Effective Date: October 3, 2024
Western Gate (“we,” “us,” “our”) is committed to protecting and respecting your privacy in compliance with Regulation (EU) 2016/679, the EU General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 when processing personal data.
This Privacy Policy explains how we collect, use, share, and protect your personal data when you visit and interact with our website (the “Website”) or submit inquiries through the Website’s inquiry form.
Please read this policy carefully to understand our views and practices regarding your personal data and how we handle it.
- Data Controller
The data controller responsible for the processing of your personal data is:
Western Gate
1 Bartholomew Lane
London, England
EC2N 2AX
Press Contact
westerngate@apcoworldwide.com
- What Data We Collect
Personal data is ‘any information relating to an identified or identifiable natural person’ (the data subject). It does not include data where the identity of the natural person has been removed in such a manner that the data subject is not or no longer identifiable (anonymous data).
We collect the following personal data when you submit an inquiry through the form on our Website:
- First Name and Last Name
- Email Address
- Phone Number (optional)
- Message/Inquiry Details
This data is voluntarily provided by you when you submit a request or question via the inquiry form. We encourage you not to submit any special categories or sensitive data, such as health data, when contacting us.
We may also collect personal data regarding your use of our Website.
- How We Collect Your Data
We collect your personal data when you submit a request using our “Get InTouch” inquiry form on our Website.
We also obtain personal data when you navigate our Website via cookies, pixel tags, or similar technologies (collectively referred to as “cookies”). Cookies are small pieces of data that may be stored in and retrieved from your web browser while you browse a website.
Through the use of cookies, we may collect your device IP address, unique device ID, hardware and software type, Internet service provider, serving domain, geographical area, location data, browser type and settings data (such as screen resolution, color depth, time zone settings, browser extension and plugins) operating system, referring URLs, search history, information on actions taken or interaction with our digital assets (e.g., page views) and dates and times of actions.
Where required, we obtain your consent to use cookies. You may obtain more information of our use of Cookies by reading our Cookies Policy.
- Purposes of Processing Your Data
We process your personal to (i) follow up on your request or to provide information about our investments, or (ii) to meet legal obligations or respond to lawful requests from authorities.
We may analyse how users interact with the Website to improve its functionality.
- Lawful Bases for Processing
We only process your personal data when we can rely on a valid legal ground, namely:
Performance of a contract or pre-contractual procedures: in order to proceed with a potential business venture or respond to your enquiries regarding our activities.
Legitimate interests: We have a legitimate interest in processing your personal data to conduct business analytics or to improve the safety, security and performance of the website.
Legal obligations: In certain cases, we may need to process your data to comply with legal obligations.
- How We Share Your Data
We do not sell, rent, or otherwise disclose your personal data to third parties, except in the following circumstances:
- Service Providers: We may share your data with trusted service providers who assist us in managing and operating the Website or responding to inquiries. These providers will only process your data under our instruction and in compliance with applicable laws.
- Legal Compliance: We may disclose your data to comply with legal obligations, including to respond to requests from public authorities.
- International Transfers
We do not routinely transfer your personal data outside the European Economic Area (EEA) and our servers are located in Portugal. However, if such a transfer becomes necessary, we will ensure that appropriate safeguards are in place, in line with the GDPR and UK data protection laws, such as standard contractual clauses or an adequacy decision.
- Data Retention
We will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including responding to your inquiries or complying with legal obligations. When the data is no longer needed, we will securely delete or anonymize it.
- Your Data Protection Rights
Under the GDPR and UK Data Protection Act, you have the following rights regarding your personal data:
Right to Access: You can request access to the personal data we hold about you.
Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data.
Right to Erasure (“Right to be Forgotten”): You can request the deletion of your personal data, subject to certain conditions.
Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.
Right to Data Portability: If some requirements are met, you can request that we transfer your personal data to another organization or directly to you, where technically feasible.
Right to Object: You have the right to object to the processing of your personal data under certain circumstances, including processing based on legitimate interests.
Right to Withdraw Consent: If we rely on your consent to process your personal data, you may withdraw your consent at any time.
To exercise any of these rights, please contact us at info@westerngate.eu. We will respond to your request within one month (and after this, under certain conditions), as required under GDPR and UK data protection laws.
- Security of Your Data
We maintain administrative, technical and physical safeguards that are intended to appropriately protect personal data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the personal data in our possession.
For instance, we securely store your data by various methods and redundancies. We will not save your personal data for a longer period than is necessary to fulfil the purpose for which your data was collected and fulfil our legal requirements.
We limit access to your personal and account information to those employees who need to process such information for us to provide you with a response to your enquiries.
However, because no information system can be 100% secure, we cannot guarantee the absolute security of your information.
- Data Retention
We take measures to delete your personal data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period.
At the expiration of the data retention period the data is erased by irreversible destruction and/or is anonymised.
- Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or technical developments. When we make changes, we will update the “Effective Date” at the top of this policy. Please review this policy periodically to stay informed about how we protect your data.
- Contact Information
If you have any questions or concerns about this Privacy Policy or the way we process your personal data, please contact us at:
Western Gate
1 Bartholomew Lane London, England EC2N 2AX
If you are not satisfied with our response to a complaint, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
If you are resident in the EU, you may also lodge a complaint with an EU Supervisory Authority, in particular in the Member State of your habitual residence, place of work or place of alleged infringement if you consider that the processing of personal data in question infringes the GDPR.
For a list of EU Supervisory Authorities, please consult the EDPB’s list at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
By submitting your personal data through our Website, you acknowledge that you have read and understood this Privacy Policy.
