Last updated: 08/09/21
We do not market to or enter into contracts with children, nor we do knowingly collect personal data from any person under 18 years of age. Please do not access or use the Website or Services if you are under 18 years of age.
This Policy and Our Contact Details
This policy sets out what personal data we might collect, how we process and protect that data, the lawful grounds for that processing, and your related rights. Essentially ‘personal data’ is any data which can identify a person. The term ‘personal data’ means any information relating to an identified or identifiable natural person, namely one who can be identified, directly or indirectly from that information alone or in conjunction with other information.
As data protection laws and practices are constantly developing, we may need to update this policy from time to time, which we’ll do by posting a new policy on the Website that takes effect from the date stated above and, where possible, we’ll send you a copy of the new policy by email. It is however your responsibility to return to the Website from time to time and check for changes.
If you have any questions regarding this policy or our privacy practices, you can always contact us by post at the address above or by email to firstname.lastname@example.org.
What Personal Data Do We Collect and How Do We Obtain Personal Data?
We collect or are provided with personal data in the following ways:
- Initial Discussions: you may provide us with your contact details, such as your name, email address and telephone number, during discussions about investing in our fund or our fund investing in your business;
- Services: once you have decided you would like to engage our Services for you or your business, we may collect limited further personal data as part of providing the Services including contact details of other employees who work with the business and who we are required to liaise with as part of performing the Services;
- Website Usage: when you visit the Website, we may collect information about your visit such as your IP address and the pages you visited (for further information, please see the Cookies section below);
- Questions or Queries: you may provide us with your contact details, including your name, email address and the company you represent, when you ask us any questions or queries, for example about our funds or other Services, through the Website, by email or otherwise;
- Marketing: you may provide us with your name, email address and the company you represent so we can send you information about us or our Services which we believe may interest you.
When you provide us with personal data about yourself or another person, such as a colleague, you are confirming to us that the personal data you give us is accurate and up-to-date. If you are providing personal data of another person, you also authorise that you are authorised to do so.
Sensitive Personal Data
Given the nature of our business, we do not ask for 'sensitive' or 'special categories of personal data', such as information about your health, political opinions, racial origins or sexual life and we would ask you not to send any to us. If any such personal data is provided to us, we will delete it.
How Do We Use The Personal Data?
To process personal data, the law requires that we have a lawful basis to do so. In most cases, the lawful ground will be that the processing: (i) is necessary for our legitimate interests in carrying out our business, including to raise and invest the funds / maintain, improve and market our products and services, to keep our Website and other properties secure, provided those interests are not outweighed by your rights and freedoms ('Legitimate Interests'), (ii) is necessary to perform a contract with you or to enter into a contract with you ('Contract'), or (iii) is necessary to comply with our legal obligations ('Legal Obligation'). Where processing is based on your consent ('Consent'), we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent. We have listed below the purposes for which we use your personal data and which ground(s) we rely on when doing so.
We may use your personal data for the following purposes:
- to respond to enquiries, including about the funds and other Services. Lawful basis: Legitimate Interests or Contract;
- to provide and operate the Website and Services. Lawful basis: Legitimate Interests or Contract;
- to provide advice and support regarding the Website and Services. Lawful basis: Legitimate Interests or Contract.
- to analyse and improve the Website, the funds and other Services, for example for technical or security purposes and to improve the customer experience. Lawful basis: Legitimate Interests, however where for example applicable law requires your consent to use certain cookies, we will ask for your Consent having provided you with relevant information.
- to market our fund(s) and/or other Services – if we do so, we will provide you with an easy and free way to opt-out of receiving such communications in the future. Lawful basis: Legitimate Interests or, where required by law, Consent.
- to investigate investment opportunities. Lawful basis: Legitimate Interests or Contract.
- in certain circumstances, to share it with a limited number of third parties as described in this policy, for example for operational requirements and business continuity purposes. Lawful basis: most processing will be based on Legitimate Interests, some processing is based on Contract and, where necessary (as above) some processing may be based on your prior Consent.
Sharing Data & International Transfers
Where permitted by law, we may share personal data in the following limited circumstances.
- For provision of the Services and for disaster recovery and business continuity purposes, we may store or transmit personal data to or through third party providers, such as with our contractors and advisors to help us operate, secure and analyse our business. Such third parties may include, for example, a cloud storage provider. Lawful basis: Legitimate Interests or Contract.
- We may be obliged to disclose your personal data to comply with a law, order or request of a court, government authority, other competent legal or regulatory authority or any applicable code of practice or guideline. Lawful basis: Legal Obligation.
In each case, we share the minimum personal data necessary and we have written contracts in place incorporating relevant wording to safeguard that personal data and comply with applicable laws, and we will only share such data as is necessary for the purpose in question. Where possible, we keep personal data within the United Kingdom and/or the European Economic Area ('EEA'). However, in order to carry out the above purposes, we may use third parties and their facilities outside the United Kingdom and/or the EEA. In all such cases we will ensure that appropriate security measures are in place to protect your personal data and a valid legal basis for the transfer applies.
We will only retain your personal data for as long as is necessary for the purpose(s) for which it was collected. In doing so, as a default position, we will only retain personal data for any applicable statutory retention period, then a reasonable period (if any) necessary for the above purposes. This is subject, for example, to any valid opt-out or withdrawal of consent where processing is based on Consent, or other valid exercise of your data subject rights which is affected.
The security of personal data is very important to our business. In accordance with our legal obligations, we have implemented appropriate and robust technical and organisational measures to protect your personal data and we keep those measures under constant review. For example, we use encryption tools where appropriate, ensure confidential information is only accessible by those who need to access it, password protect certain documents, and continually train new and existing personnel on the security of personal data and other confidential information.
However, we can only be responsible for systems that we control and we would note that the internet itself is not inherently a secure environment.
Third Party Services
In certain circumstances, you may be able to exercise the following rights:
- the right to know if we process any personal data about you and, if we are, with certain limitations, to a copy of that personal data;
- the right to ask us to delete your personal data;
- the right to correct any of your personal data that is inaccurate;
- the right to object to or restrict certain processing, including to object to direct marketing;
- the right to withdraw any consent you may have given us for any processing of your personal data;
- the right to 'port' certain of your personal data to you or another provider.
You also have the right, at all times, to submit a complaint to any regulator such as the Information Commissioner’s Office in the UK, although we would welcome the opportunity to discuss and resolve any complaint with you first.