IMPORTANT INFORMATION FROM ALBIONVC
AlbionVC 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
- One of our business contacts
- Involved in a transaction with us or our investment entites
- A potential candidate for director roles
When used in this notice, “Albion” 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 on 1 October 2018.
We do not collect any sensitive personal data about you. We are allowed to 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.
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 ensure full disclosure is made to the Financial Conduct Authority). 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.
Some of our service providers that act as our processors could have access to your personal data such as our IT consultants or psychometric testing providers. In addition, we share your personal data with recruitment and credit reference agencies and, in some circumstances, the Financial Conduct Authority, who act as separate controllers of your personal data.
If you are employed by us, our staff privacy notice will then apply to your personal data.
If you have had contact with us, for example through emailing us or meeting an Albion representative, we may store limited amounts of personal data relating to you, such as your name, job title, employer organisation and contact details.
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.
We are allowed to process this personal data on the basis that it is in our legitimate interests to:
- Maintain relationships with our business contacts
- Send you material which will think will be of interest given our business dealings
- Develop our business network
- Promote and run our business.
We may share your personal data with companies who process personal data for us such as providers of contact management systems. We may also share your personal data with our professional advisers such as accountants, lawyers or other consultants. We may also share your personal data with other companies in our group.
Suppliers and Professional advisors
If you are a supplier to us, or one of our professional advisers, we will store limited amounts of personal data relating to you, including your name, job title, qualifications, employer organisation and contact details. 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 are allowed to process your personal data on the basis that it is in our legitimate interests to run and promote our business.
Actual or Potential management teams
If you are involved in a transaction that we or our investment entities enter into, or a potential transaction that Albion considers, as the member of the management team 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. This might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, 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 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
- Providing periodic business updates.
We may share your personal data with companies who process personal data for us such as providers of contact management systems. We may also share your personal data with third parties who act as separate controllers of your personal data such as credit reference 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 are allowed to process your personal data on the basis that it is in our legitimate interests in running 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 are allowed to process your personal data for the purpose of performing a contract and to comply with our regulatory and legal obligations.
If we ask for more detailed personal data from you when filling out directors questionnaires as part of our due diligence before we make an investment, we will provide a separate privacy notice to you when you receive the questionnaire.
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 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.
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 contact you about prospective roles.
Some of our service providers that act as our processors could have access to your personal data such as 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.
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. 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. If you are a 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 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.
International transfers of personal data
Albion and the investment entities do not transfer your data outside of the EEA. However, we use suppliers who may process personal data and have operations or use IT services in countries outside of the EEA. We ensure that our suppliers only transfer personal data outside of the EEA in accordance with General Data Protection Regulation. If you want more information about our suppliers and international transfers, please contact us using the details at the end of this privacy notice.
If we hold your personal data you are 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 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. Any requests should be submitted in writing and provide 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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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.
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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/
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How to contact us
If you need to contact us about this notice, please email firstname.lastname@example.org or call 020 7601 1850. You may also write to Head of Compliance, Albion Capital Group LLP, 1 Benjamin St, Farringdon, London, EC1M 5QG.