Legal terms, privacy notice and cookie policy

IMPORTANT INFORMATION FROM ALBION CAPITAL

LEGAL TERMS

The information on this site is directed at persons resident in the UK and is not to be regarded as an offer to buy or sell, or the solicitation of any offer to buy or sell securities or investments in any jurisdiction other than the UK, including, but not limited to, the United States of America.

Persons resident in territories other than the UK should consult their professional advisers as to whether they require any governmental or other consents or need to observe any formalities to enable them to invest in the products described on this website.

We do not offer investment advice or make recommendations regarding investments, nor do we offer tax advice and nothing on this website should be construed as investment or tax advice. The information on this website is for information purposes only. Under no circumstances is the information to be used or considered as an offer to sell, or a solicitation of an offer to buy, any security. Additional information is available upon request. Where information has been obtained from outside sources, it is believed to be reliable but is not represented to be accurate or complete. Past performance is not necessarily a guide to the future. The value of an investment and any income from it can go down as well as up and you may not get back the amount originally invested.

If you need more information about investment with Albion Capital, please contact us. Alternatively, if you wish to obtain personal advice as to whether the products on this website are suitable for your needs, you should consult an independent financial adviser ("IFA"). If you would like a list of IFAs in your area, please go to www.unbiased.co.uk

Telephone calls and electronic communications are recorded to comply with our legal and regulatory obligations.

We accept responsibility for the information on this website. To the best of our knowledge and belief (having taken all reasonable care to ensure that such is the case) the information on this website is in accordance with the facts and does not omit anything likely to affect the import of such information. This website may contain links to other websites provided by third parties. Such links are for your information only and we have no control over the content or resource of those sites and accept no responsibility for them, or any loss or damage that may arise from your use of them.

This website is subject to regular update and revision. While we attempt to ensure the correctness and timeliness of all material posted on the website, we take no responsibility for errors or omissions which are the result of technical causes, or otherwise. We maintain the right to delete or modify in part or in full any information on this website without prior notice.

Albion Capital Group LLP is authorised and regulated by the Financial Conduct Authority ("FCA").

PRIVACY NOTICE

Albion Capital takes your privacy seriously. This notice sets out how we collect, store and use your personal data if you are:

a user of our website
applying for a job with us
an investor or shareholder in one of our investment entities
one of our business contacts
one of our suppliers or professional advisers
involved in a transaction with us or our investment entities
involved in our Platform or Talent initiatives
a potential candidate for director roles

When used in this notice, “Albion Capital” means Albion Capital Group LLP or any of its subsidiaries or related companies. Unless otherwise stated below, Albion Capital Group LLP is the controller of your personal data for the purposes of applicable data protection legislation.

Changes to this privacy notice will be posted here, so please check here for the most recent version when you visit our website. This privacy notice was last updated in May 2023.

Website users

If you are just browsing our website we will not collect personal data other than your IP address collected through our cookies. You can see our cookie policy below. This website only collects data that you enter into the website for example to submit an enquiry or where you follow a link from our website to send us an email. If you subscribe to any of our mailing lists or you otherwise ask to receive our mailings, we will use your contact details to send you the material you have requested. You can unsubscribe at any time by clicking the unsubscribe link in the emails you receive or by contacting us using the details below.

We do not collect any sensitive personal data about you. We process your personal data on the basis that it is in our legitimate interests to:

monitor how our website is used in order to improve it
respond to enquiries, complaints and requests
send you the material you have requested or which we think will be of interest given our previous business dealings.

We use service providers to operate our website and some of these service providers may process your data as part of the services they offer to us. We take steps to ensure that our service providers treat your data in accordance with the law, only use it in accordance with our contract with them and keep it secure.

Job applicants

If you submit an application for a job with us we will store personal data relating to you. Depending on how far your application progresses, this might include your contact details, your relevant education and employment history, details of referees and information you provide in your CV. Further information may be generated by you and us later on such as notes of interviews and answers to written tests. We may gather further personal data before deciding whether to make you a final offer such as proof of your identity, proof of your qualifications, pre-employment health questionnaires and credit checks. If you apply for a role that must be approved by the Financial Conduct Authority we may obtain details of any relevant criminal or disciplinary history as part of that approval process.

Most of the personal data that we process about you when you apply for a job is information that you give us directly or is generated through the recruitment exercise, although we may gather information from recruitment agencies, your referees and credit reference agencies. If you are required to take psychometric tests, the test provider will send us your responses and any analysis they carry out based on your responses. We may in certain circumstances need to seek confirmation from the Home Office that you have the right to work in the UK.

Most of the personal data described above is processed by us pursuant to our legitimate interests as an employer. We use your personal data to contact you about your application and to assess your experience and suitability for a job with us, to help us assess your training needs and understand your characteristics and working style. We may process special categories of data to ensure that we can comply with our legal or regulatory obligations as an employer, such as details of your right to work in the UK, information about your health (in order to assess whether you are medically able to carry out the work offered and whether any adjustments would be needed to your work environment), information about a disability (in order to make reasonable adjustments to your application process or assess adjustments to your potential work environment), details of your relevant criminal or disciplinary history (to comply with our regulatory obligations). We may process information about your health for the purposes of occupational medicine, in order to assess your medical capacity to perform the job you have applied for. We may also need to process personal data in order to exercise our legal rights and bring or defend claims.

We may share your personal data with companies who process personal data for us such as providers of background checking, screening services or psychometric testing services, cloud hosting solutions, IT consultants or contact management systems. In addition, we may share your personal data with recruitment agencies and, in some circumstances, the Financial Conduct Authority, who act as separate controllers of your personal data.

If you become employed by us, our staff privacy notice will then apply to your personal data.

Shareholders and investors

If you are a shareholder or investor in one of the venture capital trusts that we manage or another Albion Capital investment fund or entity that we manage or advise (together “investment entities”), the investment entity will collect personal data about you including your name, address, email address, contact numbers, bank account details and national insurance number in order to process your application to subscribe for shares or limited partnership interests and to maintain the share register or equivalent of the investment entity. The investment entity may also collect documents to confirm your identity or the identity of owners and controllers of an investor vehicle. The relevant investment entity is the controller of your personal data.

The personal data of investors and shareholders is collected and processed on behalf of the investment entity so that it can comply with its legal, regulatory and contractual obligations to:

confirm your identity before accepting your investment
process your application
maintain the shareholder register (or equivalent)
communicate with shareholders and investors (including the mailing, in physical or electronic format, of annual reports, AGM or EGM notices and proxy card)
facilitate the payment of dividends or other distributions from the investment entity
provide you or your advisers with up to date information about your investment.

The relevant investment entity will share your data with service providers who process personal data on their behalf, such as ourselves, Albion Capital Group LLP (as manager or adviser), any appointed registrar, the depositary of the investment entity for their monitoring activities, entities who provide data reporting services or platform services for the online investor applications or providers of cloud hosting solutions.

The relevant investment entity may instruct Albion Capital to share data with your financial or other adviser, where you give authority to do so or Albion Capital is satisfied that an adviser is appointed by you. Such information may be shared via a third-party data reporting service. It is in the legitimate interests of the investment entity to respond to you or your adviser’s enquiries about your investments so that your adviser can provide you with updated information on your investments and advise you in relation to your portfolio. Your financial or other advisers act as separate controllers of your personal data. The relevant investment entity may instruct Albion Capital to share your data with professional advisers such as brokers, accountants, lawyers or consultants in order to assist with enquiries from investors or to provide professional advice.

If we make changes to this notice that affect you we will let you know in our communications with you.

Business contacts

If you have had contact with us, for example through emailing us, registering for an event, completing one of our online forms or surveys, downloading our information brochures or meeting an Albion Capital representative, we may store limited amounts of personal data relating to you, such as your name, job title, employer organisation and contact details.

If you register and sign up to attend an event hosted by us, whether online or in person, we will collect personal data such as your name and email address. Recordings of such events hosted by us may capture your image, voice and any contributions made by you to the event. We are the controller of your registration and sign-up data and the event content. Online events are hosted on platforms provided by third parties. The platform provider is the processor of your registration data and the event content. The platform provider may also act as a separate controller of your registration and sign-up data for its own legitimate business purposes as described in its own privacy notice.

We will use this personal data in order to:

maintain a record of contacts
provide you with periodic business updates
invite you to presentations and events
organise meetings between you and our representatives
analyse attendance at our events
maintain recordings of events for viewing by others.

We process this personal data on the basis that it is in our legitimate interests to:

maintain and manage relationships with our business contacts
send you material which we think will be of interest given our business dealings
develop our business network
promote and run our business
develop and provide events of interest to our contacts

We may share your personal data with companies who process personal data for us such as providers of cloud hosting solutions, online forms, surveys or event invitations, email automation platforms or contact management systems. We may also share your personal data with our professional advisers such as accountants, lawyers or other consultants. Our online event platform provider may process event data such as recordings of events, streamed materials and chat transcripts. We may publish recordings of our events on our website and social media. We may also share your personal data with other companies in our group.

Suppliers and Professional advisers

If you represent or work for one of our suppliers or professional advisers, we will store limited amounts of personal data relating to you, including your name, job title, qualifications, employer organisation and contact details. We will store this personal data for the purposes of administering and maintaining records of services or advice we have received and commissioning further services.

We process your personal data on the basis that it is in our legitimate interests to run and promote our business.

Transacting with us or our investment entities

If you are involved in a transaction that we or our investment entities enter into, or a potential transaction that Albion Capital considers, we may store personal data relating to you. Transactions include the initial investment made by our investment entities, further investments, exiting from the investment or any exercise of investor rights. The personal data might include your name and contact details, CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, your date of birth, your residential address, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out.

We collect and store this data for the purposes of:

assessing potential transactions including the experience, capability and financial stability of the management team
maintaining records of investments
administering any transactions that we or our investment entities enter into
assessing your suitability for involvement in a transaction, including by verifying your identity
complying with our legal and regulatory obligations such as those relating to money laundering and assessing and managing risk on behalf of our investment entities
safeguarding our legal rights and interests and those of the investment entities we manage or advise
seeking and receiving advice from our professional advisers
arranging meetings
providing periodic business updates.

We may share your personal data with companies who process personal data for us such as providers of background checking, screening services or psychometric testing services, cloud hosting solutions, IT consultants or contact management systems. We may also share your personal data with third parties who act as separate controllers of your personal data such as regulators and law enforcement agencies, our professional advisers and other persons who have a potential interest or involvement in one of our transactions such as co-investors or investors in our investment entities.

We process your personal data on the basis that it is in our legitimate interests to run our business, in particular by considering potential investments and administering transactions that we and our investment entities enter into. If we or our investment entities enter into a transaction that you are involved in, we process your personal data for the purpose of performing a contract with you or the entity you work for. We may also process your data to comply with our regulatory and legal obligations.

If we collect additional personal data from you through a directors' questionnaire as part of our due diligence before we make an investment, we will provide a supplementary privacy notice to you when you receive the questionnaire.

Platform and Talent initiatives

Leadership development programmes:

We store personal data that you voluntarily disclose to us if you participate in the leadership development aspects of our Platform or Talent initiatives as a founder of one of our portfolio companies, prospective portfolio companies or other start-up.

We store your name, email address, job title and other contact details. We may store information arising from registration forms, questionnaires or coaching sessions relating to your behavioural and personality characteristics and career experiences.

If we enable you to access web-based tools or other software designed to interpret your personal characteristics or develop your leadership potential, the platform or software provider acts as our processor and we are the controller of any resulting reports or outputs that are shared with us. The platform or software provider may collect technical data about your equipment, browsing actions and patterns, as outlined in the privacy notice on their websites. The platform or software provider may collect your registration and sign-up data in relation to any account or profile you have with them and your interactions with their customer services or technical support. We are the controller of this information unless the platform or software provider specifies that they are an independent controller of this data in their privacy notice.

We collect and store this data for the purposes of:

providing leadership coaching and other forms of support to you as a participating founder
corresponding with you and arranging meetings with you
understanding and improving our support for portfolio companies experiencing growth
developing and improving our understanding of archetypal founder characteristics
creating and publishing articles relating to thought leadership, industry and market trends
providing you with information and updates about our business and inviting you to events we believe are of interest to you.

Your personal data is processed by us pursuant to our legitimate interests as a fund manager in assisting with the development of portfolio companies and their founders. We may share your personal data with companies who process personal data for us such as providers of cloud hosting solutions, online forms, surveys or event invitations, email automation platforms, contact management systems and web-based tools.

We may collect demographic data about you such as your age, background, family history and education. This includes special category data relating to your ethnicity and disability status. We will only do this where you have provided us with your explicit consent to allow us to collect and process this type of information. We remove personal identifiers from this information and use it for equal opportunity monitoring and reporting, research and statistical analysis. We may use it to write articles on thought leadership, industry and market trends. You will not be identified in any outputs resulting from this analysis and your demographic data will not be used to make decisions about you. Some of our service providers that act as our processors could have access to your personal demographic data such as providers of cloud hosting solutions, online surveys and web-based tools.

We do not use your demographic or other personal data to make solely automated decisions about you.

Platform:

If you are a portfolio founder or CXO with access to our web-based founder and CXO community (“Platform”), we store personal data that you voluntarily provide to us when you register to be included. This includes your name, role title, LinkedIn profile web address, career experience, interests, skills, areas of expertise and your photograph. This information will be viewable by other Platform users. You can request a copy of the information you provide on registration. For our own purposes we also store your contact details, such as your email address, and data about our interactions with you including introductions we facilitate between you and others.

If you are included on our Platform as a recruitment partner, network expert or service provider, we store personal data that you voluntarily provide to us when you register to be included. This includes your name, LinkedIn profile web address, values, skills, interests, expertise and professional experience. This information will be viewable by our Platform users. You can request a copy of the information you provide on registration. For our own purposes we also store your contact details, such as your email address, data about our interactions with you, feedback we receive about you and any introductions to you that we facilitate.

We collect and store your personal data in order to:

manage and maintain our Platform
facilitate introductions
enable founders and CXOs to access our professional networks
understand and improve our support for portfolio companies experiencing growth
correspond with you and provide you with information and updates about our business and invite you to events we believe are of interest to you.

Your personal data is processed by us pursuant to our legitimate interests as a fund manager in assisting with the development of portfolio companies and their founders.

We may share your personal data with companies who process personal data for us such as providers of cloud hosting solutions, app platforms, online forms, surveys or event invitations, email automation platforms and contact management systems.

If you wish to update the information you supplied to us on registration or request that we remove your information from our Platform, please send an email to hello@albion.vc

Messaging platforms:

If you are invited to participate in any of our channels within a messaging platform such as Slack, we store personal data about you including your name and the content of your messages, files and other contributions to our channels.

We collect and store your personal data in order to:

communicate with you
facilitate introductions
enable founders and CXOs to access our professional networks
understand and improve our support for portfolio companies experiencing growth
correspond with you and provide you with information and updates about our business and invite you to events we believe are of interest to you.

Your employer or the person/entity who set up your account with the messaging platform is the controller of your registration, log-in and other data on the platform in accordance with their privacy notice. The messaging platform may collect other information about you as described in its own privacy notice.

Your personal data is processed by us pursuant to our legitimate interests as a fund manager in assisting with the development of portfolio companies and their founders.

You may remove yourself from our channels at any time.

Hiring Playbook:

If you request access to our digital Hiring Playbook, we store personal data that you provide to us when you register your interest. This includes your name and email address. We also store information that you input to your Hiring playbook. We collect and store your personal data to:

Enable your access to the digital Hiring Playbook and respond to your enquiries
Improve and develop our research and understanding of the hiring needs of venture businesses
Correspond with you and provide you with information and updates about our business and invite you to events we believe are of interest to you

Your personal data is processed by us pursuant to our legitimate interests as a fund manager developing and providing tools to assist the development of venture businesses. We will share your personal data with the platform that hosts the digital hiring playbook in order to grant you access. The platform acts as controller of the information you provide to create an account with them.

Candidates for Director roles

If you send us your information because you would like us to refer you for relevant director or non-executive director roles in one of our portfolio companies or VCTs we will store personal data relating to you. This will include your contact details and information you provide in your CV such as your relevant education and employment history and details of your referees. Further information may be generated by you and us later on such as notes of meetings with you or conversations with your referees.

For director roles for our portfolio companies, your personal data is processed by us pursuant to our legitimate interests as a fund manager in assisting with the development of portfolio companies. We use your personal data to assess your suitability and to contact you about prospective roles.

Some of our service providers that act as our processors could have access to your personal data such as providers of cloud hosting solutions, our IT consultants or contact management system providers. In addition, we share your personal data with relevant portfolio companies, who act as separate controllers of your personal data.

For VCT director roles, we will store personal data relating to you. This will include your contact details and information you provide in your CV such as your relevant education and employment history and details of your referees. Further information may be generated by you and us later on such as notes of meetings with you or conversations with your referees.

We may also collect information to confirm your identity such as your date of birth, residential address and nationality. The relevant VCT is the controller of your personal data.

The personal data of VCT director candidates is collected and processed by the VCT so it can comply with its legal, regulatory and contractual obligations to:

assess your suitability for the role
confirm your identity before appointing you
maintain statutory registers
maintain insider lists and notify transactions made by persons discharging managerial responsibilities
make RNS announcements.

The relevant VCT will share your data with service providers who process personal data on their behalf, such as ourselves, Albion Capital Group LLP (as manager), providers of cloud hosting solutions and, if you are appointed, with professional advisers.

If we collect additional personal data from you through a directors' questionnaire as part of our due diligence before your appointment, we will provide a supplementary privacy notice to you when you receive the questionnaire.

Retention of personal data

The period for which we will retain your personal data will vary depending on the purposes for which it was collected, as well as the requirements of any applicable law or regulation.

If you send us an enquiry, we will hold your data until the enquiry has been completed and no further response is received for a reasonable period.

If you subscribe to our mailings, we will keep your data until you tell us you no longer wish to receive them. You will always be provided with the opportunity to opt-out of receiving these communications.

If you make a complaint, we will retain your data for a period of up to six years after resolution of the complaint.

If you apply for a job with us and your application does not result in us employing you we will delete all the personal data gathered during the recruitment exercise six months after the recruitment exercise has ended unless you ask us to keep your details for a longer period in order that we may consider you for any future roles we may have. We keep your data for six months regardless so that we can defend any legal claims arising from the recruitment process.

If you are an investor or shareholder, the investment entity will retain your data for up to 10 years after the date on which you cease to be an investor or shareholder.

If you are a business contact, we will keep your data until you tell us that you no longer wish to hear from us or our relationship is ended.

Recordings of our online events will be retained for up to eighteen months and attendee data for up to five years.

If you represent or work for an adviser or supplier, we will keep your data until 6 years after our contractual relationship ends, and thereafter as a business contact.

If you provide us with personal data because you are involved in a transaction with us as part of an actual or potential management team, we will retain your personal data for up to 10 years from our exit of the investment. If we collect your personal data to comply with anti-money laundering regulations because you or the entity you work for are otherwise involved in a transaction with us we will keep your identity data for five years from the date of the transaction, as required by regulation.

If you are a participant in our Platform or Talent initiatives and are not or do not become a founder of one of our portfolio companies, we will retain your personal data for up to six years from the end of our relationship with you, unless you request us to destroy it or retain it for a shorter or longer period of time. Demographic data collected in conjunction with your participation in our Platform or Talent initiatives will be retained for a maximum of one year. We may retain aggregate information beyond this time but individuals cannot be identified from aggregate information retained. If you have accessed our digital Hiring Playbook we will retain your data until you request us to delete it.[NS1]

If you have provided your details to be included on our Platform we will remove your personal data from our Platform when you tell us that you no longer wish to be included.

If you are a candidate for director roles, we will retain your personal data for up to 10 years from when you send us your personal data or until you tell us that you are no longer interested in a role and do not want your data to continue to be held, whichever is earlier.

If you are a candidate for a VCT director role, we will retain your personal data for 7 years after the cessation of the appointment for successful candidates, or 6 months after the decision not to proceed, unless you ask us to keep your data for longer so that we may consider you for future roles.

International transfers of personal data

Some of our third party processors are based outside the UK and their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring a 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.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

If you want more information about our processors and international transfers, please contact us using the details at the end of this privacy notice.

Your rights

If we hold your personal data you may be entitled to access your personal data, or to request that it is erased, that its processing is restricted, or that any inaccurate data is rectified. You may also have the right to object to the processing of your personal data or, in some circumstances, to obtain an electronic copy of your personal data which we hold electronically or request us to provide it directly to another party. Your rights depend upon the basis on which we process your personal data and whether any exceptions or exemptions apply to the circumstances. We are unable to remove or obscure faces and voices from recordings of our online events as they are embedded in the recording. Any requests should be submitted in writing together with proof of your identify to the contact details specified below. We will respond within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.

If you do not think that we have processed your data in accordance with this privacy notice, you should let us know as soon as possible. You also have the right to complain to the Information Commissioner's Office (see www.ico.org.uk).

Accuracy and Security

We strive to implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data. We follow recognised industry practices for protecting our IT environment and physical facilities.

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COOKIE POLICY

cookie policy

Measuring Google Analytics

We use first-party Google Analytics cookies to track anonymous usage statistics and do not collect any personal information that can be used to identify you. This helps us analyse data about webpage usage and improve our website in order to tailor it to customer needs. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. We do not allow Google to use or share our analytics data.

Google analytics sets the following first-party cookies:

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_utmaRandom Number2 years from now

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_utmcRandom Number When you quit your browser

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_utmzRandom Number6 months from now

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Google Analytics does not collect any personal information, as identified in their privacy policy. Google also offers a browser plugin that allows users to opt out of their analytics. For further information about Google Analytics, visit: Google’s Privacy Policy - https://policies.google.com/privacy?hl=en Google Analytics Help pages - https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Social media website cookies

Users can ‘like’ or share our content on the likes of LinkedIn and Twitter where we have included sharing buttons on our site. The privacy implications for this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks. More information about cookies All About Cookies - http://www.allaboutcookies.org/

How do I manage cookies or turn them off?

You can manage the cookies stored on your computer, or turn them off completely, through your browser settings. All modern browsers will let you change your cookie settings to give you broad control over whether cookies can be set or not. For more information, visit the help section for the browser you use. Here are a few of the most popular:

Microsoft Edge - https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Firefox - https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

Chrome - https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

Safari - https://support.apple.com/en-gb/guide/safari/sfri11471/mac

How to contact us

If you need to contact us about this notice, please email regulatory@albion.capital or call 020 7601 1850. You may also write to Head of Compliance, Albion Capital Group LLP, 1 Benjamin Street, Farringdon, London EC1M 5QL.