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Privacy Policy

A legal disclaimer

At Alator Capital, we take the issue of your Privacy very seriously. The following Privacy Policy details what personal data we collect as a company and how we deal with it. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

 

For the purposes of data protection legislation, the data controller is Alator Capital LTD of 16 Holland Park Mews, London W11 3SX. Our Data Protection Officer is Michael Blakeley, and he can be contacted here.

Who we are and what we do

Alator Capital Limited is a capital advisory company. We collect personal data of the following types of people to allow us to undertake our business:

 

  • You, our customer, and your employees we interact with.

  • Your personal and company data which you share with us when you register with the company as a member or for one of our events.

  • If you are a private individual or sole trader, we may have your personal data.

  • Supplier contacts to support our services.

  • Our own employees, consultants, and temporary workers.

  • Any information you provide to us to carry out our core business and ancillary activities.

Information you give to us or we collect about you

This is information about you that you give us by filling in forms/sending emails to us via our Alator Capital website (our Site). Or by providing information to us for processing (our System) or by corresponding with us by phone, e-mail, or otherwise. It includes information you provide when you register to use our site, enter our database, subscribe to our services, attend our events, complete a feedback survey, or report a problem with our site. It also includes any personal data you may provide to a third party on behalf of whom we process your data.

 

Our System relates to our AI fraud detection and automation services. These typically include information provided by our customers regarding their customers/claimants:

 

  • Name;

  • Address;

  • Company Information;

  • Due diligence information;

  • Personal data of your employees;

  • Correspondence history;

  • Supporting information for fundraising; and

  • Associated photographic information and evidence.

 

This is stored in our systems and will be used only to the extent permitted by you.

Information we collect about you when you visit our website

With regard to each of your visits to our site or system, we may collect information such as technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system, and platform.

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

 

To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products, and services that you request from us in terms of anti-fraud and protection from fraudsters and scammers. The core service we offer to our customers includes the following:

 

Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation, and consent for specific uses of data.

Our Legitimate Business Interests

Our legitimate interests in collecting and retaining your personal data are described below:

 

As an anti-fraud prevention and detection solution, our legitimate interest includes the purposes strictly necessary for the prevention of fraud. In particular, we rely on our legitimate business interest of the prevention of fraud to retain data on alleged fraudsters who arise through our database. This includes retaining such information on an ongoing basis so that we can prevent other companies from being attacked in the future.

Fulfil a legal obligation

We rely on the fulfilment of a legal obligation if we are to disclose any data relating to fraudsters or scammers as part of a criminal or civil investigation by the relevant authorities as required by the law.

Consent

We rely on your consent to retain your data and to share indicators which may have identified a potential fraudster. Using the AI technology and machine learning, our AI systems will use techniques learned from reviewing your claims. This machine learning will remain with our systems, though this will not retain any of your personal data or that of your customers.

Other Uses we will make of your data

  • Use of our website;

  • To notify you about changes to our service;

  • To ensure that content from our site is presented in the most effective manner for you and for your computer.

 

We will use this information:

 

  • To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

  • To improve our site to ensure that content is presented in the most effective manner for you and for your computer;

  • To allow you to participate in interactive features of our service, when you choose to do so;

  • As part of our efforts to keep our site safe and secure;

  • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

  • To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie notice.

Disclosure of your information inside and outside of the EEA

Information may be accessed by users of the Alator Capital Systems or shared with information who have travelled or reside outside of the EEA. As a global service, we may also transfer data outside of the EEA to service providers located in such areas. In such circumstances, we will seek to ensure that appropriate safeguards are put in place and perform the necessary due diligence.

 

Selected third parties may include:

 

  • Other users of the Alator Capital System for supporting companies, organising events, or generating fundraising;

  • Clients, business partners, suppliers, and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;

  • Subcontractors including email marketing specialists, event organisers, payment, and other financial service providers;

  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.

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There are certain third parties we work with to help us deliver the best service we can. To achieve this, we use a number of third-party tools which are carefully chosen, including:

 

  • Amazon Web Services, our hosting partner. We use Amazon, a top-tier data hosting service, to host our service and keep our data safe.

  • Xero accountancy software to manage accounts and payment systems.

  • G-suite to manage our documents and emails and to keep our data secure.

  • LinkedIn to contact other companies to develop business opportunities.

  • Slack communication system.

  • Business partners, suppliers, and sub-contractors for the provision of the Alator Capital service to you.

 

We periodically appoint digital marketing agents to conduct marketing activity on our behalf. Such activity may result in the compliant processing of personal information. Our appointed data processors include:

 

(i) Prospect Global Ltd (trading as Sopro), Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro is registered with the ICO Reg: Z123456; their Data Protection Officer can be emailed at: dpo@sopro.io.

Analytics and search engine providers that assist us in the improvement and optimisation of our site

We will disclose your personal information to third parties:

 

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

If Alator Capital or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation and other agreements, or to protect the rights, property, or safety of Alator Capital, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

The lawful basis for the third-party processing will include:

 

Their own legitimate business interests in processing your personal data, in most cases to prevent fraud;

Satisfaction of their contractual obligations to us as both a data controller and data processor;

For the purpose of a contract in place or in contemplation;

To fulfil our legal obligations.

Where we store and process your personal data

The data that we collect from you will be stored on Amazon servers within the EEA; however, it may be transferred to, and accessed in, destinations outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our anti-fraud services and the provision of support services. By submitting your personal data and that of your users, you agree to this transfer, storing, or processing. Alator Capital LTD will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

 

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology or through bank transfer. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our system, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we regularly review our use of data with the aim of removing data that we no longer have a legitimate business interest in maintaining.

At the end of our contract with you, we will delete data in line with our contractual provisions or as agreed. However, please note that any machine learning over processes and techniques will remain with us as part of our intellectual property.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes, and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

 

The GDPR provides you with the following rights:

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer of your personal information to another party in certain formats, if practicable.

  • Make a complaint to a supervisory body, which in the United Kingdom is the Information Commissioner’s Office (ICO).

Password Restrictions

At Alator Capital Limited, we require all passwords to be changed at regular intervals and to be of minimum complexity. We would ask that if you are a user of our system, you keep your password safe and report any loss or breach of your passwords to us as soon as practically possible.

Access to information

The Data Protection Act 2018 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force). A subject access request should be submitted to our Data Protection Officer. No fee will apply as laid down by the GDPR.

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Contact

If you have any questions or require further information, please do not hesitate to contact our qualified Data Protection Officer, Michael Blakeley, at mike@pangolindpc.co.uk.

Cookie Policy

A legal disclaimer

Our website uses cookies to help analyse how users interact with the site and to help us improve our service. Below, you will find detailed information about how we use cookies.

 

If you want to learn more about how we handle your personal data, please refer to our Privacy Policy.

 

We are committed to protecting your right to privacy and respecting your rights. If you believe we have fallen short of these commitments, please get in touch, and we will be happy to address your concerns.

What is a cookie?

A cookie is a text file stored on your computer or mobile device by a website’s server, if you agree. Only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It contains anonymous information, such as a unique identifier and the site name.

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Further information on cookies should be available in the help pages of your browser, and most browsers will recognise when a cookie is offered and allow users to control how and when they are accepted. However, you should be aware that if you choose to decline cookies, you may not be able to fully experience all the features of the Alator Capital website and other websites you choose to visit.

How does Alator Capital use cookies?

Alator Capital uses cookies that are strictly necessary to enable you to navigate the site or to provide certain basic features. We use cookies to enhance the functionality of the website by storing your preferences, for example. We also use cookies to help us improve the performance of our website to provide you with a better user experience.

 

The information we collect using cookies is anonymous. We will never (and will not allow any third party to) use statistical analytics tools to track or collect any personally identifiable information of visitors to our site or associate your IP address with any other data held about you. We will not associate any data gathered from this site with any personally identifiable information from any source unless you explicitly submit that information via a form on our website.

We may use the following types of cookies on our website:

  • Strictly necessary cookies. These are cookies required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart, or make use of e-billing services.

  • Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and see how visitors move around our website when using it. This helps us improve the way our website works, for example, by ensuring that users easily find what they are looking for.

  • Functionality cookies. These are used to recognise you when you return to our software products. This enables us to personalise our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

  • Targeting cookies. These cookies record a user’s visit to a website, the individual pages visited, and the links followed. If the cookie is set by a third party (for example, an advertising network) which also monitors traffic on other websites, this type of cookie may also be used to track a user’s movements across different websites and create profiles of their general online behaviour. Information collected by tracking cookies is commonly used to serve users with targeted online advertising.

What are the specific cookies that Alator Capital uses?

The website uses Google Analytics, which allows us to recognise and count the number of visitors to our site and to see how visitors move around the site when they are using it. The information generated by the cookie about your use of the website, including your IP address, is transmitted to Google. This information is then used to evaluate your use of the website and compile statistical reports on website activity for Alator Capital. Google may transfer this information to third parties where required by law or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

 

If you would like to know exactly what cookies are being used by Google Analytics and how they operate, or if you would like to find out more about the EU Cookie Law, you can do so via the links below:

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  • ICO Cookie Regulations and the EU Cookie Law

  • Cookies and Google Analytics

What if I don’t want cookies?

You can restrict or block web browser cookies that are set on your device through your browser settings. You can be notified when cookies are sent to your browser, or you can refuse cookies completely. You can also delete existing cookies. The Help function of your browser will tell you how to do this.

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You can visit www.aboutcookies.org for further information about disabling cookies.

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For more information about cookies, visit the Interactive Advertising Bureau, an industry body that develops standards and guidelines to support online business processes. It has produced a series of web pages explaining how cookies work and how they can be managed.

What if I have any questions?

Alator Capital works hard to ensure that we keep your data safe and respect your legal rights and your privacy. If you have any questions or ever feel that we fall short in our efforts, please get in touch and let us know. Alator Capital has a dedicated Data Protection Officer, Michael Blakeley, who can be contacted at mike@pangolindpc.co.uk, and he will be happy to address any questions you may have.

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