This Policy (and any documents referred to in it) sets out the basis on which we process data about individuals including individuals at potential and current investors, individuals at potential and current portfolio companies and visitors to the www.fullcircle.capital website (the “Website”).
Full Circle Capital reserves the right to make amendments to this Policy from time to time. Any changes to this Policy will be posted on this page. Please check back frequently to see any updates or changes to this Policy.
Who is responsible for your data
This Policy applies to the personal data that Full Circle Capital collects and uses.
References in this Policy to “Full Circle Capital” mean Full Circle Capital Limited, a company registered in England and Wales with registration no 11630210 and registered office at Palladium House, 1-4 Argyll Street, London, England, W1F 7LD. We control the ways your personal data are collected and the purposes for which your personal data are used by us. Full Circle Capital is the “data controller” for the purposes of the UK Data Protection Act 2018, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) (each as amended or replaced) and other applicable European data protection legislation (together the “Data Protection Legislation”).
Personal data we collect about you
When using the term “personal data” in this Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your personal data may include, for example, your name, your contact details and the name of the company you work for.
How we collect data about you
We gather data about individuals during the course of our dealings with you (including, but not limited to, by email and via this Website).
The types of personal data we collect
Many of the services offered by Full Circle Capital require us to obtain personal data about you in order to perform the services we have been engaged to provide. In relation to each of the services, we will collect and process the following personal data about you.
Information that you provide to Full Circle Capital
This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of personal data we might ask for, though such information may include (by way of a non-exhaustive list):
· basic personal data (such as first name, family name, position in the company, company name, company email address, business phone number, business address, city, postcode and country); and
· any information that you choose to share with us (whether through our Website or otherwise) which may be considered personal data.
Information that we collect or generate about you
This includes (by way of a non-exhaustive list):
· information about our services which you have purchased and our interactions with you; and
· when you visit our Website, cookies are used to collect technical information about the services that you use, and how you use them.
Information we obtain from other sources
· we may be supplied with CVs of prospective candidates for roles at Full Circle Capital; and
· we may from time to time use third party public and private data sources to find out more information about an individual’s employment history.
In addition to the categories of personal data described above, Full Circle Capital may also process further anonymized information and data that is not processed by reference to a specific individual.
How we use your information
Your personal data may be stored and processed by us in the following ways and for the following purposes:
· for ongoing review and improvement of the information provided on or operation and security of our Website;
· to assess your application for our services, where applicable;
· to set you up as a customer;
· to provide you with our services;
· to understand feedback on our services and to help provide more information on the use of those products and services quickly and easily;
· to communicate with you in order to provide you with services or information about Full Circle Capital and our products and services;
· to understand your needs and interests;
· for the management and administration of our business;
· in order to comply with, and in order to assess compliance with, applicable laws, rules and regulations, and internal policies and procedures;
· for the administration and maintenance of databases storing personal data; and
· we may process business communications traffic data sent and received by us for the purposes of evaluating our existing or prospective business relationship.
However we use personal data, we make sure that the usage complies with law and the law allows us and requires us to use personal data for a variety of reasons. These include where:
· we need to do so in order to perform our contractual obligations with our customers;
· we have obtained your consent;
· we have legal and regulatory obligations that we have to discharge;
· we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
· the use of your personal data as described is necessary for our legitimate business interests, such as:
o allowing us effectively and efficiently to manage and administer the operation of our business;
o conducting market research or business analysis;
o maintaining compliance with internal policies and procedures; and
o promoting our business.
Special categories of data
Full Circle Capital does not collect any “special categories of data” that could reveal information such as racial or ethnic origin, sexual orientation, political opinions physical or mental health, religious or philosophical beliefs, trade union membership or genetic or biometric data).
Disclosure of your personal information
We may disclose your personal data, in various ways and for various reasons, with the following categories of people:
· tax, audit or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
· we may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and/or its subsidiaries;
· a third party who acquires us or substantially all of our assets or is likely to acquire us or substantially all of our assets;
· third party service providers who perform functions on our behalf (including professional advisors such as lawyers, auditors, accountants, technical support functions, anti-money laundering support and IT consultants carrying out testing and development work on our business technology systems); and
· our cloud-based storage provider and other IT systems for storage purposes.
Transferring your information internationally
Full Circle Capital may need to transfer your information globally. We want to make sure your information is stored and transferred in a way which is secure. We will therefore only transfer data outside for the European Economic Area (“EEA”) (i.e. the member states of the European Union, together with Norway, Ireland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
· by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection laws;
· by signing up to the EU-US Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the USA or any equivalent agreement in respect of other jurisdictions; or
· transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation;
· where it is necessary for the conclusion or performance of a contract between you and us or the implementation of pre-contractual measures taken at your request; or
· where you have consented to the proposed transfer, after having been informed of the possible risks of such transfers.
Retaining/deleting your information
We only keep your information for as long as it is necessary to fulfil the purpose for which it was collected.
We use the following criteria to determine how long we need to keep your data:
· whether the purpose has been fulfilled, e.g. you are no longer a customer or interested in our products;
· to comply with company record keeping obligations including keeping of accounting records;
· to represent our interactions with you in the event that a complaint is made against us; and
· whether we consider the data may need to be retained for legal or regulatory purposes.
We will use technical and organisational measures to safeguard your information.
Some parts of our Website may use a “cookie”, which is a small text file that is placed on your computer’s hard drive. The cookie collects standard internet log information and visitor behaviour information. Our Website may use a cookie to log which pages you visit or to provide you with enhanced capabilities during your visit. You can set your browser to refuse to accept cookies; however, if you choose to do this, some features of our Website (and others) may not function properly.
Third party properties
Our platform and Website may contain links to and from the online properties of third parties. If you follow a link to any of these online properties, please note that these online properties have their own privacy policies and that we cannot and do not accept any responsibility or liability for these policies or for any personal data that may be collected through these online properties. Please check these policies carefully before you click on any links and/or submit any personal data to these online properties.
You have the following rights in relation to your information:
Right to request a copy of your information. You can request a copy of your information which we hold (this is known as a subject access request).
Right to correct any mistakes in your information. You can require us to correct any mistakes in your information which we hold.
Right to request we stop processing your information. In certain circumstances, you may request that we cease processing your information.
Right to request deletion of your information. You can ask us to erase your information (also known as the “right to be forgotten”) in certain circumstances.
Right of data portability. You have the right to transfer your personal data between data controllers in certain circumstances.
If you would like to request any of the above, please contact us at firstname.lastname@example.org to make any such requests. We will comply with the Data Protection Legislation in responding to any such requests.
Right to lodge a complaint
If you have any complaints about the way in which we collect, store and use your information, you can contact the supervisory authority in the United Kingdom, the Information Commissioner’s Office: https://ico.org.uk/concerns.