Committed Capital Privacy Policy

This privacy policy is provided by the Committed Capital Group (“Committed Capital”, comprising Committed Capital Financial Services Limited, an FCA authorised and regulated business with FRN 192203, Committed Capital Limited, an appointed representative of Sapia Partners LLP which is authorised and regulated by the FCA with FRN 550103), and is addressed to individuals outside our organisation with whom we interact. It seeks to inform you as to how we look after your personal data when you visit our website and engage with our business, and will tell you about your privacy rights and how the law protects you.

The Committed Capital Group respects your privacy and is committed to protecting your personal data. At all times we aim to respect any personal data you share with us or that we collect about you and keep it safe.

This privacy policy sets out how we look after your personal data when you interact with us including online through our website , www.committedcapital.co.uk, and your rights and options regarding the ways in which your personal data is used.

It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Topics

  1. Who we are

  2. Personal data that we collect about you

  3. How is your personal data collected?

  4. How we use your personal data

  5. Purposes for which we will use your personal data

  6. Sharing your personal data

  7. International transfers

  8. Security

  9. Data retention

  10. Exercising your legal rights

1. Who we are

Controller

Committed Capital is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

We have appointed a Compliance Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Compliance Manager using the details set out below.

Contact details

Name of Compliance Manager: Else Thomson

Email: info@committedcapital.co.uk

Telephone: + 44 (0) 20 7529 1350

Post: Committed Capital Limited, 150 Buckingham Palace Road, London SW1W 9TR.

Please mark the message for the attention of / ask for the Finance Director.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Committed Capital takes complaints very seriously and will respond to complaints within 30 days.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on 1 October 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. Personal data that we collect about you:

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes full name, username or similar identifier, marital status, title, national insurance number, date of birth and gender.

  • Contact Data includes postal address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

  • Profile Data includes your username and password, orders made by you, your professional status (including directorships), your personal interests and preferences and in some cases your social media identity.

  • Usage Data includes information about how you use our website and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may also collect the following Special Categories of Personal Data about you: racial or ethnic origin, nationality, financial status, salary information, employer references and information about your physical and mental health.

We may collect information about criminal convictions and offences when you provide it to us or where we are required to do so by law. Typically this would be in the context of a commercial acquisition or investment.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

When you give it to us directly

  • You may give us your Identity and Contact Data by signing up for our email newsletter, providing feedback, contacting us through our Contact Us page or applying for a job with us.

  • We may collect Identity, Contact, Financial and Transaction Data, when you sign up for investment into one of our products or agree to undertake our services.

  • We may also collect Identity and Contact Data as a result of due diligence carried out as part of our investment process.

Through automated technologies or interactions

When you visit our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

When we obtain it from publicly available sources

Your personal information may be available to us from external publicly available sources. This may include information available on Companies House, the Charity Commission and other charity registers, reputable media articles, publications and company websites and professional networking sites such as LinkedIn. Depending on your privacy settings for social media services, we may access information from those accounts or services, including from Facebook, Instagram and Twitter.

When we obtain it from third parties

For instance, we may obtain personal information about you from various third parties as set out below:

  • Technical Data from the following parties:

a) analytics providers such as Google, based inside and outside the EU; and

b) search information providers such as W2 Global Data Solutions Ltd and Experian based inside and outside the EU.

  • Contact, Financial and Transaction Data from the following parties:

a) providers of technical services such as IT service providers based inside and outside the EU;

b) professional advisers, wealth managers and other finance providers such as LGT Vestra LLP, Stanhope Capital and a variety of UK based IFAs for example Ascot Lloyd and Macalvins Limited based inside the EU; and

c) Screening providers such as W2 Global Data Solutions Ltd or other equivalent providers that assist us with AML checks.

  • Identity and Contact Data from publicly availably sources such as Companies House, LinkedIn and the Electoral Register based inside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

a) Where we need to perform the contract we are about to enter into or have entered into with you.

b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

c) Where it is necessary for us to comply with legal and regulatory requirements.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via telephone, post, email or other electronic means. You have the right to withdraw consent to marketing at any time by contacting us.

5. Purposes for which we will use your personal data

We may use your Identity, Contact, Financial, Transaction, Marketing and Communications, Technical, Profile and Usage data for the following purposes, on the basis that it is necessary for our legitimate interests:

  • to manage payments, fees and charges and to collect and recover money owed to us;

  • to carry out our business activity as an investment fund manager and adviser;

  • to provide further information about our work, services, activities or products (where necessary, only where you have provided your consent to receive such information);

  • to answer your questions/requests and communicate with you in general;

  • to analyse and improve our work, services, activities, products or information (including our website) and to hold a list of contacts (such as other finance providers) that we work with or would wish to work with;

  • to report on the impact and effectiveness of our work, in particular to stakeholders in our funds, i.e. investors in those funds and the ultimate providers of those funds;

  • to run/administer our website, keep the website safe and secure and ensure that content is presented in the most effective manner for you and for your device;

  • to register and administer your participation in events;

  • to review your application for a job to work for us or an internship and to contact you about the position and any interview process; and

  • to review any applications for a management position where we are involved in the recruitment process for one of our portfolio companies.

Our legitimate interests in processing your personal data for the above purposes, are as follows:

  • for running and growing our business (as a regulated firm);

  • to provide effective customer service and to study how customers use our services;

  • to develop our services;

  • to keep our records updated;

  • to recruit employees for our business;

  • to provide provision of administration and IT services, network security;

  • to prevent fraud;

  • to comply with the law;

  • to recover debts due to us;

  • to facilitate a potential business reorganisation or group restructuring exercise;

  • to inform our marketing strategy; and

  • to bring and defend claims to protect our business.

We may use your Identity, Contact, Financial, Transaction data for the following purposes, on the basis that it is necessary for the performance of a contract with you:

  • to complete work for you, or supply our services to you;

  • to keep you updated with regard to the status of a transaction and/or investment;

  • to contact you with regard to further related investment opportunities and/or follow-on investments; and

  • to carry out appropriate due diligence on shareholders and management team members in the context of a commercial acquisition or investment.

We may also use your personal data to comply with legal and regulatory requirements, for example to co-operate with regulatory, government and/or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering). As a regulated firm, we are required to conduct due diligence on investors in our funds, organisations in which our funds invest, directors and senior management or trustees of those organisations, individuals and organisations we invest alongside and purchasers when we exit an investment, for the purposes of preventing financial crime. In order to fulfil our obligations, we are required to verify the organisation’s identity and conduct certain background screening. This may include verifying the identity of the organisation's shareholders, beneficial owners, management, directors, trustees or officers and/or other relevant information. To assist us with the verification and screening process, contact details you provide will be disclosed to anti-money laundering screening, credit reference and fraud prevention agencies which may keep a record of that information. If we need to conduct this due diligence using any of the personal information you have provided us with, you will be provided with further information prior to us doing so. We may also share this information with our lawyers and FCA-approved co-investors in relation to the particular transaction as is customary in the sector to avoid you having to provide the information more than once.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased work, services, activities or products from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will not share your personal data with any company outside Committed Capital for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

6. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. Sharing your personal data

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 5 above.

  • Third party suppliers such as such as Mainspring Fund Services Limited, Exact Financial Systems Limited, TipTop IT Ltd based inside the EU.

  • W2 Global Data (www.w2globaldata.com) and third party money-laundering screening, credit reference and fraud prevention agencies based inside and outside the EU, for the purpose of carrying out Know Your Client checks in the context of a commercial acquisition or investment.

  • Government bodies such as HMRC and the FCA based inside the UK where we are legally required to do so or upon their reasonable request.

  • Our lawyers and FCA-approved co-investors such as LGT Vestra LLP and Stanhope Capital (both based in London), as well as a variety of UK based IFAs, for example Ascot Lloyd, Macalvins Limited who may be based inside or outside the EU (this is customary in the sector to avoid you having to provide your personal information more than once).

  • The funds which we manage from time to time based inside the EU.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require any third parties which we have contracted with to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International Transfers

The personal information that we collect from you will be stored at a destination within the UK or European Economic Area (“EEA”) and generally our processing of your personal data will not involve a transfer of data outside the EEA.

In the event that our processing of your personal data does involve a transfer outside of the EEA, we will ensure a an adequate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • where we use certain service providers, we may use contracts which give personal data the same protection it has in Europe; and

  • where we use providers based in the US, 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. For further details, see European Commission: EU-US Privacy Shield.

This is especially important because some countries outside of the EEA may have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals.

Please contact us if you want further information on the specific mechanisms that will be used by us if we transfer your personal data out of the EEA.

8. Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We comply with best market practice and erase all user data held after a period of 6 years from the data not being legitimately in use, unless we are required to remove it for any reason before this date.

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.

In some circumstances you can ask us to delete your data: see “Right of erasure” below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Exercising your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

a) Right of access: you can write to us to ask for confirmation of what personal information we hold about you and to request a copy of that information. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.

b) Right of erasure: at your request and where you are entitled to, we will delete your personal information from our records as far as we are required to do so. In many cases we will need to hold onto limited personal information about you in order to ensure we do not send you further communications.

c) Right of rectification: if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate/up to date.

d) Right to restrict processing: you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.

e) Right to object: you have the right to object to processing where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

f) Right to data portability: we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

g) Right to withdraw consent at any time, where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.