Effective date: May 23, 2018
This Policy sets out the following:
1. About us
2. What information we collect
4. Business contacts, professional advisers and intermediaries
5. Directors and shareholders of investees
6. Our website and cookies
8. Storing your information
9. International transfers
10. Keeping your information safe
11. Your rights
12. Updates to this Policy
1. About us (and how to contact us)
For the purposes of data protection law we will be a controller of your personal information (this means we make decisions about how and why your information is used, and have a duty to ensure your rights are protected).
2. Information we collect
In order to operate our business and provide our services, we may use personal information about business contacts and details of individual professional advisers and intermediaries.
We do not actively collect information from individuals, however when you, as an employee of one of our customers communicates with us on the customer’s behalf, we may need to store your information in order to respond to you, or to maintain the business relationship. This may include personal information, such as your name and contact details provided when communicating with us.
How we use your information
We will only use your information with your consent, or because we need to in order to:
· perform a contract with you or your employer
· comply with a legal duty
· for our own (or a third party’s) lawful interests, provided your rights don’t override these
In any event, your information will only be used for the purpose(s) we collected it for (or else for a closely related purpose, such as record keeping).
If we need to use personal data in order to enter into or perform a contract with you then, if you don’t provide that data, we may not be able to contract with you or provide the services.
We will never sell or trade your personal information. We do share information with our suppliers, and this may include personal information in some cases, but they will only be allowed to use the information for a specific purpose and there will be a written agreement which makes sure your information is protected.
We don’t normally collect or process sensitive personal information about our customers or visitors (such as information about someone’s health or beliefs). In the unlikely event that we do (for example, details if an accident occurs on our premises), we’ll ensure that this information is kept private and secure.
3. Business contacts, professional advisers and intermediaries
We often work with other businesses. These might be intermediaries, professional advisers or other businesses we choose to partner with in relation to events or initiatives. We collect information about individuals working with or for these businesses, including names and contact details, information about someone’s role in a business (such as their job title).
4. Our website and cookies
We don’t collect or process personal information about visitors to our website unless they choose to provide information (such as when signing up to a mailing list).
We may collect non-personal information about visitors, as this helps us optimise and improve the website. This information might include your internet protocol address, the browser being used to connect to our website, the device (e.g. its operating system) and the connection type (e.g. the Internet service provider used). However, none of this information will directly identify you.
Hyperlinks to other sites
We sometimes send emails to business customers, contacts, intermediaries and professional advisers without their prior consent, which we do in order to promote our services and build relationships. If we have contacted you it will be because we think these communications may be of interest or relevance to you on the basis of our previous dealings with you or a recommendation from a third party.
Our marketing emails will always tell recipients why they are receiving that email and give them the option to unsubscribe.
Our marketing communications are sent directly by us.
6. Keeping your information safe
We employ a variety of physical and technical measures to keep your personal data safe and to prevent unauthorised access to, or use or disclosure of it. Electronic data and databases are stored on secure computer systems and we control who has access to them (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.
We cannot absolutely guarantee the security of the internet or external networks or your own device, accordingly any online communications (e.g. information provided by email or through our website) are at your own risk.
We only store personal information so long as it is required for the purpose(s) we collected it for (or for a related compatible purpose, such as keeping a record of a transaction). We regularly review what data we have and delete that which is no longer necessary. In certain situations you have the right to request that your data be deleted (the right to be forgotten), please see clause 8 for further details.
If you believe that any information we are holding on you is incorrect or incomplete, please contact us using the details set out in clause 1.
We only store personal information within the European Economic Area (EEA). If one of our subcontractors (such as a payment processor) needs to transfer it outside of the EEA then we will take steps to make sure adequate levels of privacy protection, in line with UK data protection law, are in place. These safeguards will usually be contractual and/or the result of a European Union decision which allows the transfer (for example, a US organisation which is certified under the EU-US Privacy Shield framework).
8. Your rights
We want you to remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:
(a) where data is processed on the basis of consent, the right to withdraw that consent;
(b) the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of that personal data;
(c) the right to have inaccurate data rectified;
(d) the right to object to your data being used for marketing or profiling, or on the basis of our or a third party’s legitimate interests;
(e) the right to restrict how your personal information is used; and
(f) the right to be forgotten, which allows you to have your data erased in certain circumstances (though this is not an absolute right and may not apply if we need to continue using the information for a lawful reason).
If you would like further information on your rights or wish to exercise them, please write to us using the details given in clause 1, with details of your request.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).
If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner's Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.
9. Updates to this Policy
We may update this Policy at any time. When we do, we will post a notification on the main page of our website and revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect.
This policy was last updated on 23rd of May 2018.