- What Information Do We Collect From You and How Do We Use It?
The information we collect about you and how we will use it, depends on how you interact with us, as set out below.
General Information
We may collect basic information about you in the course of our interactions. It is not mandatory that you provide this information, but providing it helps us communicate with you. Such information includes your name, company name, email address, and phone number.
Client Engagement
As part of our client engagement process, prior to your subscription to an investment with us, it is mandatory that we collect the following information about you:
- Your full name, gender, and date of birth
- Residential address (current and previous), business name and address (if relevant)
- Employment status,
- Email address, telephone numbers
- National insurance number, tax ID number, tax status
- Bank details
- ID documents, such as your passport or driving licence
- An image or photo of you
We will use this information in order to complete our client engagement process, onboarding, and suitability checks, and if you subscribe to an investment with us, as set out in the “Investor Data” section below. You will not be able to subscribe to an investment with us without providing this information to us.
The legal basis for our use of this information is that it is in our legitimate interests to collect it in order to complete our client engagement process and for the purposes of your subscription. Some of this information is also required to enable us to comply with our legal obligations as set out in the “Fraud and Anti-Money Laundering Checks” section below.
Fraud and Anti-Money Laundering Checks
As part of our client engagement process, we will use the information you have provided to us to carry out ”Know Your Customer” (“KYC”) checks, such identification verification checks, anti-money laundering checks and in some cases, credit checks, for the purposes of meeting our regulatory obligations, including under the anti-money laundering regulations and any other applicable legislation, crime prevention, fraud prevention and credit risk reduction.
This may involve sharing your personal data with fraud prevention and credit reference agencies, our administrators, lenders, and similar third parties related to specific investments that are also subject to regulatory obligations in their dealings with us.
We may repeat some or all of these checks at intervals whilst you remain an investor with us, for example, where required by a bank or other lender for the purposes of their KYC/anti-money laundering checks or to fulfil our regulatory obligations, such as where identity verification documents have expired.
When we process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering and to verify your identity and reduce credit risk, in order to protect our business and to comply with laws that apply to us. Where applicable, you are required to submit to these checks under the terms of your Subscription Agreement.
We may also enable law enforcement agencies to access and use your personal data, to detect, investigate and prevent crime.
If we determine that you pose a fraud or money laundering risk or a credit risk, you may not be able to subscribe to an investment with us and there may be other consequences as set out in the subscription agreements and other governing documentation.
A record of any credit, fraud, or money laundering risk will be retained by us and the relevant fraud prevention/credit reference agencies and may result in others refusing to provide credit, services, financing, or employment to you.
Investor Data
If you subscribe to an investment with us, we will use your personal data to manage your investments and to communicate with you about existing and potential investments (for example to send you periodic updates of your portfolio). We may also use your personal data to perform analysis on your investments, perform risk management functions, and generally to aid us in managing your investments.
The legal basis for our use of this information is that it is in our legitimate interests to collect it in order to manage your investment(s) and to provide you with related services.
Additional Uses of Personal Information
We may also use the information we collect about you as set out below.
| The personal data we collect from you |
How we use it |
Lawful Basis |
| Personal data needed to identify you such as your name, company name, and your contact details, such as your email address and telephone number. |
To allow you to use the functions available on our website, such as to enable you to log-into and to use our data room. |
Legitimate business purposes. |
| To send you email notifications and/or newsletters. |
Where you consent/ legitimate business purposes. |
| To deal with enquiries and complaints made by or about you. |
Legitimate business purposes. |
| Technical information about your computer and about your visits to our website and documents viewed (including your IP address, geographical location, browser type, referral source, length of visit, number of page views, the links opened, the content accessed); social media views; and whether you have opened our emails and links selected. |
To administer and improve our website, to ensure it is presented in the most effective manner for you, to give you the best website experience and to better understand the products and services you may be interested in. This includes the use of Google Analytics and other similar tools to analyse the performance of our website, including how many visitors we have, how long they stay on our website and how many pages they visit. |
Legitimate business purposes |
| For data analysis, testing, research and statistical purposes to help us to improve our products and services. |
Legitimate business purposes |
| To keep our website safe and secure. |
Legitimate business purposes |
| To make suggestions and recommendations to you and other users of our website about products or services that may interest you or them. |
Legitimate business purposes |
| To measure or understand the effectiveness of marketing materials we serve to you and others, and to deliver relevant messaging to you. |
Legitimate business purposes |
You do not have to give us any of the personal data set out in the table above but, if you do not provide us with certain information, you may not be able to use all functions on our website, and we may not be able to provide you with the products or services you have requested or deal properly with any enquiries or complaints raised by you.
