LAST UPDATED: 22 August 2019
- IMPORTANT INFORMATION
- OUR SERVICES
- HOW WE PROCESS AND USE YOUR DATA
- Portfolio companies
- HOW IS YOUR PERSONAL DATA COLLECTED
- DISCLOSURES OF YOUR PERSONAL DATA
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- CONTACT DETAILS
1 – Important information
Seedcamp Investment Management LLP is a limited liability partnership incorporated in England and Wales with registered number OC391626 as authorised and regulated by the Financial Conduct Authority with FCA number 628313 (“Seedcamp”). As the controller of your personal data, Seedcamp is therefore responsible for any collection, processing, use and disclosure that may be carried out in relation to your personal data.
Duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2 – Our services
Seedcamp is an early stage investment firm. In order to provide our services, we may collect personal data through a number of sources. Please see the ‘How is your personal data collected’ section for more information.
Where we need to collect personal data by law, or under the terms of a contract we have (or are negotiating) with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel all or part of the services you have with us, but we will notify you if this is the case at the time.
Our website and services are intended for adults only. We do not knowingly collect, use, process, or disclose personal data relating to children.
3 – How we process and use your data
“Personal data” is information that identifies you as an individual or relates to an identifiable individual.
We have set out below a description of the ways we plan to use your personal data, and on which legal basis we do so. Where we rely on our legitimate interests as a legal basis for processing, we have identified the nature of those legitimate interests.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., national insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise.
4 – How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- request for our products or services;
- complete an online submission form;
- request marketing to be sent to you;
- employment applications;
- submitting funding applications and any related materials including slide decks, presentations and web submissions;
- give us some feedback;
- use of our website (seedcamp.com); or
- use of our social media pages including Twitter (twitter.com/seedcamp), Facebook (www.facebook.com/seedcamp), LinkedIn (www.linkedin.com/company/seedcamp_2/), Angel List (www.angel.co/seedcamp/) and SoundCloud (www.soundcloud.com/seedcamp).
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. This information does not reveal your specific identity. We collect this personal data by using server logs and other similar technologies such as IP address identification and logging.
- Third parties or publicly available sources. We may receive personal data about you from various third parties including analytics providers, advertising networks and search information providers. We require third parties to have lawful rights to collect, use and share your data before providing any data to us.
- Identity data from data brokers or aggregators.
- Public sources. Identity data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details provided in the “Contact Details” section.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5 – Disclosures of your personal data
We may disclose personal data to third party service providers (including IT system administrators, professional advisers, providers of finance, HM Revenue & Customs, regulators and other authorities) to facilitate services they provide to us. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In such circumstances, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6 – International transfers
Seedcamp is based in the European Economic Area (“EEA”). If we transfer personal data to our group or affiliate entities or to third parties outside of the EEA, we will ensure your personal data is protected, for example by ensuring one or more of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Standard contractual clauses approved by the European Commission are in place with the transferee.
- Where we transfer personal data to service providers or affiliates based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us using the contact details provided in the “Contact Details” section if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7 – Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. 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 any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We cannot guarantee the security of any personal data that you disclose online, for example when it is sent by email. You accept the inherent security risks of providing information online over the internet and will not hold Seedcamp responsible for any breach of security unless this is due to Seedcamp’s negligence or willful default.
8 – Data retention
How long will you use my personal data for?
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, 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.
You can request details of retention periods for specific categories of your personal data by contacting us using the details provided in the “Contact Details” section.
9 – Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Such rights include your right to:
- request access to your personal data;
- 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; and
- right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us using the details provided in the “Contact Details” section.
We give you choices regarding our use and disclosure of your personal data for marketing purposes. You may opt-out from receiving electronic communications from us by following the ‘Unsubscribe’ link provided at the footer of any marketing materials that you may have received from Seedcamp by email or by contacting us using the details provided in the “Contact Details” section.
You have the right to lodge a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we would encourage you to contact us in the first instance.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10 – Contact Details
There may be instances where will request additional information in order to identify you and assess your request. If you do not provide the requested information and, as a result we are not in a position to identify you, we may refuse to action your request.
We will not charge you for such communications or actions we take, unless:
- you request additional copies of your Personal Information undergoing processing, in which case we may charge for our reasonable administrative costs, or
- you submit excessive requests, in which case we may either: (a) charge for our reasonable administrative costs; or (b) refuse to act on the request.
We may be contacted at: Seedcamp Investment Management LLP 4-5 Bonhill Street Shoreditch London England EC2A 4BX
PLEASE NOTE: Seedcamp uses firstname.lastname@example.org solely for privacy related matters. All unrelated matters sent to this email address (e.g. unsolicited requests for funding) will not be considered or responded to.