Archangels Investors Limited (“We“, “Archangels“) 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 Archangels 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.
For the purpose of the Data Protection Laws, the data controller is Archangels Investors Limited of 20 Rutland Square, Edinburgh, EH1 2BB and the Data Protection Officer is David Ovens.
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) via our membership forms. We may, on occasion, be provided with information by your or our solicitor or by an existing member or board member. We will promptly notify anyone whose data we receive that we are holding that data.
We may collect the following information from you:
- contact details;
- date of birth;
- financial information (including details of funds invested in); 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, 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;
- pay you any returns on your investment;
- inform you of investment opportunities;
- facilitate the entering into of investment agreements; and
- invite you to Archangels’ 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;
- invite you to Archangels 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 20 Rutland Square, Edinburgh, EH1 2BB. 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 20 Rutland Square, Edinburgh, EH1 2BB.
Accuracy of personal data
Archangels 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 20 Rutland Square, Edinburgh, EH1 2BB as soon as possible. We will promptly correct or delete any information found to be incorrect.
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 finance, IT, 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:
- 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
- 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.
- so that our legal advisers can carry out checks in relation to regulatory compliance.
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 may transfer personal data we hold about you to a country outside the European Economic Area (“EEA“) where we engage suppliers located in jurisdictions outside the EEA.
As at the date of this policy, we transfer personal data to some IT service providers located in the United States of America (“US“); these are Microsoft and Insightly. We have not taken steps to protect any of your personal data which we send to the US, as we believe the entities themselves have sufficient measures in place.
If we transfer any data to any other jurisdiction outside the EEA, we will provide you with details of the country to which data is being transferred, along with details of the measures we have put in place to protect it (which you may see a copy of, on request).
Retention of personal data
Archangels will destroy records of shareholders and individuals who cease to be members after the companies they invested in have been sold or dissolved.
Archangels 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 20 Rutland Square, Edinburgh, EH1 2BB 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.
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.
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 David Ovens at 20 Rutland Square, Edinburgh, EH1 2BB or by email to firstname.lastname@example.org.
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
Collection of Personal Information
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.
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.
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.
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.
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.