Please complete your details below if you would like the following documents:
-
Information Memorandum
-
Summary Document
-
Application form
* Correct at May 2023
This Privacy Policy is provided by the Committed Capital Group (“CCFSL” or “Committed Capital”), comprising Committed Capital Financial Services Limited, an FCA authorised and regulated business with FRN 192203, and Committed Capital Limited (“CCL”). Together CCFSL and CCL are referred to as Committed Capital Group (“CCG”).
Should you not want to undertake providing the required personal data on any contractual basis, then please don’t contact or contract with Committed Capital Group for any product and/or services.
This CCG-PP is addressed to individuals or entities outside our organisation with whom we interact. It seeks to inform you as to how the CC Group look after your personal data when you visit our website and engage with our business, and will tell you about your privacy rights and how the law protects you. The Committed Capital Group (“CCG”) respects your privacy and is committed to protecting your personal data. At all times we aim to respect any personal data you share with us or that we collect about you and keep it safe.
This Privacy Policy sets out how we look after your personal data when you interact with us including online through our website, www.committedcapital.co.uk, and your rights and options regarding the ways in which your personal data is used.
It is important that you read this Privacy Policy in conjunction with any and all other privacy policy and clauses we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and contractual clauses and is not intended to override them.
Controller
Committed Capital is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).
We have appointed a GDPR Officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the GDPR Officer using the details set out below.
Contact details
Name of GDPR Officer: Else Thomson
Email: info@committedcapital.co.uk
Telephone: +44(0)20 7529 1378
Post: Committed Capital Limited, 150 Buckingham Palace Road, London SW1W 9TR.
Please mark the message for the attention of / ask for the Finance Director.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Committed Capital takes complaints very seriously and will respond to complaints within 30 days.
Changes to the privacy policy and your duty to inform us of changes
This version was last updated and issued on 30 April 2021.
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.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Basis of Engagement
You are not providing information by consent, but by a Voluntary Agreement. You are unable to request removal of personal data while you are receiving, holding or processing products or services provided by us. The retention of key data is a legal and/or regulatory requirement even after services have been terminated (typically 5 to 6 years).
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, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We 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 privacy policy.
We may also collect the following Special Categories of Personal Data about you: racial or ethnic origin, nationality, financial status, salary information, employer references and information about your physical and mental health.
We may collect information about criminal convictions and offences when you provide it to us or where we are required to do so by law. Typically, this would be in the context of a commercial acquisition or investment.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us, or face operational limitations and risks in our services to you (e.g. communications) but we will notify you if this is the case at the time.
When you give it to us directly
Through automated technologies or interactions
When you visit 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
When we obtain it from publicly available sources
Your personal information may be available to us from external publicly available sources. This may include information available on Companies House, the Charity Commission and other charity registers, reputable media articles, publications and company websites and professional networking sites such as LinkedIn. Depending on your privacy settings for social media services, we may access information from those accounts or services, including from Facebook, Instagram and Twitter.
When we obtain it from third parties
For instance, we may obtain personal information about you from various third parties as set out below:
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:
1. Where we need to perform the contract we are about to enter into or have entered into with you.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. 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). 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.
3. Where it is necessary for us to comply with legal and regulatory requirements.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via telephone, post, email or other electronic means. You have the right to withdraw consent to marketing at any time by contacting us.
4. Purposes for which we will use your personal data
We may use your Identity, Contact, Financial, Transaction, Marketing and Communications, Technical, Profile and Usage data for the following purposes, on the basis that it is necessary for our legitimate interests:
Our LEGITIMATE INTERESTS in processing your personal data for the above purposes, are as follows:
We may use your Identity, Contact, Financial, Transaction data for the following purposes, on the basis that it is necessary for the performance of a contract with you:
We may also use your personal data to comply with LEGAL AND REGULATORY REQUIREMENTS, for example to co-operate with regulatory, government and/or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering).
As a FCA regulated firm, we are required to conduct due diligence on investors in our funds, organisations in which our funds invest, directors and senior management or trustees of those organisations, individuals and organisations we invest alongside and purchasers when we exit an investment, for the purposes of preventing financial crime. In order to fulfil our obligations, we are required to verify the organisation’s identity and conduct certain background screening. This may include verifying the identity of the organisation's shareholders, beneficial owners, management, directors, trustees or officers and/or other relevant information.
To assist us with the verification and screening process, contact details you provide will be disclosed to anti-money laundering screening, credit reference and fraud prevention agencies which may keep a record of that information. If we need to conduct this due diligence using any of the personal information you have provided us with, you will be provided with further information prior to us doing so.
We may also share this information with our lawyers and FCA-approved co-investors in relation to the particular transaction as is customary in the sector to avoid you having to provide the information more than once.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased work, services, activities or products from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will not share your personal data with any company outside Committed Capital for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please see our Cookie Policy for further details.
Change of purpose
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 5 above. Note that this parties may change from time to time and we as the CCG are not obligated to inform you of these internal changes unless we deem it necessary.
We require any third parties which we have contracted with to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
The personal information that we collect from you will be stored at a destination within the UK or European Economic Area (“EEA”) and generally our processing of your personal data will not involve a transfer of data outside the EEA.
In the event that our processing of your personal data does involve a transfer outside of the EEA, we will ensure an adequate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
This is especially important because some countries outside of the EEA may have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals.
Please contact us if you want further information on the specific mechanisms that will be used by us if we transfer your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We comply with best market practice and erase all user data held after a period of 6 years from the data not being legitimately in use, unless we are required to remove it for any reason before this date.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see “Right of erasure” below for further information.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
No fee usually required
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.
What we may need from you
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. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
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.
This Cookie Policy is provided by the Committed Capital Group (“CCFSL” or “Committed Capital”), comprising Committed Capital Financial Services Limited, an FCA authorised and regulated business with FRN 192203, and Committed Capital Limited (“CCL”). Together CCFSL and CCL are referred to as Committed Capital Group (“CCG”).
Should you not want to undertake providing the required personal data on any contractual basis, then please don’t contact or contract with Committed Capital Group for any product and/or services.
This policy is addressed to individuals or entities outside our organisation with whom we interact. It seeks to inform you as to how the CC Group look after your personal data when you visit our website and engage with our business, and will tell you about your privacy rights and how the law protects you. The Committed Capital Group (“CCG”) respects your privacy and is committed to protecting your personal data. At all times we aim to respect any personal data you share with us or that we collect about you and keep it safe.
Use of Cookies and Similar Technologies
When data is provided to us, we use it solely for the purposes for which it is given. We recognise that the security of your information is paramount and we take all reasonable measure to protect it whilst in our care. Your confidential information will not be disclosed to third parties.
What are Cookies?
Cookies are used on almost every website and are text files containing small amounts of information, which your computer or mobile device downloads when you visit a website. When you return to these websites – or visit other websites that use the same cookies – they recognise these cookies and therefore your browsing device.
How and why we use Cookies?
The CCG uses “cookies” for several reasons, namely to:
Cookies used by the CCG’s Website DO NOT:
What types of cookies do we use?
We use four main types of cookies on our website:
These are essential to the navigation of our website and to features such as, logging in to your account. These cookies do not gather information about you for profiling or targeted marketing purposes.
These allow us to collect anonymous data on how visitors use our website and to improve the way our website works. These cookies do not gather personally identifiable information and the information collected is anonymous and only used to improve the performance of our website. We use these cookies to monitor the performance of our website and to make relevant enhancements that could help improve your experience when using our online services.
These remember certain information from the choices you make whilst using our website and may be used to save search settings or login details. The information these cookies collect is anonymous and cannot be used to track your browsing activity on other websites.
We use targeting and advertising cookies so that the adverts we provide to you are more relevant and limit the number of times you see an advert. They may also be used for market research and to help measure the effectiveness of an advertising campaign.
These types of cookies work by remembering the sorts of topics you’ve looked at and using this information to provide our own advertisements or to share the information with other advertisers.
Links to sites provided by others
If you follow a link from our Website/s to another website, please be aware that the owner of the other external websites will have their own privacy and cookie policies for their site. We therefore recommend that you read their policies as we are not responsible or liable for what happens at these external websites.
Using browser settings to manage cookies
Most web browsers allow you to manage cookies via the browser settings.
For example, you may choose to delete existing cookies, prevent your browser from accepting new cookies, have the browser notify you when you receive a new cookie or disable cookies altogether.
By using our Committed Capital Group website, you are agreeing to the placement of cookies on your computer.
Please note: if you share the use of a computer or web-enabled device, accepting or rejecting the use of cookies will affect all users of that computer or web-enabled device.
How Committed Capital Group protect your personal data
Internal data security policies restrict access to personal information to authorised personnel. Committed Capital Group maintains physical, electronic and procedural safeguards that are designed to protect/guard personal data. Any directors, staff, contractors or personnel who violate these policies are subject to disciplinary action up to and including dismissal.
We, use cookies to give you the best possible experience when browsing our website.
Scope of Policy
This Cookie Policy is applicable to the Committed Capital Group and any authorised representatives of Committed Capital Group as they may exist from time to time.