Internal Capital Adequacy Assessment Process -
These Terms govern the manner in which Compound Growth Ltd collects, uses, maintains and discloses information collected from users (each, a "User") of the www.icaap.support website ("Site"). These Terms apply to this Site and all services offered upon it by Compound Growth Ltd.
Personal identification information
Compound Growth Ltd respects your privacy and is committed to protecting your personal data.
This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
We may collect personal identification information from Users when they use our Site and when submitting an enquiry via the contact form or contact links on Site. We will collect personal identification information from Users only if they voluntarily submit such information to us.
We act primarily as a data processor for our clients. This means that we do not control the collection, use and storage of personal data provided to us by our clients, other than to carry out our obligations under our contracts with them, in accordance with the terms of those contracts. Consequently if we are processing personal data supplied to us by a client and a data subject raises a query with us, we will refer that query to our client rather than deal with it ourselves.
Should there be circumstances where we are not acting as a data processor for our clients, Compound Growth Ltd would be the controller and responsible for any personal data.
We may collect non-
Personal data, or personal information, means any information about an individual from which that person can be identified. This identification can be either direct or indirect. However, it will be made possible because of information which provides a reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity a natural person. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature via Google Analytics. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data or Sensitive Personal Data about you.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
o apply or enquire about our services;
o during the course of utilising our services; or
o provide us with feedback or make comments on the content of our site.
o analytics providers such as Google based outside the EU;
o advertising networks such as Google, Facebook, Twitter and LinkedIn based outside the EU and
o search information providers such as Google based outside the EU.
Web browser cookies
Our Site may use "cookies" to help us enhance User experience, such as Google Analytics. A User's web browser places cookies on their hard drive for record-
How we use collected information
We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:
a) if you have consented to us doing so;
b) if we need it to perform the contract we have entered into with you;
c) if we need it to comply with a legal obligation; or
d) if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms.
We will use your Personal Data to deliver compliance consultancy and training services to the institution you work or act for. We may also use your Personal Data to inform you about our services and new regulatory developments.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following purposes:
Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of any personal information that may have been obtained via our Site.
Sharing your personal information
We do not sell or trade our Users personal information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners and trusted affiliates for the purposes outlined above.
Third party websites
Users may access content on our Site that links to the sites and services of our business partners and other third parties. We do not control the content or links that appear on third party sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.
When you leave our website, we encourage you to read the privacy notice of every website that you visit.
Your legal rights
Under certain circumstances, you have rights under GDPR data protection laws in relation to your personal data as follows:
If you wish to exercise any of the rights set out above, please contact us.
In accordance with data protection regulations, we may ask for proof of your identity before disclosing certain information to you
Company: Compound Growth Ltd
Contact Name: David Dudeney
Address: 120 Pall Mall, London, SW1Y 5AE
Telephone: 020 3813 2890
The information upon this site is provided in good faith at the time of writing for general information purposes only and does not constitute legal or professional advice. It should not be relied on or treated as a substitute for specific advice relevant to your particular circumstances. We do not make any warranties about the completeness, reliability and accuracy of this information and errors and/or omissions may exist due to changes over time. Any action you take upon the information on this site is strictly at your own risk and we will not be liable for any losses and/or damages in connection with the use of our site.
Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
This document was last updated on 29th July 2019.