When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Angel CoFund, a company limited by guarantee and registered in England and Wales with company number 07864831|
|Personal data||Any information relating to an identified or identifiable individual|
|Special category personal data||Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membershipGenetic and biometric dataData concerning health, sex life or sexual orientation|
Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.
|Personal data we will collect||Personal data we may collect depending on why you have instructed us|
|Your name, address, email and telephone numbers for the purposes of initial enquiries relating to potential investment from the fundInformation to enable us to check and verify your identity, e.g. your date of birth or passport details, following any approval to invest and prior to completion Information to enable us to undertake AML checks, e.g. date of birth and gender||Your bank and/or building society details where a fee is payable by the fund to you in connection with initial investments from the fundDetails of your professional online presence, e.g. LinkedIn profile, for the purposes of investment research and due diligence|
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect this information from you direct via forms filled in through our website, direct emails to one of our team members, or emails to our generic Angel CoFund email accounts. However, we may also collect information from the following sources:
- from publicly accessible sources, e.g. Companies House;
- directly from a third party, e.g.:
- introductions or referrals from companies or other investors;
- sanctions screening providers;
- client due diligence providers;
- from a third party with your consent, e.g.:
- your bank or building society, another financial institution or advisor;
- consultants and other professionals we may engage in relation to your matter.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so:
|What we use your personal data for||Our reasons|
|To assess an investment proposal and provide funding to you, including working with our co-investment partners and throughout investment rounds||For the performance of our contract with you or to take steps at your request before entering into a contract|
|Conducting checks to identify our clients and verify their identityScreening for financial and other sanctions or embargoes, including liaising with our co-investment partners where necessaryOther processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by regulatory bodies||To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable informationTo comply with our legal and regulatory obligations|
|Statistical analysis to help us manage our fund and in connection with our reporting activities with public sector bodies, e.g. in relation to our investment levels and geographic splits||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for youTo comply with our legal and regulatory obligations|
|Updating and enhancing client records||For the performance of our contract with you or to take steps at your request before entering into a contractTo comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you|
|Marketing our services and those of selected third parties to:— existing and former clients— third parties who have previously expressed an interest in our services— third parties with whom we have had no previous dealingse.g. annual infographics about how the fund has been investing||For our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients|
|External audits and quality checks||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standardsTo comply with our legal and regulatory obligations|
The above table does not apply to special category personal data, which we will only process with your explicit consent.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by contacting us.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal data with
We routinely share personal data with:
- professional advisers who we work with in connection with an investment by the fund, e.g. lawyers, other investors or other experts;
- other third parties where necessary to carry out your instructions, e.g. lawyers in the case of the establishment of legal entities in various jurisdictions;
- our bank;
- external service suppliers, representatives and agents that we use to make our business more efficient, e.g. marketing/PR agencies.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.
How long your personal data will be kept
We will keep your personal data after our relationship has ended, e.g. for 7 years in respect of co-investors, company directors, and general fund enquiries. We will do so for one of these reasons:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g.:
- in connection with our portfolio companies where such entities are based outside the EEA;
- with your and our service providers located outside the EEA;
- if you are based outside the EEA;
- where there is an international dimension to the matter in which we are advising you.
These transfers are subject to special rules under European and UK data protection law. These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA.
Whenever we are required to transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
- where we use providers based in the US (e.g. Dropbox Inc.), we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA please contact us.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|To be forgotten||The right to require us to delete your personal data—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party — in certain situations|
|To object||The right to object:— at any time to your personal data being processed for direct marketing (including profiling);— in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.|
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the ICO’s guidance at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you would like to exercise any of those rights, please:
- complete a data subject request form—available at https://ico.org.uk/for-organisations/guide-to-data-protection/principle-6-rights/subject-access-request/; or
- email, call or write to us; and
- let us have enough information to identify you, e.g. your full name, address and client or matter reference number;
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns.
How to contact us
Our contact details are shown below:
|Our contact details|
|Angel CoFund, Suite 15, Sheffield Technology Parks, Cooper Buildings, Arundel Street, Sheffield S1 2NS firstname.lastname@example.org|
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).