In this policy when we refer to “personal data” we mean information that could directly identify you (for example your name or national insurance number) and information that could indirectly identify you when combined with other information that we hold on you such as gender or date of birth. Process or processing means just about any conceivable use of personal data including recording, storing, viewing or disclosing such data.
Longwall Venture Partners LLP (registered number OC362933) is the data controller of your personal data (referred to here as “Longwall”, “us” or “we”).
If you have any queries about this policy or about your personal data which are not answered by this policy please contact our data protection officer either by email or by post as follows:
Post: Data Protection Officer, Longwall Venture Partners LLP, Quad One, Becquerel Avenue, Harwell Oxfordshire OX11 0RA.
How we collect your data
The way we collect your data can broadly be categorised as follows:
– Information you provide to us directly
When you visit our website or approach us for funding or as a potential investor or you approach us for a job, we may ask you to provide personal data to us. For example as a potential investor we will need to be sure that you are an eligible investor for our funds, so as well as contact information and information for our legal obligations under the Money Laundering Regulations 2017, we may also ask you to provide information on your income and investment experience. If you have a funding proposal for us, in the first instance we will require your contact information and if we decide to pursue the opportunity we will require information on your employment history, references and information on your financial circumstances. If you do not want to provide us with this personal data you do not have to, but it may mean that you will not be able to receive information on our investment funds or be able to progress your funding request.
– Information we get automatically
We collect some information automatically about you when you visit our website, this may include your IP address or type of device. We may also collect information as you navigate through our website, such as what pages you looked at and what links you clicked on. Some of this may be collected using cookies and tracking technology. This is useful for tracking the number of visitors to our website and understanding how they use the site. This information will not be used for any other purpose.
– Information we get from third parties
In general our information will come directly from you. However in some cases we may use a third party to provide us with further details such as publicly available information. This will be used purely to supplement the personal data we already hold about you and to validate the personal information that you have provided.
How we use your data
Where we collect personal data we will only process it:
Where we collect personal data we will only process it:
- To perform a contract with you (ie to enable an investment in our fund or for our fund to invest in your business);
- In accordance with a legal obligation (such as our obligations under the Money Laundering Regulations 2017); or
- Where we have your specific consent (which you have the right to withdraw at any time).
We do not pass on any of your information to marketing agencies or operate any mailing lists, other than those used to fulfil our contractual obligations to you. We will only use your data to fulfil one of the three criteria noted above.
How we share your data
In very limited circumstances we may need to share your data with third parties. We will only disclose your data to the following groups of people:
- Third party service providers – such as our legal representatives, external software or hosting providers or external identification verification agents, who assist us in providing our fund management services to you
- Regulators, law enforcement agencies, government bodies, courts or other third parties where we believe that it is necessary to comply with applicable laws or regulations or to exercise, establish or defend our legal rights. Where possible and appropriate we will notify you of this type of disclosure, although this may not always be possible
- Other people where we have your specific consent.
International data transfers
When we share data it may be transferred to and processed in countries other than the United Kingdom and in some cases outside the EEA – such as the United States where a number of data hosting providers are located. If this happens we take steps to ensure that the country in question has adequate protection for your data or the third party we use has approved measures in place to protect your personal data, such as signing up to European Commission approved standard contractual arrangements or in the case of US based service providers, ensuring they have signed up to the EU-US Privacy Shield.
We are committed to providing a safe and secure environment for the storage of your data. We have implemented appropriate technical and organisational measures to protect the confidentiality of the personal data that you entrust to us. We update our physical and procedural security controls on an ongoing basis including limiting access to your personal data to those who need it and training our employees about the importance of maintaining the privacy and security of your personal data.
We will only store your data for as long as is necessary to fulfil the purposes outlined in this policy or for as long as we reasonably consider necessary to establish, exercise or defend our legal rights. In the first instance your data will be retained in line with statutory and regulatory requirements as follows:
- To comply with our obligations under the Money Laundering Regulations 2017
- To comply with the regulatory requirements imposed on us by the Financial Conduct Authority
- To comply with statutory retention periods for accounting records as set out by Companies House and HM Revenue and Customs.
Where retention periods are not governed by legislation our policies are based on commercial justification, set in accordance with the principle of not retaining personal data for any longer than is necessary for the purposes for which it is processed. These include:
- To enable us to provide you with our fund management services
- To allow us to resolve any disputes or complaints
- To detect and prevent fraud.
You have the following rights:
- To know the data that we hold on you and to make sure that it is correct and up to date
- To request a copy of your personal data, ask us to restrict processing it or delete it – unless we have a lawful reason to continue
- To object to our continued processing of your personal data if you believe that it is no longer necessary in relation to the purpose for which it was collected or processed
- To withdraw your consent to our processing your data, if that data was collected based on your consent and there is no other legal ground for processing
If you have a query about the personal data we hold on you or wish to request that we no longer process such data, please contact us at firstname.lastname@example.org
If you would like to make a complaint please contact our Data Protection Officer at:
If you are not satisfied with our response, you also have the right to make a complaint to the Information Commissioner’s Office (www.ico.org.uk), the UK’s supervisory authority for data protection.
Changes to this policy
This policy was reviewed in August 2019.