Briarwood Partners Limited – Privacy Notice
This notice describes how Briarwood Partners Limited (“Briarwood”) uses personal data.
It outlines Briarwood’s data protection obligations and your data protection rights under
the regime introduced by the EU General Data Protection (Regulation 2016/679, the
"General Data Protection Regulation").
The GDPR applies to “personal data” meaning any information relating to an identifiable
person who can be directly or indirectly identified in particular by reference to an
Briarwood needs to use your personal data to provide its services to you. This notice
outlines the following points about the processing of your personal data:
which data items are used, how they are used and who they are shared with;
why this is done and the lawful basis; and
your rights and Briarwood’s obligations..
Why Briarwood Needs To Process Persona l Data
Your Data are collected to effectively and properly manage your relationship with us. Data
is stored for specific purposes and only data that is relevant to that purpose will be stored.
We will use the Data for several different purposes, including:
1. to carry out obligations (such as but not limited to placement agent services – for
example making qualified introductions) arising from any agreements entered into
between you and Briarwood;
2. to provide you with information, products or services that you request from us
(including through our website) or which we feel may interest you; and
3. to competent authorities (including tax authorities), courts and bodies as required
by law or requested or to affiliates for internal investigations and reporting.
Briarwood may collect data:
1. when you or an agent of yours contacts Briarwood in relation to business and
2. when you complete documents or forms during the course of business with
3. from Service Providers and other third parties that assist us in conducting
4. when you telephone Briarwood; and
5. when you use the Briarwood website.
Types Of Data That Might Be Collected
During Briarwood’s relationship with you Briarwood will collect and process Data about
1. information which individuals and entities provide when contacting us (including
through using this website) such as their names, postal addresses, telephone
numbers, identification documents and email addresses;
2. corporate information;
3. details of services provided to you; and
4. where permitted or required by regulators or the law, special categories of
personal information such as information relating to criminal convictions or
Briarwood uses Service Providers to conduct aspects of its business, so information may
be disclosed to them and their affiliates Data that you have provided in order to fulfil the
purposes for which the Data is held. These Service Providers may disclose such Data to
each other and to each other’s affiliates in order to achieve the same purposes.
Briarwood and its Service Providers may also be required to disclose your Data to
governmental agencies, self-regulatory organisations, industry associations and similar
bodies in order to fulfil legal and regulatory requirements. In addition, the laws of certain
countries and states give people involved in lawsuits and other legal proceedings the right
under certain circumstances to obtain information from Briarwood and its Service
Providers, including your Data. Briarwood and its Service Providers will comply with
these laws to the extent required.
Briarwood will not sell your Data to any third party. Wherever possible, Service Providers
are required to enter into confidentiality agreements that prohibit them from selling or
improperly using your Data.
Briarwood will retain your personal information for a period of up to seven years
following the point where the business relationship has ceased.
It may be necessary to retain your personal information beyond this period depending on
additional legal/regulatory obligations. Thereafter, Briarwood will refrain from collecting
any further personal information on you and shall take appropriate steps to dispose of
any records containing your personal information to the extent this is operationally
feasible and proportionate.
We do not collect data about our users other than if you contact Briarwood using the
'Contact Us' form. This website does not place cookies on your computer and does not use
any other means of data collection. From emails we may collect your name, your email
address and any other information which you decide to supply.
Lawful Basis For Processing
Briarwood assesses all personal data that is collected or stored to ensure that there is a
legal basis for each type of data under GDPR. The majority of lawful basis for Briarwood’s
processing is to meet its obligations to the FCA (legal obligation basis) or to fulfil its
obligations to clients under contract (contract basis).
Other lawful basis may be used where Briarwood assesses this is necessary and
Data Subject Rights
You have the following rights, in certain circumstances, in relation to your personal
Right to access your personal information (in an easily readable form);
Right to rectify your personal information;
Right to restrict the use of your personal information (in certain specific
Right to request that your personal information is erased (in certain specific
circumstances). Please note that the right for your data to be erased (the "right to
be forgotten") that applies in some contexts under the General Data Protection
Regulation is not likely to be applicable to most, if not all, of the personal
information you provide to Briarwood, given the specific nature of the purposes
for which Briarwood uses the data, as described above;
Right to object to processing of your personal information (in certain specific
Right to data portability (in certain specific circumstances);
Right to withdraw consent (in certain specific circumstances); and
Right to receive information regarding any entities we disclose your data to.
Where Briarwood or its Service Provider(s) requires your personal information to comply
with AML or other legal requirements, failure to provide this information means
Briarwood will not be able to accept you as a client or investor.
Briarwood shall notify you of any personal information breach affecting you that is likely
to result in a high risk to your rights and freedoms.
Changes To This Notice
Briarwood will need to update its privacy notice in response to regulatory requirements
or changes to its business. The latest notice will always be available on the Briarwood
How To Contact Briarwood
Under the GDPR, data subjects can make a complaint to the supervisory authority
including the Member State in which they reside or work or the place of the alleged
wish to make a complaint about how Briarwood has processed your personal data, please
contact Briarwood by writing to email@example.com or firstname.lastname@example.org .