Sussex Place Ventures Privacy Statement
May 2018
Introduction
This Privacy Statement describes how and why Sussex Place Ventures Ltd (“we” or “us”) collects and uses personal data (i.e. data relating to an identified or identifiable individual) in the course of its business. It applies to personal data provided directly to us by the individuals concerned and to personal data provided to us by companies and other organisations.
We are committed to the protection of personal data and to fair and transparent processing. If you have any questions about this Privacy Statement, you can contact our Data Protection Officer via email at info@spventures.com.
General Data Protection Regulation (GDPR) Privacy Notice
We are the data Controller and data Processor of the Personal Data you provide to us. We only collect basic personal data about you which does not include any special types of information or location based information. This does however include name, address, email and phone number and if you are an investor in any fund we manage this may include your national insurance and tax reference numbers, tax residence and personal identification needed to fulfil our anti-money laundering obligations. We do not collect any Sensitive Personal Data such as racial origin, political opinions or religious beliefs.
Why we need your personal data
We aim to collect personal data only to the extent necessary for us to provide our services to you. We need to know your basic personal data in order to provide you with on-going organisational updates and fund information and analysis services in line with this overall contract. We will not collect any personal data from you we do not need in order to provide and oversee this service to you. These data are held in password protected files.
Security of personal data
We have policies, procedures and training in place in respect of data protection, confidentiality and information security. We regularly review such measures with the objective of ensuring their continuing effectiveness.
What we do with your personal data
All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information is located on servers within the European Union. No third parties have access to your personal data unless the law allows them to do so.
We will only share personal data with third parties where we are legally permitted to do so. We do not provide information to third parties for their own marketing purposes and we do not undertake mailings for third parties. Where we transfer personal data to third parties, we will put in place appropriate contractual arrangements and seek to ensure that there are appropriate technical and organisational measures in place to protect personal data.
How long we keep your data
We will only keep personal data for as long as necessary for the purposes for which it was collected, or as required by applicable law or regulation.
We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. We will keep information including your address email and telephone numbers in order communicate fund news, as we are contractually obliged to do, until you notify us that you no longer wish us to hold this information.
What are your rights
You have rights in relation to any of your personal data held by us as a data controller. Should you wish to exercise your rights right, please contact our Data Protection Officer via email at info@spventures.com. We will endeavour to respond to any request promptly and within any legally required time limit.
If at any point you believe the information about you is incorrect you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated. info@spventures.com
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office https://ico.org.uk/