1.0 We are committed to safeguarding the privacy of our service users.
1.1 This policy applies where we are acting as a data controller with respect to the personal data of our service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.2 In this policy, "we", "us" and "our" refer to Sapphire Capital Partners LLP. For more information about us, see Section seven.
2. How we use your personal data.
2.1 In this Section two we have set out:
(a) the general categories of personal data that we may process;
(b) In the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We (including our appointed representatives and representatives) may process your general data ("service data"). The service data may include your name, email address, home address, phone number, work number, date of birth, bank details, investment history, national insurance number, appropriate credit checks, police reports, photographic I.D, tax information, nationality and place of birth. The source of the service data is provided by you. The service data may be processed for the purposes of providing out services, ensuring the security of our services, maintaining backups of our data bases, obtaining tax relief’s such as SEIS, EIS and R&D tax credits, the vetting process to be an investor in which we act as an investment manager, the creation of an EPUT or data relating to the start-up and/or innovator visa program. The legal basis for this processing is performance of contract or our legitimate interests, namely the proper administration of our business or the performance of a contract between you and us and at your request and to enter into such a contract.
2.3 We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and advising on relative services to you. The legal basis to process enquiry data for the purposes of responding to that enquiry is likely to be performance of contract and our legitimate interests. In the case where we wish to process enquiry data for the purposes of marketing or an offering, we will have obtained explicit consent and therefore the legal basis for this processing is consent.
2.4 We may process [information relating to our customer relationships, including customer contact information] ("customer relationship data"). The customer relationship data may include your name, your company, your role, your contact details, and information contained in communications between us. The source of the customer relationship data is you or a related party, such as the custodian, the investment advisor, the investment provider or the fund mentor. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis to process customer relationship data is likely to be to comply with a legal obligation as well as the performance of contract. It may also include legitimate interests, depending on the circumstances.
2.5 We may process data from our website “customer website data”. This data may include your name, company name, address, number, email address, business information and any other relative information relating to a query. The customer website data may be processed for marketing purposes, which includes industry news, blog articles, e-Book updates, newsletters and other relative information. The legal basis for marketing purposes will be consent, a tick box is present at every data entering location on the website. Other data collected on the website for other business purposes, such as answering questions or starting the client process will be obtained on the legal basis of legitimate interests or performance of a contract, a consent option may also be required depending on where your data is submitted.
2.6 We may process data from third parties or publicly available sources ("third party data"). The third-party data may include data such as a name, company name, role, contact details, and information contained in communications between us. The source of the third-party data is a third party or a related party, such as a public website, a custodian, an investment advisor, an investment provider or a fund mentor. The legal basis to process third party data is likely to be to comply with legitimate interests, depending on the circumstances.2.6 We may process information relating to transactions, including purchases of our services, that you enter into with us ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our business.
2.7 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.8 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.9 In addition to the specific purposes for which we may process your personal data set out in this Section two, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
2.10 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3.1 In order for us to provide our services, we may be required to share your personal data. Consequently, we may disclose your personal data to those parties who act as the custodians, the nominee, the investment advisor and the fund mentor. We may also be required to disclose your personal data to the Financial Conduct Authority or Financial Ombudsman.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 In addition to the specific disclosures of personal data set out in this Section three, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.1 This Section four sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 We will retain your personal data as follows:
(a) All data relating to funds will be retained for a period of six years following the end of investment.
(b) where applicable to funds some data may be held for a period longer than six years if HMRC or the Finance Act 2007 requires so.
(c) All data relating to client work such as SEIS/ EIS/ VCT or R&D tax credit engagements will be retained for a period of six years following the end of the engagement.
4.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of fund and investment related data will be determined based on any requirement or investigation by HMRC.
4.5 Notwithstanding the other provisions of this Section four, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.1 We may update this policy from time to time by publishing a new version on our website or a new version will be emailed to you.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We will notify you of significant changes to this policy by email.
6.1 In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
6.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by emailing email@example.com.
6.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing purposes including profiling for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
6.9 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract.
6.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. However, we would appreciate the opportunity to resolve your concerns prior to you making a compliant. Please feel free to contact us directly by email at firstname.lastname@example.org to discuss any concerns you may have.
6.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.12 Your personal data we receive is stored on Google drive which encrypts documents and attachments, storing them securely in encrypted folders. Google drive uses a ‘Perfect Forward Secrecy’ encryption which ensures the security of documents when they are moving through the web. More information can be found on googles security page: https://support.google.com/googlecloud.
6.13 All computer devices that has access to any data is password protected and encrypted to ensure data security. Any printed data is locked away in a secured room and filing systems. Any data stored on paper is disposed of via shredder. It is noted that Sapphire Capital Partners LLP rarely use printed data.
7.1 Sapphire Capital Partners LLP is regulated by the Financial Conduct Authority (FCA number: 565716).
7.2 We are registered in the United Kingdom under registration number NC000562 and our registered office is at 28 Deramore Park, Malone, Belfast, BT9 5JU.
7.3 Our principal place of business is at our Belfast office: 28 Deramore Park, Malone, Belfast, BT9 5JU and our London office: Berkeley Suite, 35 Berkeley Suite, Mayfair, London, W1J 5BF.
7.4 You can contact us:
(a) by post, to our Belfast office given above.
(b) by telephone, on +44 (0) 800 0545 070
(d) by email, email@example.com
8.1 Our data protection managers details are:
Johnathan Graham, firstname.lastname@example.org , 07833085164