For the purpose of data protection legislation in force from time to time the data controller is VenCap International plc of Seacourt Tower, West Way, Oxford OX2 0JJ, United Kingdom, whose data protection registration number is Z7027930.
Who we are and what we do
We are an independent investment advisory firm. We collect the personal data of the following types of people to allow us to undertake our business:
- prospective and current clients;
- prospective and current investors;
- prospective and current suppliers;
- professional advisers and consultants;
- enquirers; and
How we may hold your information
We may collect and process the following information about you:
Information you give us
You may give us information about you:
- to enable you to have access to the investor area of our website. For example, if you sign up as an investor with us, you will create a username and password and you will share your personal information with us, including your name, e-mail address and any other details you may provide within the investor area of our website;
- by filling in forms on our website. For example, if you complete a registration form for an event, you will share your personal information with us, including your name, email address, address, telephone number and any other relevant personal information such as spouses’/partners’ details and dietary requirements. Please note: such information as spouses’/partners’ details and dietary requirements are “special categories of personal data” (sensitive personal data) under the General data Protection Regulation (GDPR): please refer to the section below on sensitive personal data for information on how we treat this data;
- if you contact or correspond with us (for example, by email, telephone or otherwise) and we may keep a record of that correspondence (either directly or through our service providers).
Information we collect about you
Each time you use our services or the website we may automatically collect the following information:
- technical information about your computer or mobile device for system administration and analysis, including your IP address, unique device identifiers, operating system, wireless network interface, device telephone number and network and browser type; and
- information about your visit to our website and browsing activity, including the full URL information, pages you viewed and length of visits to certain pages, and files you have downloaded. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
How We May Use Your Information
We use information held about you in the following ways:
Information you give to us
We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to enable your access to the investor area of our website;
- to provide you with information about your portfolio;
- to enable you to attend events hosted by us or by third parties on our behalf;
- to notify you about changes to our service;
- to deal with any enquiries, correspondence, concerns or complaints you have raised; or
- to ensure that content from our website is presented in the most effective manner for you and for your computer.
Information we collect about you
We will use this information:
- to administer our website and for internal operations;
- to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so; and
- as part of our efforts to keep our website safe and secure.
We will not use this information to contact you for promotional or marketing purposes.
Purposes of the processing and the legal basis for the processing
We use information held about you for the following purposes:
- to carry out our obligations under any contracts we intend to enter into or have entered into with you, and to provide you with the information and services that you request from us; and
- to provide you with information about other services which we may offer from time to time and which are similar to those that you have already received from us or enquired about.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent (where that consent is specific, written in clear and plain language and separate from other written matters) for specific uses of data.
We will rely on contract if we are negotiating or have entered into an agreement with you or your organisation or any other contract to provide services to, or receive services from, you or your organisation.
We will rely on legal obligation if we are required to hold information on you to fulfil our legal obligations.
Our legitimate business interests
Our legitimate business interests in collecting and retaining your personal data are that as an investment advisory firm focused exclusively on investing in venture capital funds we contact, and develop relationships with, a variety of individuals and organisations. The collection and retention of the personal data of our prospective and current clients, investors and suppliers, and of professional advisers, consultants, enquirers and complainants is essential to our business activities.
In order to support the commercial aspirations of our clients, investors and suppliers we require a database of personal data containing historical as well as current information.
To maintain, expand and develop our business we need to record the personal data of prospective clients, investors and suppliers.
Disclosure of your information
We may share your personal information with VenCap (Channel Islands) Limited and the Administrator to the VenCap funds at our sole discretion. VenCap (Channel Islands) Limited is a Jersey Registered Private Company (No. JE66663). They are required to keep and use your information in accordance with their Privacy Notice here. Jersey is the subject of an “adequacy finding” by the European Commission, which means that the Commission has decided that Jersey’s data protection legislation or international commitments provide an adequate level of data protection. That decision (‘Adequacy of the protection of personal data in non-EU countries’) can be accessed on the European Commission’s website.
We may share your personal information with VenCap (Channel Islands) Limited at our sole discretion. VenCap (Channel Islands) Limited is a Jersey Registered Private Company (No. JE66663). Jersey is the subject of an “adequacy finding” by the European Commission, which means that the Commission has decided that Jersey’s data protection legislation or international commitments provide an adequate level of data protection. That decision (‘Adequacy of the protection of personal data in non-EU countries’) can be accessed on the European Commission’s website.
We may disclose your personal information to any third party:
- in an anonymous format to be able to provide catering services at our events;
- if VenCap International plc or substantially all of its assets are acquired by a third party, in which case personal data held by us about clients, investors or suppliers will be one of the transferred assets.
Except as explained above, we will not disclose your personal data to any third parties for any other purpose unless we have your consent (where that consent is specific, written in clear and plain language and separate from other written matters) or we otherwise legally have the legal right or obligation to do so (for example, in an emergency).
We require our service providers to comply with data protection laws whenever they process your personal information.
Special categories of personal data (“sensitive personal data”)
Some of your personal data processed by us may be classified as falling within “special categories” under the GDPR or as “sensitive” under the Data Protection Act 2018. This may include any medical conditions which affect your dietary requirements or access to events.
If you disclose sensitive personal information to us, we will seek your consent (specific, written in clear and plain language and separate from other written matters) to use that information for the purpose given to you at the time the information was collected.
We will only share your sensitive personal data with other third parties without your consent if we are legally obliged to do so.
International data transfers
The information that we collect from you will only be transferred to, processed and stored in a jurisdiction outside the European Economic Area (EEA) other than one deemed “adequate” by the European Commission’, or a company within the United States of America which does not participate in the Privacy Shield Framework, if:
- appropriate safeguards as set out in the GDPR have been put in place; or
- you have consent explicitly to the transfer (where that consent is specific, written in clear and plain language and separate from other written matters, and you have been informed of the possible risks of such a transfer in the absence of an adequacy decision, Privacy Shield participation or appropriate safeguards); or
- the transfer is necessary for the performance of a contract between you and us, or for the implementation of pre-contractual measures taken at your request; or
- the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and another natural or legal person; or
- the transfer is necessary for important reasons of public interest; or
- the transfer is necessary for the establishment, exercise or defence of legal claims; or
- the transfer is necessary in order to protect your vital interests or those of other persons, where you are physically or legally incapable of giving consent.
Security of information
Where we have given you (or where you have chosen) a username and a password which enables you to access the investor area of our website, you are responsible for keeping your username and password confidential. You must not share your username or password with anyone, or store them in a way that may allow a third party to access them.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website: any transmission is at your own risk.
Your personal credentials are encrypted using a secure protocol (HTTPS) between your browser and the website and when we receive any of your information we will use strict procedures and security features which are appropriate to the type of personal data you have provided to try to prevent unauthorised access or inadvertent disclosure.
Retention of your data
We understand our legal duty to retain accurate personal data and to retain such data only for as long as we need it to meet our legitimate business interests. Accordingly, we have a data retention policy and procedures to remove data that we no longer have a legitimate business interest in retaining.
We will retain the information we receive and collect about you in accordance with our legal rights and obligations.
Under the GDPR you have the rights to:
- access the personal information that we hold about you (please refer to “Access to your personal information” below);
- rectification of personal information – this enables you to have any incomplete or inaccurate information we hold about you corrected;
- erasure of your personal information – this enables you to ask us to delete or remove your personal information where there is no good reason for is to continue to process it. You also have the right to ask us to delete your personal information where you have exercised your right to object to processing (see below);
- object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which means that you want to object to processing;
- restriction of processing – this enables you to request that we suspend the processing of your personal information, for example where you want its accuracy verified;
- transfer of your personal information to another party to another controller, if technically feasible; and
- make a complaint to a supervisory body if you are unhappy with the way in which we have handled your personal information – in the UK this is the Information Commissioner’s Office, which can be contacted through this link: https://ico.org.uk/concerns
Access to your personal information
You have the right to obtain from us confirmation as to whether or not we are processing your personal information and, if so, to obtain access to it and to be given the following information:
- the purposes of the processing;
- the categories of the personal data concerned (i.e. what type of information about you we process);
- the recipients, or the categories of recipients, to whom your personal information has been disclosed or will be disclosed;
- the length of time we envisage holding your information for, or at least the criteria on which we base our decision;
- if your personal information has not been collected from you by us, where we received it from; and
- whether we use your personal information for automatic decision-making, including profiling, and, if so, the logic involved and the significance and consequences for you of that processing.
If you request a copy of your personal information, we will provide it in electronic form unless you request otherwise (as long as another format is impracticable for your information).
We will not charge you for providing a copy of your information unless you make a duplicate request, in which case we will charge a reasonable fee based on our administrative costs.
If your request requires us to go to disproportionate effort, or is manifestly unfounded or excessive, or would adversely affect the rights of others, then we will not provide you with the information. In that event we will inform you promptly, giving you our reasons. We will make every effort to provide you with a satisfactory form of access or summary of the information you requested.
If you wish to request access to your information you should email us at firstname.lastname@example.org or write to us at VenCap International plc, Seacourt Tower, West Way, Oxford OX2 0JJ, United Kingdom.
We can assist you more effectively if you complete and return our Subject Access Request Form, which we will be happy to send to you. Please note that we will require you to prove your identity before we release any personal information to you (for example, by providing photographic identification).
Our website is not intended for children. We do not knowingly collect personal information from users deemed to be children under their respective national laws.