Privacy Policy

Raising Partners Syndicate Limited, a company registered in Scotland under company number SC687582 and having its registered office at 5^th Floor, 125 Princes Street, Edinburgh, EH2 4AD (“We“ or “Raising Partners“) are committed to protecting and respecting the confidentiality, integrity and security of personal information about individuals whose data we hold.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and how Raising Partners complies with its responsibilities under applicable data protection laws, including, when and to the extent in force,  the Data Protection Act 1998, the General Data Protection Regulation (Regulation (EU) 2016/679) and the Privacy and Electronic Communications Regulations 2003 (“Data Protection Laws“). Please read this policy carefully.

References to a “member” in this policy refer to an investor member of the business angel investment syndicate that is administered by Raising Partners.

Data Controller

For the purpose of the Data Protection Laws, the data controller is Raising Partners and the Data Protection Officer is Helena Murphy.

Personal data collection

We hold personal data about you which you provide to us in the course of meetings or correspondence between you and us, or (where you are a member or potential member of Raising Partners) via our membership forms. We may, on occasion, be provided with information by your or our solicitors or by an existing member or board member of Raising Partners. We will promptly notify anyone whose data we receive that we are holding that data.

We may collect the following information from you:

• name;
• address;
• contact details;
• date of birth;
• financial information (including details of investments you wish to make as a member and source of wealth information); and
• bank account details.

Use of personal data and legal basis for processing

All personal data we hold about you will only be used for the purposes set out below or for any other purpose specifically permitted by the Data Protection Laws or which you may authorise (which may include direct marketing, if you authorise us to do so).

If you are a member or a shareholder of an investee company (that has received investment from members), we may use information you provide to us to:

• update you on investee companies in which you have an investment;
• provide you with access to our investment portal;
• carry out statutory anti-money laundering and source of wealth checks;
• assist with the payment to you of any returns on your investments;
• inform you of investment opportunities;
• facilitate the entering into of investment, subscription and/or shareholder agreements with investee companies; and
• invite you to Raising Partners’ events.

If you are an investee company or are seeking investment for your business, we may use information you provide to us to:

• communicate with you regarding the management of the company and/or investment proposals;
• share such information with our members;
• invite you to Raising Partners’ events; and
• send you a copy of our email newsletter (if you agree).

Where you provide personal information to us, we are processing it in order to perform our obligations under our contract with you or in order to take steps at your request prior to entering into a contract or you becoming a member.

Where you provide personal information to us, you will be asked if you consent to us adding you to our distribution list for our email newsletter. If you give your consent, we are processing your information for that purpose on the basis of your consent.

Access and other rights

You may request to view records held about you at any point by making a request in writing to us at our registered office.  This request will be responded to within 30 working days. If we require more time to respond fully to any request, we will notify you in writing within the 30-day period referred to. Any additional copies of any information we provide to you may be subject to a reasonable fee.

You also have other rights under Data Protection Laws in relation to your personal data. In particular, you may have (i) the right to request that we rectify or erase information we hold about you in certain circumstances, (ii) the right to ask us to limit our processing of your information, (iii) the right (if we are processing information based on your consent, such as for marketing purposes) to withdraw your consent, (iv) the right to object to certain processing of your information (including the right to object to processing of your personal data for direct marketing purposes at any time), (v) the right to ask us to move, copy or transfer your personal information to another organisation. If you wish to exercise any of these rights, please contact us at our registered office.

Accuracy of personal data

Raising Partners tries to ensure that personal data we hold about you is accurate and kept up-to-date. If you believe that any information we are holding about you is inaccurate, out-of-date or incomplete, please notify us at our registered office as soon as possible. We will promptly correct or delete any information found to be incorrect.

Security

We have put in place what we consider to be appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.

Disclosure and sharing of your personal data

We may disclose personal data to third parties for the purposes of concluding investments for members, finance, IT and/or other outsourced administrative and/or management functions, professional advice, portal development/support, or for any other purposes specifically permitted by the Data Protection Laws or for any other purpose which you may authorise.

We may also disclose personal data we hold to third parties:

1. in the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets; and/or
2. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and
3. so that our legal advisers and any other legal advisers advising on investments for members can carry out checks in relation to regulatory compliance and ingather funds.

To the extent we transfer any personal data to any third party, we will only do so if that third party agrees to put in place appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, the personal data.

Transferring personal data outside the EEA

We do not transfer your personal data outwith the United Kingdom to a non-European Economic Area (EEA) member.

Retention of personal data

Raising Partners will destroy records of shareholders and individuals who cease to be members after the companies they invested in have been sold or dissolved.

Raising Partners will retain records of potential members for 2 years, after which they will be destroyed.

We will take all reasonable steps to destroy, or erase from our systems, all personal data which is no longer required.

Please note that you may contact us at any time at our registered office and ask for your details to be removed (please refer to the section headed “Access and other rights” above). We may not be able to continue to provide you with our services in the event you request that your details are removed.

Profiling

We use a third-party service provider, which, as part of its service to us, identifies the geographic location of individuals who open our email newsletter, how many times the newsletter is opened and what items were clicked on.

Changes to this policy

We may make changes to this data protection policy at any time. Any changes we make will be notified to you in writing.

Contact

If you have any queries about this policy or your data, or you wish to submit an access request or raise a complaint about the way your personal information has been handled, please do so in writing and address this to Helena Murphy, Raising Partners and send this to our registered office or by email to [email protected]

If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data not in accordance with the Data Protection Laws you can complain to the Information Commissioner’s Office (https://ico.org.uk/).

Statement of Intent

Our Privacy Policy explains how and why we collect personal information about you. We are committed to responsible management of personal information in accordance with the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

Collection of Personal Information

In order to receive certain information and to use certain services on this site you may be asked to provide personal information about yourself such as your name, address and email address. When you provide this information to us you consent to our use of that information in accordance with the terms of this Privacy Policy. This information will be used to provide you with the services that you have requested and to provide you with news and information about our services and those of our investee companies. If you no longer want to receive such information just let us know by email and we will stop sending it.

Storage of Personal Information

We will keep your personal information for as long as we need it to provide our services to you. We will try to keep personal information which we hold about you up to date, but if you think that we are holding information which is inaccurate or you are otherwise unhappy about our use of your personal information then please send us an email to let us know.

Sharing Information

We will not sell the personal information that we collect from you. We use the personal information which we collect from you to help us provide our services to you. Some data processing in relation to this site may be carried out for us by a third party and in some cases that may mean that the third party will receive your personal information. Apart from this we will not share or transfer any personal information with any other third party unless we are required to do so by law.

Cookies

Some websites use “cookies” which are text only strings of information that the website you are visiting transfers to the cookie file of the browser on your computer. Their purpose is to identify users and to enhance the user’s experience by customising web pages. A cookie will usually contain the name of the domain from which the cookie has come, an expiry date for the cookie, and a value, which is usually a random generated unique number.

Use of cookies on our site: This site does use cookies. For more information about how to manage cookies visit http://www.allaboutcookies.org/

IP Address

This site logs your Internet Protocol (IP) address. All computers that are linked to the Internet have an IP address. An IP address does not provide identifiable personal information.

Access

You are entitled under the Data Protection Act 1998 to a copy of the personal information that we hold about you if you apply to us in writing. We may make a small charge for dealing with any such request.

Links

This site provides links to other websites. Our Privacy Policy applies only to this site and we are not responsible for the privacy practices of third party sites.

1. Introduction
   1. This Privacy & Cookie Policy details how we, Raising Partners Limited, company number 10660599, registered office 85 Great Portland Street, First Floor, London, England W1W 7LT collect, use and process personal data provided to us. This Privacy & Cookie Policy affects your legal rights and obligations so please read it carefully. It applies to personal data you provide to us whether you are a Driver, Passenger or other user of our mobile app If you do not agree to be bound by this Privacy & Cookie Policy, do not use our app and do not provide us with any personal data. If you have any questions, you can contact us at [ ].
   2. We reserve the right to update this Privacy & Cookie Policy from time to time at our discretion. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy & Cookie Policy so that you are aware of any changes to it.
   3. We are the controller of your personal data for the purposes of applicable data protection legislation. By personal data we mean identifiable information about you, such as your name, email address, gender, mobile and home telephone number and your IP address.
2. Collecting Your Data
   1. From time to time you may provide to us personal data in order that we can provide services to you, or that you can provide services to us or for any other reason. You may provide personal data to us directly, or through our social media platforms or by completing the Let’s Chat form on our website. We shall process all such personal data in accordance with this Privacy & Cookie Policy. Certain personal data is mandatory to be provided to us in order that we can provide services to you and we shall make this clear to you at the point of collection of the personal data.
   2. All personal data that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal data. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this. You must not register under someone else’s name.
   3. When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.
   4. We may also receive personal data about you from others. In particular, investors may share personal data with us about the individuals seeking funding for their company, and likewise such individuals may provide to us personal data about investors.
   5. We may also receive personal data about you from third parties, such as from payment providers.
3. Data we automatically collect
   1. When you use our website, we, or third parties on our behalf, automatically collect and store information about your device and your activities. This information could include (a) your device’s unique ID number; (b) technical information about your device such as type of device, web browser or operating system; (c) your preferences and settings such as time zone and language; and (d) statistical data about your browsing actions and patterns. We collect this information using cookies in accordance with the Cookie section of this Privacy & Cookie Policy and we use the information we collect on an anonymous basis to improve our website and services, and for analytical and research purposes.
4. Lawful Use of your personal data
   1. We will only use your personal data where we have a lawful basis to do so. The lawful purposes that we rely on under this Privacy & Cookie Policy are: consent (where you choose to provide it), performance of our contract with you; compliance with legal requirements; and legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.
   2. The main reason that we use your personal data is to provide services to you under the contract that we have entered into with you.
   3. We may also use your personal data for our legitimate interests, including dealing with any customer services you require, enforcing our contract, for regulatory and legal purposes (for example anti-money laundering and fraud prevention purposes), for audit purposes and to contact you about changes to this Privacy & Cookie Policy.
5. Who do we share your data with?
   1. In order to provide services to you, we may share your personal data with investors if you are seeking funding, and with companies seeking funding if you are an investor. You agree that we cannot provide our services unless we share personal data in this way.
   2. For our legitimate interests, we may also share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers, marketing agencies, IT service providers, accountants, auditors and lawyers. We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.
   3. In order to comply with our legal obligations, under certain circumstances we may have to disclose your personal data under applicable laws and/or regulations or in response to a court order including to protect a third party’s rights, property, or safety.
   4. For our legitimate interests, we may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
6. Marketing
   1. From time to time you may be offered the opportunity to consent to receive marketing emails from us. We record your consent. You can choose to no longer receive marketing emails from us by contacting us at [email protected] or by clicking unsubscribe from a marketing email. If you do unsubscribe to marketing communications, it may take up to 5 business days for your new preferences to take effect.
   2. We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer wish to receive marketing emails from us.
7. Where we hold and process your personal data
   1. Some or all of your personal data may be stored or transferred outside of the European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the EEA or if any of our service providers are based outside of the EEA
   2. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data (like New Zealand), or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
8. Cookies and Device IDs
   1. A cookie is a small text file containing a unique identification number that is transferred (through your browser) from our app to your device. The cookie identifies your browser but will not let us know any personal data about you, such as your name and/or address. These files are then used by our app to identify when users return.
   2. Most browsers are initially set up to accept cookies. You can change your browser settings either to notify you when you have received a cookie, or to refuse to accept cookies. Please note that our site may not operate efficiently if you refuse to accept cookies.
   3. We use and store your mobile device IDs, which is the unique identifier assigned to a device by the manufacturer, to recognise you. Device IDs cannot be deleted.
   4. We also use third party cookies such Google Analytics to monitor how our siteis used. These cookies collect information anonymously and generate reports detailing information such as the number of visits to the system, where visitors generally came from, how long they stayed on the system, and which pages they visited. They place several persistent cookies on your device. These do not collect any personal data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent these third party cookies from logging your visits.
   5. We also use social media buttons and/or plugins on the site that allow you to connect with your social network in various ways. For these to work the relevant social media sites (Twitter, and Linked In) will set cookies which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
9. Security
   1. We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. All information you provide to us is stored on our secure servers.
   2. Where we have given, or you have chosen a password, you are responsible for keeping this password confidential.
   3. However, you acknowledge that no system can be completely secure. Therefore, although we take these steps to secure your personal data, we do not promise that your personal data will always remain completely secure.
10. Your rights
    1. You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found hereRight of access: You have the right to obtain from us a copy of the personal data that we hold for you.
       Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.
       Right to portability: You can request that we transfer your personal data to another provider.
       Right to restriction of processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information.
       Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws.
       Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your account.
    2. Please note, we reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.
    3. If you have any complaints in relation to this Privacy & Cookies Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You can also contact the Information Commissioner, see www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local regulatory authority
    4. Our website contains links to third party websites. We have no control over how they process your personal data. You should review their privacy policy before providing any personal data.
11. Retention of personal data
    1. We retain your personal data in accordance with applicable laws. Therefore, if you are our client, we shall retain your personal data until all of our contractual commitment to one another are complete, except where we are required to retain your personal data for longer to comply with accounting and taxation requirements. If you receive marketing communications from us, we shall retain your personal data until you opt out of receiving such communications.
    2. If you have otherwise contacted us with a question or comment, we shall retain your personal data for 6 months following such contact to respond to any further queries you might have.
12. General
    1. If any provision of this Privacy & Cookie Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.
    2. This Privacy & Cookie Policy shall be governed by and construed in accordance with the law of England and Wales, and you agree to submit to the exclusive jurisdiction of the English Courts.