1. What data will we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect data about you:

 

• if you are an investor or prospective investor, or connected with a portfolio company or prospective portfolio company or otherwise provide us with your personal details (such as your name, contact details, e-mail address etc.); and
   

• from your usage of the website and any other information you post on the website, e-mail or otherwise send to us.

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2. How might we use that data?
We will only use your data to supply you with the services and information which you have requested and when legally allowed to do so. Most commonly, we will use your personal data where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

For example:

• if you are an investor or prospective investor in one of our funds, we may use your data in connection with that investment, or
   

• if you are connected with a portfolio company or prospective portfolio company, we may use your data in connection with the monitoring and management of our investment.

We may also send you further information about our services or keep you informed of updates through our periodic newsletters, provided you have indicated that you are happy to be contacted for these purposes.

We may contact you by post or telephone as well as by e-mail. If you change your mind about being contacted in the future, then please let us know.

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3. How is data secured?
All information you provide to us is stored on secure servers with industry standard anti-virus and firewall protection in place.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted online or through the website. Any transmission is at your own risk.

 

Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.

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4. How will data be disclosed?
We process all data in accordance with the EU General Data Protection Regulation. We may disclose your data to other third parties who act for us, in order to provide the services you have requested.

Unless required to do so by law, we will not otherwise share, sell or distribute any of the data you provide to us without your consent.

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5. What are your rights?
You have certain rights by law including the right to access your information held by us (for which we may charge a small administrative fee) and to have any inaccurate information corrected.

The law on data protection sets out several different reasons for which a company may collect and process your personal data, including:

Consent: In specific situations, we can collect and process your data with your consent.

Contractual obligations: In certain circumstances, we need your personal data to comply with our contractual obligations.

Legal compliance: If the law requires us to, we may need to collect and process your data.

Legitimate interest: In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

GDPR gives you (as an individual) a number of rights in respect of your data, including:

Right to access: You have the right to access the information we hold about you. If you would like a copy of this information, please contact us via the methods outlined below. We may request proof of your identity before sharing such information.

Right to rectify your personal data: If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information.

Right to be forgotten: You may ask us to delete information we hold about you in certain circumstances. It may not be possible for us to delete all of the information we hold about you where we have an ongoing relationship, however please contact us and we will do our best to assist with your request.

Other rights: In addition to the above, you may also ask us to stop or restrict processing of the information we have about you. You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any other information on these aspect of your rights, please contact us.

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6. When will this policy change?
This policy may be reviewed and amended from time to time and if any update is made it will be published on our website.

As a result of improvements, we make to our services, changes in the law or developments in technology, we may change the information we hold about you, the method we use to collect information, and purposes for which we process such information. If we make any substantial change in the way in which we use your personal information we will notify you, where possible, by email.

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7. How can you be contacted?
If you have any questions, want to exercise any of your rights or make a complaint, please contact us:

Illuminate Financial Management Ltd (partnership no: 12839665)
Website: illuminatefinancial.com
Address: 404, The Frames | 1 Phipp Street, London | EC2A 4PS | United Kingdom
Telephone: 020 3198 1600