Circadia Ventures LLP website privacy policy statement
Information
Circadia Ventures LLP LLP is committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms of Use) describes how we collect, use and otherwise process personal data relating to you, or that you provide to us:
(i) when you visit or use the website at www.circadiaventures.com (the "Website" or "Site"); and/or
(ii) when you contact us (by email or telephone or in person), for example to submit a query or comment regarding the Website or its content.
Circadia Ventures LLP acts as a data controller and processor. The Firm Limited is referred to as "firm, the firm, we", "us" or "our" in this privacy policy statement.
Contact Details
Circadia Ventures LLP, 5 Marble Arch, London, W1H 7EJ, Company registration number: OC317841
Contact details for the purpose of this privacy policy statement and the person responsible for data protection and privacy for the firm is Compliance contact: Email: david.atkinson@circadiaventures.com
The firm's ICO reference number is: ZA361006.
In this Privacy Policy, the terms "personal data", "processing", "data controller" and "data processor" shall have the meaning ascribed to them in the General Data Protection Regulation ((EU) 2016/679).
The personal data we may collect about you
Where we collect data that identifies an individual this is classed as "personal data". Personal data may include (but is not limited to):
- 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. 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).
The above list is not exhaustive and we may from time to time require additional information in order Internal Use Only to satisfy our legal and regulatory obligations. Where additional information is required we will provide you with a reasonable explanation of why it is required unless we are prevented from doing so by law.
The firm may use methods such as pseudonymisation which is a process whereby the firm can replace identifying fields of data with other non-identifying data fields in order to anonymise the data from the individual therefore meaning the data is no longer personal. The firm may use this method where we are required to retain certain types of information for clients, such as number of females and males employed, jobs created and average salaries paid. This type of statistical data is often required for ESG (Environmental, social and governance) investment purposes by clients to show value added investments made by the firm on behalf of its clients.
Use of this website
We do not employ cookies on this website or collect personal data automatically when you use the Website and when you navigate through the Website.
Special Category Data
Special Category data refers to any data which is sensitive and is subject to additional rules and requirements under the General Data Protection Regulations. Special category data may include information regarding: Criminal convictions and offences, race, ethnicity, religious or philosophical beliefs, political opinions, sexual orientation, trade union membership and information about your health, genetic and biometric data.
As a general rule we do not collect any Special Category Data about you. However, we are required to request information relating to criminal convictions as part of our recruitment process for staff and contractors undertaking regulated activities and as such we require consent from the individual for this. If we are required by law to request any special category data from you, aside from the reasons mentioned above we will provide you with a reasonable explanation as to the nature and purpose for this request and obtain your consent. We would not be able to proceed without your consent unless there was a lawful reason for doing so.
How do we collect your personal data?
Typically, where we are required to obtain your personal data we will request it from you. However, we may also from time to time receive your personal data through intermediaries where you have authorised the sharing of your personal data with us. Intermediaries may include Accountants, Solicitors, Independent financial advisors, Tax advisors and wealth managers who may be working on your behalf. Personal data may be provided to us via post, in person, email or via a specially created secure data room /platform. The data collection may be facilitated by way of completing an application form or questionnaire or by responding to information requests from us. We may also receive information from publicly available resources.
Why do we collect your personal data?
We only collect your personal data where we believe we have a legitimate business interest with you Internal Use Only or we have a lawful purpose to do so. These reasons may include but may not be limited to circumstances such as:
- You have requested a response to a query, for example an investment proposal you may have sent us;
- You are a shareholder in one of the companies to whom we have an administration and / or management agreement with;
- You are a Limited Partner or an investor in one of the funds to which we are appointed manager / operator;
- We are undertaking due diligence and manage investments in our capacity as an investment manager;
- You consent to receiving communications from us;
- You have a contractual agreement with us ;
- You wish to give us feedback or some other form or legitimate business interest with you;
- Our efforts to keep the Website safe and secure, and
- For any other purposes that you would reasonably expect.
How and why do we use your personal data
Typically, we only use your data to be able to perform our duties under contracts we may have with you or where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Generally, we do not rely on consent as a legal ground for processing your personal data.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at david.atkinson@circadiaventures.com if you need details about the specific legal ground we are relying on to process your personal data
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.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal grounds for this.
We may process your personal data without your knowledge or consent only where this is required and permitted by law.
Sharing and Disclosure of your personal data
We may share your personal data with the parties set out below for legitimate business interests and lawful purposes, these may include but are not limited to:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors, tax advisors and insurers who provide consultancy, banking, legal, insurance, tax and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances which may include but is not limited to The Financial Conduct Authority.
- Fraud prevention agencies,
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
External Links
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.
International Transfers
We do not share or transfer your data outside of the European Economic Area (EEA)
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Please email david.atkinson@circadiaventures.com if you like further information regarding international transfers or the ICO (information commissioner's office)
The Security of your Data
The security of personal data regarding you is a high priority. We have put in place adequate, proportionate and appropriate security measures as is required of an authorised firm to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 Internal Use Only accessible by those employees who have special access rights to such systems;
- our IT networks undergo necessary vulnerability testing to continually identify and remediate potential opportunities for unauthorised data access.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with data breaches in accordance with the GDPR (General Data protection regulation) and we will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention periods
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory. accounting, or reporting requirements
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years for tax purposes and for at least five years after a client ceases to be a client under the UK money laundering regulations 2017.
In some circumstances we may pseudonymise your personal data for statistical purposes in which case we may use this information indefinitely without further notice to you.
GDPR personal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data (Subject access request).
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
For further information visit or if you wish to exercise any of the rights set out above, please email us Internal Use Only at david.atkinson@circadiaventures.com.
You will not have to pay a fee to access your personal data (or to exercise any of your rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. In order to respond to a subject access request, we will need to confirm your identity as a security measure to safeguard you from your personal data from being disclosed to non-authorised third parties. Please provide us with as much information as possible to enable us to comply with your request within an acceptable time-frame. We are required to respond to subject access requests where practically possible within 30 days and if this is not possible we will provide you with a reasonable explanation as to why this cannot be achieved.
Complaints and queries
If you are not happy with any aspect of how we collect and use your data, please contact david.atkinson@circadiaventures.com and we will do our best to resolve your issue. You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
Accurate Data
We will make all reasonable efforts to ensure the data we hold on you is accurate and up to date and to correct any inaccuracies that we become aware of. Please help us to comply with our obligations by letting us know of any changes in relation to the data we hold about you as It is very important that the information we hold about you is accurate and up to date. Please email david.atkinson@circadiaventures.com with any required updates or amendments.