This is the data protection and privacy policy of Cambridge Innovation Capital plc 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

Change of purpose

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

Your rights

Changes to this policy

Contact us

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Information we collect about you and how we will use it

We may process your personal data if:

  • you or the company you work for are:
    • enquiring about;
    • are in the process of; or
    • have already secured capital or other support from us;
  • you or the company you work for have invested in Cambridge Innovation Capital and/or one of the funds we manage;
  • you are a member of our Advisory Panel;
  • you or the company you work for supply goods or services to us;
  • you have attended, or signed up to attend, one of our events;
  • you are a business contact or professional advisor (such as a lawyer or accountant) who interacts with our business;
  • you submit an enquiry via our website or via social media; or
  • you provide us with your CV or submit any other information in relation to a potential role with us or our portfolio, or potential portfolio, companies.

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:

  • from your organisation in connection with your role and how it relates to us; or
  • from third parties we work closely with including, for example, the University of Cambridge, Cambridge Enterprise, our shareholders, other potential investors and professional advisers such as lawyers and accountants. 

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?

Individual shareholders and employees of our shareholders

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

Employees and shareholders of companies we invest in or consider investing in

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

Suppliers, advisors and experts (including our Advisory Panel)

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:

  • nature of the services provided or area of expertise
  • professional qualifications
  • details of previous services provided/your cv
  • other information you provide to us regarding your personal or business interests

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

Event attendees

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:

  • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person);
  • sign up for or attend one of our events or meet us at external events or provide us with your business card;

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

Website Users

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 

Marketing and business development

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:

  • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person);
  • sign up for or attend one of our events or meet us at external events or provide us with your business card; or
  • otherwise introduce yourself to us

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

General enquiries, requests for information and complaints

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:

  • information provided by you when you:
    • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person)
    • complete an online enquiry form via our website
    • sign up for or attend one of our events or meet us at external events or provide us with your business card;
  • information received from third parties (including when they refer you to us)
  • information collected by us in the course of operating our business (including information collected by us from publicly available information about you or your organisation)
  • information provided by you regarding a recommendation, referral or reference

To enable us to pursue our legitimate interests to provide requested information or to deal with complaints

Change of purpose

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.

Cookies and other technologies

Our use of cookies and other similar technologies to process personal data is explained in our cookie policy, which you should please read.

Our marketing updates and communications

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.

Who we share your information with

We may share your personal data with:

  • any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries if we have a legitimate interest in doing so;
  • appropriate third parties including:
    • our business partners, customers and suppliers  for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
    • our website and Cloud hosting providers;
    • marketing agencies, for the purposes of managing our communications with you and promoting our business;
    • our auditors, legal advisors and other professional advisors or service providers; and
  • (in relation to information obtained via our website) analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.

We may also disclose your personal information to third parties:

  • in the context of the possible sale or restructuring of our business, or any part of it;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce agreements with you or the company you work for; or

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.

Where we store your information

The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.

We may transfer your personal information outside the EEA:

  • in order to enable us to provide investment services and fulfil our contract with you or the company your work for. This includes order fulfilment, processing of payment details, and the provision of support services;
  • where we are legally required to do so; or
  • in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.

How we protect your information

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.

How long we keep your information

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.

Your rights

You have the right under certain circumstances:

  • to be provided with a copy of your personal data held by us;
  • to request the rectification or erasure of your personal data held by us;
  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  • to object to the further processing of your personal data, including the right to object to marketing sent by us; and
  • to request the transfer of your personal data to a third party.

Your right to withdraw consent

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.

How to exercise your rights

You can also exercise the rights listed above at any time by contacting us at enquiries@cicplc.co.uk.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/ index_en.html). 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.

Changes to this policy

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.

Contact us

Our full details are:

Cambridge Innovation Capital
Hauser Forum
3 Charles Babbage Road
Cambridge
CB3 0GT

+44 (0) 1223 764875

enquiries@cic.vc