Privacy Notice
Why are we providing this notice?
This Privacy Notice is intended to ensure that individuals outside our organisation with whom we interact, including visitors to our website, personnel of service providers or other suppliers and others who interact with us whether via our website or by corresponding with us by other means (e.g. by emailing or phoning us) are aware of the categories of personal data about them that Atomico (UK) Partners LLP (“we”, “us” or “our”) may collect, how we collect it, what we use it for and with whom we share it.
“Personal data” means any information relating to you, such as your name and contact details, but does not include data where you can no longer be identified from it such as anonymised, aggregated data.
Atomico (UK) Partners LLP will be a data controller in respect of personal data about you that is collected through this website or that you otherwise provide to us. A data controller is responsible for deciding the ways in which and purposes for which personal data about you is processed. We may process your personal data ourselves or through others acting as data processors on our behalf.
If you have any questions about this Privacy Notice, you can contact us using the details set out in the ‘Contact Us’ section below.
We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. These supplemental notices should be read together with this Privacy Notice.
What information may we process about you?
If you contact us
If you contact us through our website or otherwise, you may provide personal data to us in the course of your correspondence with us. This may include, but is not necessarily limited to, your name, address, place of business, email address, other contact details, job title, correspondence records and your opinions. We may also generate personal data about you in connection with the correspondence, such as correspondence records and opinions.
The purposes for which we may collect, store and use such personal data about you and our ‘lawful basis’ for processing such data are set out in the table below. The GDPR specifies certain ‘lawful bases’ for which we are allowed to use your personal data where that processing is subject to the GDPR.
Purpose
- To correspond with you, respond to your enquiry or address matters raised by your correspondence.
Lawful basis for processing
- Our legitimate interests in responding to or addressing your enquiry or otherwise communicating with you in the course of our business.
If you sign up to and use our Investor Portal
If you sign up to and use our investor portal, we may collect the following types of personal data: name, email address, user name and password. The purposes for which we may collect, store and use such personal data about you and our ‘lawful basis’ for processing such data are set out in the table below.
Purpose
- To provide information to you in a secure manner and to restrict access to sensitive information
Lawful basis for processing
- Our legitimate interests in limiting access to information to appropriate persons and enabling investors to access confidential information securely.
If you sign up to the Atomico Newsletter
If you sign up to our newsletter through our website, you will be required to provide your email address and name. The purposes for which we may collect, store and use such personal data about you and our ‘lawful basis’ for processing such data are set out in the table below.
Purpose
- To raise the profile of our business, our portfolio companies and our industry. This may include direct electronic marketing.
Lawful basis for processing
- Our legitimate interests in promoting our products and services and growing our business.
Potential investment evaluation
If you are connected with (e.g. a director, officer or employee of) an entity which we are evaluating for a potential investment, we may collect the following types of personal data: name, place of business, email address, other contact details, corporate contact information, signature, nationality, country of residence, place of birth, date of birth, employment and job history, education details, correspondence records, passport number. We may also generate personal data about you to help us evaluate our potential investment, such as correspondence records and opinions.
We may collect this personal data ourselves when you provide information to us or others acting on our behalf and we may also receive personal data from third parties such as public sources or information vendors or your service providers.
The purposes for which we may collect, store and use such personal data about you and our ‘lawful basis’ for processing such data are set out in the table below.
Purpose
- To undertake pre-investment steps including assessing the investment prospects of our potential investment and undertaking due diligence.
- To maintain our records.
- To monitor our investment including undertaking valuations.
Lawful basis for processing
- Compliance with applicable legal obligations and our legitimate interests in conducting our business in a proper manner.
- Our legitimate interests in conducting our business in a proper manner.
- Our legitimate interests in conducting our business in a proper manner.
Cookies
Our website uses cookies. These cookies collect information about how you use our website and other technical data (such as your IP address, browser type and version, time zone setting and location). The purposes for which we may collect, store and use such personal data about you and our ‘lawful basis’ for processing such data are set out in the table below.
Purpose
- To administer and maintain our website and record and monitor your use of our website (which may include analysing your use of our website).
Lawful basis for processing
- Our legitimate interests in studying how our website is used, keeping our website updated and relevant, developing our business and informing our marketing strategy.
Other purposes
In addition to the uses above, we may also process your information where required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
We may also process personal data for purposes other than those for which the personal data was originally collected (provided that such new purposes are not incompatible with the original purposes). Where this is the case, we will provide you with information about that further processing.
Special categories of personal data
There are more limited bases for processing special category personal data. This is personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation.
We do not intend to actively collect special category data about you. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally. For example, where you volunteer special category data to us, such as if you send us an email containing special category data.
What if you do not provide the personal data requested?
Unless and until you make a decision to engage in a business transaction with us (at which point we will send you a copy of any relevant privacy notice) or if you are connected with a potential investment valuation, you are not required to provide us with any information although please note that our website may automatically collect certain technical data (further details information in this respect is set out in our Cookies Policy). We may not be able to grant you access to certain parts of our website if you do not provide certain personal data. If you are connected with a potential investment valuation, in some circumstances if you do not provide us with certain information when requested, we may be limited or restricted in our ability to deal with you and may in some cases be prevented from complying with our legal obligations. Where we require your personal data to comply with anti-money laundering or other legal requirements, failure to provide this information means we may not be able to proceed with the potential investment with which you are connected.
With whom will we share your information?
We may share your personal data with a third party where this is required by law, where it is necessary to progress the proposed investment with which you are connected or perform our contract in respect of it, or where we have another legitimate interest in doing so.
We may need to share your personal data with:
- other entities within our group as part of our regular reporting activities in company performance, in the context of a business reorganisation or group restructuring exercise, for assistance in relation to marketing and business development or in connection with the operation of group-wide functions and services;
- professional advisers, including lawyers, bankers, auditors and insurers to the extent such information is relevant to their performance of their services;
- regulators and government bodies;
- IT service providers (such as cloud services providers, IT consultants and software-as-a-service providers), including The Rocket Science Group, LLC d/b/a MailChimp, which administers our marketing mailing lists; and
- any of our service providers where such information is relevant to their performance of such services.
We may share your personal data with third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protection our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
Where your personal data may be processed.
We are established in the UK.
The Rocket Science Group, LLC d/b/a MailChimp, which administers our marketing mailing lists, is based in the USA and personal data processed by MailChimp may be processed by Mailchimp in the USA. MailChimp participates in the EU-US Privacy Shield Framework. The European Commission has certified that it the EU-US Privacy Shield Framework ensures adequate level of protection in respect of personal data. We also use cloud based platforms to process personal data, such as Google Drive. These platforms may process personal data on our behalf on servers outside the EEA.
Where required by the GDPR, we will (or will require a processor to) put in place appropriate safeguards such as the standard contractual clauses approved by the European Commission. If you require further information about this you can request it using the details set out in the ‘Contact Us’ section below.
How long will we retain your information?
We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. In doing this we will have regard to 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. Generally, we will keep information relevant to our dealings with you for 7 years following the last date of activity or completion of the relevant investment transaction.
In some circumstances your personal data may be anonymised so that it can no longer be associated with you, in which case it is no longer personal data.
Once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data in accordance with applicable laws and regulations.
Accuracy of information
It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data which we hold changes during your relationship with us.
Your rights in relation to your information
Where the processing of your personal data is within the scope of the GDPR, you have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:
- request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
- request rectification of your personal data;
- request the erasure of your personal data;
- request the restriction of processing of your personal data;
- object to the processing of your personal data;
- request the transfer of your personal data to another party.
If you want to exercise one of these rights please use the contact details set out in the ‘Contact Us’ section below.
You also have the right to make a complaint at any time to a supervisory authority for data protection issues.
Fees
You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where we may require your consent to process your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using the contact details listed below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.
Changes to this Privacy Notice
Our practices with respect to personal data may vary from time to time and we may update this Privacy Notice at any time. The latest version of this Privacy Notice will be made available to you on our website. If we intend to process your personal data for a purpose other than the purposes referred to above, we will provide you with additional information about that purpose.”
Contact us
This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please do not hesitate to contact us using the following contact details: privacy@atomico.com.
