be contacted at EUrep@greyline.co.

How We Collect Information About You

We collect this information from you directly when you sign up to receive Bramshill Investments Marketing Updates or request to be contacted via our website. Information may also be obtained during direct contact with Bramshill Investments staff, including via email and through the exchanging of business cards at events, and we may also collect and cross-reference against open source and non-confidential information from the internet.

What Information We Collect About You

We collect your name, contact details and information about your preferences on how and when to be contacted and for what purposes. We may also seek to understand and record other details, such as the name and type of company being represented, where applicable.

How We Will Use Information About You

We collect and use this information to send you only the Bramshill Investments Marketing Updates that you have expressed an interest in, and where appropriate to facilitate direct outreach by an appropriate member of Bramshill Investments staff. Where individuals have signed up via our website, we will obtain and rely upon their explicit consent to allow us to use this data. Where data has been obtained from other sources, we will rely on legitimate business interests to permit the processing of this information and provide a copy of this privacy policy to the individual at the earliest opportunity.

Where appropriate, we may send you information about our products and services that are likely to be of interest to you. If you have consented to receive marketing updates from us, you may opt out later. You have the right to stop us from contacting you for marketing purposes at any time. If you no longer wish to be contacted for marketing purposes, please contact info@bramshillinvestments.com.

We will not share your information for marketing purposes with other organizations outside of Bramshill Investments.

How We May Share the Information

Our outsourced IT service providers may have access to your information by virtue of our data being hosted on their servers. Any such, third parties will be bound by confidentiality obligations by way of contract. We may also be required to share some personal information if required to do so to comply with applicable law.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

Where Information May Be Held

Information may be held at our offices and those of our group companies, along with on their email and IT servers, some of which are hosted by third-party service providers.

This may involve transferring information internationally to other countries around the world, with Bramshill Investments offices currently being located in the United States and the United Kingdom. In all cases, we have security measures in place to seek to ensure that there is appropriate security for information we hold.

How Long We Keep Your Information

We will continue to process your information until you request to unsubscribe from receiving the Bramshill Investments Marketing Updates, you request not to be contacted for marketing purposes, or until we have dealt with your request to be contacted. Residual information may be retained after this time as part of our normal business records, but no further processing will take place.

Your Rights as a U.K. or EU Data Subject

You have the following rights in relation to your personal information:

• The right to access your personal information;
• The right to rectify your personal information;
• The right to request the restriction of the use of your personal information;
• The right to request that your personal information is erased;
• The right to object to the processing of your personal information; and
• The right to request the transfer of your personal data (“data portability”).

Please contact us at info@bramshillinvestments.com if you would like to correct or request access to information that we hold relating to you, or if you have any questions about this notice. We may charge a fee for responding to such a request, but only a reasonable fee for responding to access requests in cases where the request is manifestly unfounded or excessive, especially if it is repetitive, or the request is for further copies of the same information.

You also have the right to request the information we hold to be erased (the ‘right to be forgotten’) in certain circumstances. Note that erasure may not be immediate and may not be possible in some situations where continuing legal obligations apply.

How We Keep Your Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. This also extends to any subcontractors or IT service providers.

We also have procedures in place to deal with any suspected data security breach. We will notify you and the appropriate regulator of any suspected data security breach where this is required in light of the likelihood and severity of the risk posed to your rights and freedoms.

Other Websites

Our website may contain links to other websites which are outside our control and are not covered by this Privacy Notice. If you access other websites using the links provided, you should read the privacy notices on those websites.

Changes to our Privacy Notice

We will keep this Privacy Notice under regular review. Any changes we make to our GDPR Privacy Notice will be posted on our website at https://www.bramshillinvestments.com/GDPR/ or can be requested by email at info@bramshillinvestments.com.

How to Contact Us

If you have any questions about our use of your personal information or this Privacy Notice, please contact us at info@bramshillinvestments.com.

How to Complain

Please contact us at info@bramshillinvestments.com if you have any query or concern regarding how we collect or process personal data, or would like to make a formal complaint.

If we are unable to resolve any complaint to your satisfaction, you should contact the Information Commissioner online at www.ico.org.uk/concerns or by telephone at 0303 123 1113 for further information about your rights and how to make a formal complaint.