This is the data protection and privacy policy of Cambridge Innovation Capital Limited and its subsidiaries, being Cambridge Innovation Capital Manager Limited and any future subsidiaries of either party, (we, us and our) and explains who we are, why and how we process your personal information (also referred to here as personal data), your rights and how to contact us if you need to.
Our contact details are set out at the end of this policy. We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).
This policy (together with our Cookies Policy and any other documents referred to within them) sets out:
Information we collect about you and how we will use it
Cookies and other technologies
Our promotional updates and communications
Who we share your information with
Where we store your information
How we protect your information
How long we keep your information
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We may process your personal data if:
In relation to the latter, please also see our Privacy Notice for Applicants.
We may process your personal data that we have either obtained from you or obtained from somewhere else. Personal data which is not collected directly from you may be collected:
The information we collect depends on the context of our interactions with you. We will only use your personal data where we have a valid lawful basis to do so.
| Why are we processing information about you? | What information will we collect about you? | How will we collect information about you? | What is our legal basis for processing information about you? |
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Individual shareholders/limited partners and employees of our shareholders/limited partners |
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| To administer, operate, facilitate and manage your/your employer’s relationship and/or account with us
To communicate with you regarding the investments managed by CIC To administer payments to and from you To execute transactions To meet our regulatory and legal obligations |
Contact information (name, address, email address, telephone number etc)
Financial information |
Provided by you/your employer when you/they contact us | To enable us to pursue our legitimate interest to operate our business and to meet our regulatory and legal obligations |
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Employees and shareholders of companies we invest in or consider investing in |
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| To administer, operate, facilitate and manage your/your employer’s relationship and/or account with us
To evaluate potential investment opportunities To execute transactions To communicate with you regarding CIC’s investment and the status of your/your employer’s business To meet our regulatory and legal obligations |
Contact information (name, address, email address, telephone number etc)
Financial information |
Provided by you/your employer when you/they contact us
Collected by us in the course of our business |
To enable us to pursue our legitimate interest to operate our business and to meet our regulatory and legal obligations |
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Suppliers, advisors and experts (including our Advisory Panel) |
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| To maintain details of preferred partners (including suppliers, advisers and experts)
To instruct the services of a partner (including suppliers, advisers and experts) To communicate with you To arrange payment to you/your employer |
Identity information
Contact information (name, address, email address, telephone number etc) Financial information Other relevant information including:
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Provided by you when you introduce yourself to us for future work
Provided by other professionals, agencies or other bodies when they recommend you to us or give us references Provided by you when we instruct you to provide a service Collected by us in the course of our business (including information collected by us from publicly available information about you or your organisation) |
Necessary for the performance of a contract with you
To enable us to pursue our legitimate interest to operate our business |
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Event attendees |
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| To enable us to host a meeting, seminar or other event
To communicate with you To send you follow up information (if you agree) |
Identity information
Contact information (name, address, email address, telephone number, your company/position etc) |
Provided by you when you:
Received from third parties (including when they refer you to us) |
To enable us to pursue our legitimate interest to arrange and run such meetings, seminars and other events, and to promote our business |
| Information about your dietary requirements and allergies | Provided by you | Your consent
To enable us to pursue our legitimate interest to provide catering at meetings, seminars or other events |
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Website Users |
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| To administer our site and manage its operation, including troubleshooting, data analysis, testing, research, statistical and survey purposes
To ensure that the content on our website is presented in the most effective manner for you and for your device To allow you to participate in interactive features of our website For our internal operations, including analysis of the traffic to our website To protect the security of our website |
Device and usage data (including IP addresses, browser type and version, time zone setting, browser plug-in types and versions, domain names, referring website addresses and device identifiers)
Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time) Device event information (including crash logs, hardware settings, browser type and browser language) Location information |
Automatically collected by cookies and stored in our server logs when you interact with our website
For further information see our cookie policy |
Your consent
To enable us to pursue our legitimate interest to present our website in the most effective way |
| To enable you to use the ‘Investors’ area of our website (applicable to investors only)
To protect the security of our website |
Your log-in details to access the ‘Investors’ area of our website | Generated by us or provided by you | To enable us to pursue our legitimate interest to protect the security of, and manage access to, our website |
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Marketing and business development |
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| To send you marketing communications, newsletters, information about company, services, funds, events and industry updates that may be of interest to you
To keep records and maintain contacts in order to grow our business |
Identity information
Contact information Your areas of interest (where provided by you) Your interactions with us (including meetings and discussions, and events attended) |
Provided by you when you:
Received from third parties (including when they refer you to us) Collected by us in the course of our interactions with you |
To enable us to pursue our legitimate interest to maintain contacts and to grow our business |
| To assess the effectiveness of our marketing campaigns | Your interactions with our marketing materials (for example, whether you opened a marketing email and when) | Collected by us (or on our behalf by our third party marketing agencies) through the use of tracking codes | To enable us to pursue our legitimate interest to assess the effectiveness of our marketing campaigns and to grow our business |
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General enquiries, requests for information and complaints |
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| To deal with enquiries, recommendations, references, correspondence or complaints (whether you are communicating with us by phone, by email, via our website, via social media or otherwise) | Identity information
Contact information (name, address, email address, telephone number etc) Who you work for, and your job function or department Any other personal information you provide to us relevant to the enquiry or issue raised |
Collected by us in the course of dealing with enquiries or other requests made by you or the organisation you represent including:
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To enable us to pursue our legitimate interests to provide requested information or to deal with complaints |
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Our use of cookies and other similar technologies to process personal data is explained in our cookie policy, which you should please read.
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information to provide you with marketing communications that may be of interest to you (including, for example, promotional materials and newsletters).
We may include tracking codes in our marketing materials, to enable us to assess the effectiveness of our marketing campaigns and their relevance to you.
You can object to further marketing at any time by selecting the “unsubscribe” link at the end of any marketing message sent to you.
You can also request that we send marketing material to a non-personal email address instead of one which identifies you as an individual.
We may share your personal data with:
We may also disclose your personal information to third parties:
to protect the rights, property, or safety of Cambridge Innovation Capital, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
The data that we process in relation to you may be transferred to, and stored at, a destination outside the United Kingdom or European Economic Area (“EEA”) that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the United Kingdom or EEA who work for us or for one of our suppliers.
We may transfer your personal information outside the United Kingdom or EEA:
Where your information is transferred outside the United Kingdom or EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on applicable approved standard contractual clauses which give personal information the same protection it has in the United Kingdom or EEA, and that it is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our website may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
We retain personal data for as long as you as is necessary to fulfil the purposes for which we collected it. We may keep your personal information for a certain period after your relationship with us has ended. For us to establish the retention period for your personal information, we will take account of our legal obligations, the expectations of financial and data protection regulators, and the amount of time we may strictly need to hold your personal information to carry on our business or defend our rights.
We may retain aggregated and anonymised information indefinitely for research purposes and to help us develop and improve our services. You cannot be identified from such information.
You have the right under certain circumstances:
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us using the details below. Once we know that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so.
You can also exercise the rights listed above at any time by contacting us at enquiries@cic.vc.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see https://ico.org.uk/). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Any changes we make to our privacy policy in future will be posted on our website at cic.vc and, in relation to substantive changes, will be notified to you by email (if we hold your email address). This policy was last updated in December 2019.
22 Station Road, Cambridge, CB1 2JD
+44 (0)1223 856593
enquiries@cic.vc