This is Cambridge Innovation Capital's (we/us/our) data protection and privacy policy that explains who we are, why and how we process your personal information (also referred to here as personal data), your rights and how to contact us if you need to.

Our contact details are set out at the end of this policy.  We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).

This policy (together with our Cookies Policy and any other documents referred to within) sets out:

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.  

Information we collect about you

We may process your personal data if:

  • you or the company you work for are:
    • enquiring about;
    • are in the process of; or
    • have already secured capital or other support from us; or
  • you provide us with your CV or submit any other information in relation to a potential role with us or our portfolio, or potential portfolio, companies.

In relation to the latter, please also see our privacy notice for applicants.

Information we collect from you or from a third party
We may process your personal data that we have either obtained from you, or obtained from somewhere else. Personal data which is not collected directly from you may be collected:

  • from your employer in connection with your job and how it relates to us;
  • if you use any websites operated by us; or
  • from third parties we work closely with including, for example, the University of Cambridge, Cambridge Enterprise, our shareholders, other potential investors and professional advisers such as lawyers and accountants. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Personal data
Personal data relating to you that we process may include:

  • your name;
  • who you work for, and your job function or department;
  • your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the company that you work for);
  • information about you that you give us by communicating with us by phone, by e-mail, via our website, via social media or otherwise. This includes information you give us or that we obtain when you use our website, provide us with your CV or submit any other information in relation to a potential role;
  • information relating to business opportunities and/or transactions with us involving you or the company you work for;
  • other information relating to you which it is necessary for us to process in order to enter into or perform a contract with you or the company you work for (for example, right to work information); and
  • your log-in details where you are using the 'Investors' area of our website.

Information that we obtain from you when you use our website may include:

  • information you give us. This is information about you that you give us by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our website, subscribe to our services and/or updates, participate in discussion boards or other social media functions on our website, and when you report a problem with our website. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and previous property purchase information.
  • information we collect about you. With regard to each of your visits to our website we will automatically collect the following information:
    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, domain names, and referring website addresses.
    • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time),

Cookies and other technologies

Our use of cookies and other similar technologies to process personal data is explained in our cookie policy, which you should please read.

How we use your information

We will use the information you give to us to:

  • take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you or the company you work for and us including:
    • supplying services to you or the company you work for;
    • administering your/your company's account with us in order for you to access the 'Investor' area of our website; and
    • notifying you about changes to our service; and
  • ensure in our legitimate interests that:
    • content from our site is presented in the most effective manner for you and for your computer; and
    • we provide you or the company you work for with the information and services you request from us where possible.

Information we collect about you from your use of our website
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:

  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to keep our site safe and secure;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer; and
  • to allow you to participate in interactive features of our service, when you choose to do so.

Our marketing updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information to provide you with marketing communications.

You can object to further marketing at any time by selecting the "unsubscribe" link at the end of all email sent to you.

You can also request that we send marketing material to a non-personal email address instead of one which identifies you as an individual.

Who we give your information to

We may share your personal data with:

  • any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy;  
  • appropriate third parties including:
    • our business partners, customers and suppliers for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
    • our auditors, legal advisors and other professional advisors or service providers;
  • in relation to information obtained via our website, we may share your personal data with analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.

We may also disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy;
  • if Cambridge Innovation Capital or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets; or
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce agreements with you or the company you work for; or to protect the rights, property, or safety of Cambridge Innovation Capital, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Where we store your information

The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.

We may transfer your personal information outside the EEA:

  • in order to store it;
  • in order to enable us to provide investment services and fulfil our contract with you or the company your work for. This includes order fulfilment, processing of payment details, and the provision of support services;
  • where we are legally required to do so; or
  • in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.

How we protect your information

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our website may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

How long we keep your information

We retain personal data for as long as you are a shareholder or you have a relationship with us in order to meet our contractual obligations to you. We will also keep your personal information for a certain period after your relationship with us has ended. For us to establish the retention period for your personal information, we will need to account for our legal obligations, the expectations of financial and data protection regulators, and the amount of time we may strictly need to hold your personal information to carry on our business or defend our rights.  

We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.  

Your rights

You have the right under certain circumstances:

  • to be provided with a copy of your personal data held by us;
  • to request the rectification or erasure of your personal data held by us;
  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  • to object to the further processing of your personal data, including the right to object to marketing sent by us; and
  • to request that your provided personal data be moved to a third party.

Your right to withdraw consent

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us using the details below.

How to exercise your rights

You can also exercise the rights listed above at any time by contacting us at enquiries@cicplc.co.uk.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/ index_en.html). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

Changes to this policy

Any changes we make to our privacy policy in future will be posted on our website at https://www.cicplc.co.uk/ and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated in May 2018.

Contact us

Our full details are:

Cambridge Innovation Capital
Hauser Forum
3 Charles Babbage Road
Cambridge
CB3 0GT

+44 (0) 1223 764875

enquiries@cicplc.co.uk