Last updated: June 7th, 2022
This Policy provides information relating to your Personal Data which we may collect, including in relation to the investment services we provide to you, via our partners and service providers, or through this website. This policy describes the following:
What Data that we may collect
What do we do with the information we gather
How is it collected
How long, where and how we store your data
Details about information storage and Data security
Details as to how you can access and make certain choices about how we use your Personal Data, and your rights regarding Personal Data.
If we have asked you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used lawfully (in accordance with the General Data Protection Regulation (EU) 2016/679 as applicable in the UK together with the Data Protection Act 2018 (together “UK GDPR”)), as set out in this Policy.
By visiting http://www.firstminute.capital you are accepting and consenting to the practices described in this Policy. We may make changes to this Policy from time to time by updating this page, and may do so without expressly notifying you of these changes. However, should the legal bases or purposes for processing your Personal Data change, we shall expressly notify you.
Please check this page from time to time to ensure that you are happy with any changes.
If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Email address: email@example.com
Postal address: firstminute capital, 4th floor, Northcliffe House, Derry Street, London W8 5EH
Other than in accordance with any contract you have with us, we are the controller and responsible for your Personal Data.
What we may collect
Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymous data, where an individual’s identity has been removed.
We may collect, use, process, store and transfer different kinds of Personal Data about you, such as:
Identity Data – including given name(s), surname(s) and maiden names, username or similar identifier, title, date of birth, nationality, marital status, gender
Employment Data including your employer’s name, your position or job title, and your corporate contact details;
Contact Data – including billing address, delivery address, email address and telephone/fax numbers;
Profile Data – including your username and password or any other login date, purchases or orders made by you.
Client Service Data – including Personal Data received from clients in respect of our employees or our customers or affiliates and client feedback;
Technical Data – including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
Financial Data – including bank account and payment card details; your financial circumstances, including your profession, income, assets and liabilities.
Transaction Data – including details about payments to and from you and other details of services or products you have purchased from us;
Compliance data – Government identifiers, passports or other identification documents, dates of birth, beneficial ownership data and due diligence data;
Usage Data – including information about how you use our website, products and services; and
Data that might be considered Sensitive – including criminal records (convictions and offenses) and trade union memberships.
Except as otherwise mentioned in this Policy, we do not collect any Special Categories of Personal Data about you, including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data.
This website is not intended for children and we do not knowingly collect data relating to children.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Policy.
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.
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract or to facilitate any arrangement we have with you, and you fail to provide that data when requested, we may not be able to perform the contract or arrangement we have or are trying to enter into with you or otherwise comply with the legal obligation. For example, when you initially engage with our services but you do not provide relevant identification documents that would allow us to comply with anti-money laundering checks, we may refuse to carry out our services to you. In such cases, we will notify you at the time.
What we do with the information we gather
We require this information mainly to provide you with our services and improve them, as well as to understand your needs, and in particular for the following reasons:
to register you as a new client;
to provide and improve our services and respond to enquiries;
to process and deliver payments including managing payments, fees and charges and collecting and recovering money owed to us;
to manage our relationship with you including notifying you about changes to our terms or policies;
to administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
to offer you our services or products, or our affiliates’ services or products, as may be of interest to you;
to use data analytics to improve our website, products and/or services;
to deliver relevant website content to you and measure or understand the effectiveness of the content we provide to you; and/or
To comply with any legal, regulatory, accounting or other obligations
We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data.
We may collect and process Personal Data with respect to persons connected with the investment services we provide. As well as collecting Personal Data from our clients, we may also process Personal Data about relevant persons connected with the investment services, for example investors in our funds, co-investors, directors of investee company portfolios, etc.
Where relevant, we may collect, and process personal information of persons related to you. In such circumstances, it is your responsibility to ensure you have permission from that third-party for us to collect their information and you remain responsible for ensuring that the third-party understands how their information is being used.
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. 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 or otherwise request your consent.
Third Party Transfers
We may have to share your Personal Data with third parties such as:
IT and system administration service providers acting as processors;
Service providers who assist and support us with running our website or other IT services;
KYC service providers;
Some of our consultants and lawyers, as well as professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers; and
HMRC, regulators and other authorities acting as processors or joint controllers.
Your data may be shared with third parties located in countries outside of the European Economic Area (EEA). Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
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 or by a similar arrangement approved by the European Commission;
Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.
Alternatively, where we can’t guarantee the safeguarding of your Personal Data, we will first ask for your explicit permission to transfer the data, and by consenting to the transfer you understand and agree to the risks that may be involved in such transfer and handling of your Personal Data by said third party.
We may also have to share your Personal Data for the above purposes with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Policy.
How we use your Personal Data – Legal base and purposes
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
in order to fulfil our contractual or other obligations to you or in order to facilitate the provision of such contracts and obligations or of goods or services (e.g. where you have asked us to do something before entering into a contract, for example to provide a quote)
Where it is necessary in order to achieve our Legitimate Interest (or those of a third party). This may include electronic communications between us, the provision of investment information to you, obtaining and recording details relating to your visit behaviour on our website in order for us to manage and improve our website, etc. In doing so, we ensure that your rights and interests are considered and protected-
Your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests.
We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We are able to demonstrate that we use your data in a proportionate manner. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us; and
Where we need to comply with a legal or regulatory obligation, including but not limited to UK Financial Conduct Authority Conduct of Business Rules, AML/CTF legislation etc. We can lawfully disclose personal data to a third parties where we can demonstrate that this disclosure is justified
Based upon reasons of substantial public interest; and
Where your personal information is public information by your own actions.
Please contact us if you need more details about the specific legal ground we are relying on to process your Personal Data.
How is your Personal Data collected?
We use different methods to collect data from and about you including through:
Direct interactions – you (on your own or via our affiliates, delegates, partners, service providers, and professional advisors) may give us your Identity, Contact and Financial or other 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 apply for our services, fill out a new enquiry form on our website, etc.
Automated technologies or interactions – as you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources – we may receive Personal Data about you from various third parties (including any third parties with whom we undertake due diligence checks upon you) and public sources such as (but not limited to):
Technical Data from analytics providers such as Google based inside or outside the EU and/or search information providers based inside or outside of the EU;
Contact, Financial and Transactional Data from providers of technical, payment and delivery services based inside the UK/EU; and
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK/EU.
In doing so, we will ensure that the information we collect is proportionate to our stated purposes.
How long, where and how we store your data
We will keep your Personal Data for as long as we need to in order to use it as described above, and/or for as long as we have your permission to keep it. We might also keep your Personal Data for as long as we reasonably believe it to be necessary in order to facilitate our Legitimate Interests, in order for us to comply with our legal, regulatory, tax, accounting or reporting obligations, where based upon reasons of substantial public interest, or where your Personal Data remains public information by your own actions.
We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We store your physically held personal information in our UK offices. Your electronically held personal information is in cloud storage on servers in the UK or the EU.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
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 take all reasonable steps to protect your personal information; however, where you choose to transmit your personal data to us via the internet, we do not guarantee the security of the personal information transmitted and therefore any transmission is at your own risk.
We may transfer your personal information to our affiliates, partners or service providers that are based outside of the European Economic Area. In such circumstances, we will ensure that your personal information is adequately protected to European Commission approved standards and if for any reason we can’t guarantee such protection, we will contact you and request your explicit consent.
Except as described above (e.g. when we consider merging or selling or transferring parts of our business or assets or seek to acquire other businesses or when necessary to provide you with our services per the agreement you sign with us) - we will never sell, distribute or lease your personal information to third parties.
Links to other websites
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Policy. We encourage you to read the privacy statement applicable to any website you visit.
Exercising your rights
As a data subject, you have the following rights under the UK GDPR, which this Policy and our use of Personal Data have been designed to uphold:
the right to be informed about our collection and use of Personal Data;
the right of access to the Personal Data we hold about you;
the right to rectification if any Personal Data we hold about you is inaccurate or incomplete;
the right to be forgotten – i.e. the right to ask us to delete any Personal Data we hold about you;
the right to restrict the processing of your Personal Data;
the right to data portability – i.e. obtaining a copy of your Personal Data to re-use with another service or organisation;
the right to object to us using your Personal Data for particular purposes; and
rights with respect to automated decision making and profiling.
If you wish to exercise any of these rights, please contact us.
Please note that 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.
You will not 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
If you have any cause for complaint about our use of your Personal Data, please contact us and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority for data protection issues, the Information Commissioner’s Office (www.ico.org.uk).
Further details about your rights can also be found on the ICO website, however please note that your rights are subject to our overarching legal responsibilities.