At BGV, data protection is important to us. We believe in a responsible and pro-active
approach when dealing with personal information.
This policy sets out how and why we collect, store, use and share personal information, our dedication to protecting it, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a question, comment or complaint.
Welcome to Bethnal Green Ventures’ privacy policy. We are BGV Investment Management Limited (“BGV”, “we” or “us”). Our company registration no. is 10499434 and our registered address is at 63/66 Hatton Garden Fifth Floor Suite 23, London, England, EC1N 8LE. We are the controller of the personal information we process about you. We are registered with the Information Commissioner’s Office (ICO): ZA362735.
This privacy policy applies to individuals who visit our website at https://www.bethnalgreenventures.com/ (the “Website”), engage with us via our Website or social media accounts, or sign-up to our events. It also applies to all of our business contacts, including contractors, suppliers, founders, directors and staff of investee businesses, mentors, and investors.
If you are a job applicant applying to one of our open positions, please read our privacy policy dedicated to job applicants available here.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are fully aware of how and why we are using your information.
If you have any questions about how we use your personal information, please contact:
hello@bethnalgreenventures.com
1. The types of personal information we collect
We collect and use the following information about you:
● Identity Data including your gender, first name, surname, any applicable national identification number, and any type of government-issued IDs (e.g. passport details).
● Contact Data including your address, email address, and telephone numbers.
● Financial Data including your tax residency, tax identification number, investment experience, investment portfolio and bank account details.
● Transactional Data including information about our business dealings, transactions and interactions with you.
● Technical Data including your IP address, device type, browser type, usage details, and broad geographical location when you visit or engage with our Website or social media accounts.
● Employment Data including job title, salary and pay information, pension information, date of birth, right to work documentation, health information to make reasonable adjustments.
● Usage Data including information about how you use our Website.
● Marketing and Communications Data including your preferences in receiving marketing from us, including news and updates, and your communication preferences.
● Diversity Data including your ethnic identity, sexual orientation, disability status, and gender identity.
● Background Checks Data including information from anti-money laundering and sanctions checks and information from criminal records checks.
We will indicate where any personal information we have requested is mandatory. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances, this may mean we are unable to provide you with a certain service.
2. Special Categories of Data
For the purposes of engaging with us, you might also share with us special categories of personal information relating to your:
● race or ethnicity;
● disability records;
● sex life or sexual orientation;
● criminal convictions and offences.
You may share such information with us for diversity monitoring purposes, or to enable us to provide our services to you. Your personal information will be collected and processed in accordance with data protection laws and securely with safeguards in place to protect your rights and freedoms.
3. If you fail to provide personal information
Where we need to collect personal information by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
4. How we use your personal information
The personal information we process depends on our relationship with you as follows:
Visitors/users of our Website and social media accounts and individuals who sign up to our events
● Identity Data
● Contact Data
● Transactional Data
● Technical Data
● Usage Data
● Marketing and Communications Data
Founders and directors of investee businesses
● Identity Data
● Contact Data
● Transactional Data
● Diversity Data
● Employment Data
● Background Checks Data
● Special Category of Data
● Marketing and Communications Data
Staff within investee businesses
● Identity Data
● Contact Data
● Transactional Data
● Employment Data
Mentors
● Identity Data
● Contact Data
● Diversity Data
● Employment Data
● Usage Data
● Marketing and Communications Data
Investors
● Identity Data
● Contact Data
● Financial Data
● Transactional Data
● Employment Data
● Background Checks Data
● Usage Data
● Marketing and Communications Data
Suppliers and contractors
● Identity Data
● Contact Data
● Financial Data
● Transactional Data
● Marketing and Communications Data
We use personal information relating to you that we collect, or that you provide to us, for the following purposes:
● To comply with Know Your Client (KYC) and Anti-Money Laundering (AML) obligations and to ensure that certain legal requirements are met, including for tax compliance purposes such as FATCA and CRS reporting;
● To prevent fraud and perform due diligence verification for the purposes of the prevention or detection of fraud and to assist in preventing money laundering;
● To carry our due diligence checks for the purposes of making investments;
● To invite you to events which we feel may be of interest to you (including but not limited to demo days, talks, networking and social events);
● To connect you with our portfolio companies (for mentoring purposes);
● To notify you when applications for our accelerator programme open;
● To assist you and respond to your enquiries and provide assistance;
● To deliver and facilitate delivery of our services to you;
● To keep our Website and services safe and secure, including fraud monitoring and prevention;
● To prepare anonymised data sets;
● To organise fundraising activities and investment opportunities in our capacity as an appointed representative of Midmar Capital LLP;
● To identify usage trends in respect of our Website and to better understand how it is being used so we can improve it;
● To request feedback and to contact you about your use of our services;
● To manage and administer our investor relationships including: assessing eligibility to subscribe for interests in a fund, allowing participation in a fund, providing important information about a fund (such as annual and quarterly reports, drawdown notices, invitations to investor meetings and requests for investor consents) and making distributions or other payments;
● To deliver, manage and improve our Website;
● To provide you with marketing information related to our services which we believe may be of interest to you;
● To comply with the law; and
● To perform our day-to-day business activities.
5. Lawful basis for processing
We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case, the legal basis will be one of the following:
● Consent: This applies where, for example, we obtain your consent to certain marketing communications.
● Our legitimate business interests: Where it is necessary for us to carry out the services or perform our business activities, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
● Performance of an agreement with you: For example:
- where you have provided your information in order to receive details in relation to our services;
- to provide you with customer support and ensure we provide a good level of customer service;
- to employ or engage you as a supplier or contractor of our business.
● Special Categories of Data. We are required to have an additional legal basis to process special categories of personal data (including criminal offence information). We usually rely on the following:
- the processing is necessary for the establishment, exercise or defence of legal claims;
- the processing is necessary for reasons of substantial public interest (e.g., to comply with the law and prevent unlawful acts); or
- where we have your explicit consent.
● Compliance with the law. Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
6. How we share your personal information with third-parties
We may share your personal information with our third-party partners, including but not limited to:
i. third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work;
ii. members of our mentor network and senior staff from our portfolio companies and funders that assist with evaluation and selection of applications for investment from us;
iii. members of our mentor network and staff from our portfolio companies to enable mentoring opportunities; or
iv. to the extent that it is connected with investment activity, with due diligence providers, prospective or actual investee companies and co-investors.
We have contracts in place with our third-party partners, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us without our approval. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
A list of our third-party partners we currently share personal information with is available on our Website. If you would like to better understand their policies and how they collect and process your personal information, you can access this information here.
We may disclose your personal information to other third parties in the following cases:
● If we or substantially all of our assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
● If we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request; or
● To protect our business and enforce our rights (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party partners to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
7. Marketing
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We are committed to protecting and respecting your personal information. We will not sell or rent your personal information to any third parties. We may share your personal information with third parties, but only to fulfil our own marketing campaigns and in line with your marketing preferences. You can opt out of our marketing emails at any time or you can ask us to stop sending you marketing messages by contacting us at hello@bethnalgreenventures.com
8. Cookies
Our Website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. For further information on how we use cookies on our Website, please read our Cookie Policy available here.
9. External Links
Although the Website only looks to include safe and relevant external links, users should always adopt a policy of caution before clicking any external web links mentioned throughout the Website.
The Website may, from time to time, contain links to and from the websites of our partner networks. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
10. Social Media Platforms
Communication, engagement and actions taken through external social media platforms which BGV participates in are subject to the terms and conditions as well as the privacy policies of those social media platforms.
This Website may use social sharing buttons which help share web content directly from our web pages to the social media platform in question. Where you use such social sharing buttons you do so at your own discretion. You should note that the social media platform may track and save your request to share a web page respectively through your social media platform account. Please note these social media platforms have their own privacy policies, and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these social media platforms.
11. Where we store your personal information
In the event that we transfer your personal information internationally, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy policy. In these cases, we rely on approved data transfer mechanisms (such as the EU and UK “Standard Contractual Clauses”) to ensure your information is subject to adequate safeguards in the recipient country.
If you are located in the UK or EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
12. Your Rights
We take your privacy very seriously and want you to be aware of your rights, as follows:
● you have the right to request (i) confirmation of whether we process your personal information and (ii) access to a copy of the personal information retained;
● you have the right to request the rectification or removal of your personal information or restriction of the processing of your personal information;
● where processing of your personal information is either based on your consent or necessary for the performance of an agreement with you and processing is carried out by automated means, you have the right to request the personal information concerning you in a structured, commonly used and machine-readable format or to
have your personal information transmitted directly to another business, where technically feasible;
● where the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time without impact to any data processing activities that have taken place before such withdrawal;
● you have the right not to be subject to any decisions based solely on automated processing, including profiling, which has legal or other similarly significantly effects on you unless we have your consent, it is authorised by law or it is necessary for the performance of an agreement;
● you have the right to object to processing if we are processing your personal information on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to
examine the processing of your personal information, and to balance our legitimate interests in carrying out the processing and your objection to this processing;
● you have the right to object to processing your personal information for direct marketing purposes; and
● you have the right to lodge complaints before the competent data protection regulator, the UK Information Commissioner’s Office, and you may do so at
https://ico.org.uk/make-a-complaint/
Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. This is a security measure
to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Please send us an email at hello@bethnalgreenventures.com if you would like to exercise any of your rights.
13. Data Security
We have put in place appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We take steps to ensure that your personal information is treated securely and in accordance with this privacy policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal
information, for example, by encryption or by using pseudonymisation, we cannot guarantee the security of your information transmitted via the internet; any transmission
is at your own risk.
We have appropriate technical and organisational measures designed to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other individuals. We maintain these technical and organisational measures and will amend them from time to time to improve the overall security of our systems.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.
We will, from time to time, include links to and from the websites of our partner networks, advertisers, social media platforms and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.
14. How long we keep your personal information
We retain your information for as long as it is necessary to provide you with the service we supply to you or to fulfil our obligations to you. Where we do not need your information in
order to provide the service or to fulfil our obligations to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. For example, when you visit our Website, we retain information on our server logs for up to two years.
If you are a founder, mentor, or investor, we retain your information for the as long as we have a business relationship with you.
However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations (such as tax or accounting) or where it is necessary for the establishment, exercise or defence of legal claims.
If you request that your personal information be removed from our databases and/or systems, please note it may not always be possible to completely delete all your personal information due to technological and legal constraints. However, we will take such steps as are reasonable to securely delete such information or to store your information in an aggregated and anonymised format.
Should you request additional services from us, you will be authorising the extension of the data collection and/or processing purpose as a result.
15. Information relating to children
The services provided by BGV are not directed at children under the age of 18. If you believe that we have personal information about or collected from a child under the relevant age, please contact us at hello@bethnalgreenventures.com
16. Queries and complaints
In the event that you wish to discuss, or make a complaint about, how we process your personal information, please contact us in the first instance at hello@bethnalgreenventures.com
and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to submit your complaint to the relevant data protection authority.
17. Changes
We will generally notify you of any material changes to this policy, through a notice provided via the Website or otherwise supplied to you. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at
the end of this policy, which reflects the effective date of such policy. Your continued engagement with us after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop your engagement with us.
Last updated: 15 September 2023
