(i) when you visit or use the website at www.mobeusequity.co.uk (the “Website” or “Site”); and/or
(ii) when you contact us (by email or telephone or in person), for example to request our news and updates or to submit a query or comment regarding the Website or its content.
Please read the following carefully to understand our practices regarding personal data and how we will treat it.
For the purposes of laws regarding data protection, the data controller is Mobeus, a limited liability partnership registered in England and Wales with registered number OC320577 and registered office address at 52 Jermyn Street, London, SW1 6LX.
1. Personal data we collect
2. How we use personal data
4. Disclosure of personal data
5. External Links
6. Social Media Platforms
7. Where we store personal data
8. Changes of Business Ownership and Control
10. Your rights
11. Changes to this policy
We collect and process the following personal data relating to you:
- your name, contact details and other information contained in communications you send to us or that you provide to us when you contact us (by email or telephone or in person), for example to request our news and updates or to submit a query or comment regarding the Website or its content or to apply for a job;
- data collected by us in our capacity as an investment manager, investment adviser, administrator, company secretary and promoter. This may include data collected in connection with the business of making investments, for example personal due diligence checks (which may include references and credit checks), or in connection with fundraising activities; and
- data from surveys that we may, from time to time, conduct with our suppliers for research purposes, if you choose to respond to, or participate in, them.
We use personal data relating to you that we collect, or that you provide to us, for the purposes of our legitimate interests as follows:
- to respond to your queries;
- to provide you with information, products or services that you request from us or which we feel may interest you, where you have expressly consented to be contacted for such purposes (please see paragraph entitled “Marketing” for further information);
- to undertake due diligence and manage investments in our capacity as an investment manager and investment adviser;
- in connection with fundraising activities for the Mobeus-advised Venture Capital Trusts, where we act as promoter, investment adviser, administrator and company secretary, and our Institutional Funds;
- to ensure that content from the Website is presented in the most effective manner for you and for your computer;
- to prepare anonymised data sets;
- to notify you about changes to the Website and the materials on the Website;
- as part of our efforts to keep the Website safe and secure; and
- for any other purposes that you would reasonably expect.
We will only send you marketing material electronically if you consent.
When we send you marketing material, we may monitor whether or not you open and/or click on the material that we send you.
If you have consented to receive marketing material from us, you have the right at any time to ask us not to process personal data relating to you for marketing purposes. If you wish to exercise this right, please contact us.
We may disclose personal data relating to you to third parties in certain circumstances including (but not limited to) the following:
- our third party service providers, such as those we engage to host and maintain the Website, our IT systems and to assist us with marketing campaigns;
- analytics and search engine service providers that assist us in the improvement and optimisation of this Website;
- to the extent that it is connected with investment activity, with due diligence providers, prospective or actual investee companies and co-investors;
- law enforcement bodies, Courts of law or as otherwise required or authorised by law; and
- regulatory, trade association or government bodies for the purposes of resolving complaints or disputes both internally and externally or to comply with any investigation by one of those bodies.
Before we disclose personal data to a third party, we take steps to ensure that the third party will protect personal data in accordance with applicable privacy laws and in a manner consistent with this policy. Third parties are required to restrict their use of this personal data to the purpose for which the data was provided.
Although the Website only looks to include safe and relevant external links, users should always adopt a policy of caution before clicking any external web links mentioned throughout the Website.
The Website may, from time to time, contain links to and from the websites of our partner networks. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Communication, engagement and actions taken through external social media platforms which Mobeus attends are subject to the terms and conditions as well as the privacy policies of those social media platforms.
This Website may use social sharing buttons which help share web content directly from our web pages to the social media platform in question. Where you use such social sharing buttons you do so at your own discretion. You should note that the social media platform may track and save your request to share a web page respectively through your social media platform account. Please note these social media platforms have their own privacy policies, and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these social media platforms.
If you live in the EU, the personal data relating to you that we collect may be transferred to, and stored at, locations outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers.
Countries where personal data relating to you may be stored and/or processed, or where recipients of personal data relating to you may be located, may have data protection laws which differ to the data protection laws in your country of residence. By submitting your personal data, you accept that personal data relating to you may be transferred, stored or processed in this way. We will take all steps reasonably necessary to ensure that the recipients of your data will treat that data securely and in accordance with this policy.
Unfortunately, the transmission of information and data via the internet is not completely secure. Although we will do our best to protect personal data relating to you, we cannot guarantee the security of such data transmitted to the Website; any transmission is at your own risk. Once we have received personal data relating to you, we use strict procedures and security features to try to prevent unauthorised access.
The security of personal data regarding you is a high priority. We take such steps as are reasonable to securely store personal data regarding you so that it is protected from unauthorised use or access, misuse, loss, modification or unauthorised disclosure. This includes both physical and electronic security measures. Examples include the use of passwords, locked storage cabinets and secured storage rooms. Other features include:
- storing information on secured networks consistent with industry standards, which are only accessible by those employees who have special access rights to such systems;
- using industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology;
- restrictions are placed on the electronic transfer of files; and
- our IT networks undergo necessary vulnerability testing to continually identify and remediate potential opportunities for unauthorised data access.
We take steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required by law to retain the information.
Data protection laws give you the right to access personal data held relating to you. To protect your privacy, we may take steps to verify your identity before taking any action in response to any request. Any access request may be subject to a fee to meet our costs in providing you with details of the personal data that we hold relating to you.
We also want to make sure that any personal data relating to you that we hold is accurate and up to date. You may ask us to correct or remove any personal data you think is inaccurate.
You also have the right, in certain circumstances, to:
- the erasure of personal data relating to you that we hold;
- the restriction of processing of personal data relating to you that we hold; and
- object to our processing of personal data relating to you that we hold.
If you would like to exercise any of these rights or if you have any questions about our processing of personal data relating to you, please contact us.
We will respect and provide you with all rights in relation to personal data relating to you that we hold, and to which you are entitled, under applicable law.
If you have a concern about the way we are collecting or using personal data relating to you, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/.
You can contact us by emailing us at firstname.lastname@example.org or writing to us or telephoning us at:
Mobeus Equity Partners LLP
Tel: 020 7024 7600
Last updated: April 2018