The EU General Data Protection Regulation (GDPR) 2016/679 takes effect on 25th May 2018. VeniCap will adhere to GDPR regulations as applicable as a data controller and data processor.
We are totally committed to making sure that you have protection in terms of privacy. When asking you to provide certain information with which can be used for identification purposes when using this website, you can be reassured that it will only be used in conjunction with this policy statement.
We might change the policy on occasion by updating this page. You are advised to check this page on occasion to make sure that you are happy with anything that changes. This policy will take effect from 25 May 2018.
If you do have any requests about your personal information or any questions with regard to these practices feel free to contact VeniCap at firstname.lastname@example.org
“Personal Data” is Data regarding any identifiable person in so far as this regarding a Client. It means any information relating to someone identified or an identifiable natural person (‘data subject’); an identifiable natural person is someone who is able be identified, directly or indirectly, by particular reference to an identifier, for example a name, an identification number, an online identifier, location data or to one or more factors specifically associated to the physical, genetic, physiological, mental, cultural, economic or social identity of that natural individual.
Acting as a Controller, Joint-Controller or Processor, VeniCap collects personal information:
- from people who visit the Website via the using online forms,
- By obtaining from your product or service provider, if you decide to invest via our services,
- obtained from a different entity where VeniCap provides administration services,
- each time you email details to us.
When we act as a Controller, Joint-Controller or as an agent of other entity who is a Controller of your Data we might gather information about you and then process it; this information might include:
- your name,
- your postal address,
- your email address,
- your telephone number,
- your bank account details,
- your date of birth,
- your wallet ID on our FCA-regulated payment service provider, MangoPay,
- a copy of proof of identity, such as passport or similar document,
- information about investments you have made with VeniCap, such as the amount invested, the product acquired, etc.
If you act on behalf of a company, we might collect, for example:
- Certificate of Incorporation,
- Memorandum and Articles of Association,
- copy of proof of identity (such as passport or similar document) for its shareholders and directors,
- Managerial and administrative contact information (email and phone number).
Use of personal information
VeniCap is in control of and/or processes personal information for the purposes such as:
To comply with our regulatory and legal obligations, we might use your personal data (and if you do not give us this personal data we might not be able to provide you with our services):
- to confirm your identity so we can create your account on our payment services provider Mangopay S.A. and make sure that you’re suitable to use the services provided on the Website,
- to conduct necessary anti-money laundering checks, and the financial crime and fraud monitoring checks associated, in connection with transactions you might be involved in via the Website,
- in terms of investors, to confirm that you are suitable to make investments via the Website according with relevant legislation,
- to allow us to comply with our responsibilities as a regulated financial services business, which includes transaction recording, updates on your investment and fundraising on the Website, as well as other compliance responsibilities, and providing reports to regulators and governmental authorities.
To carry out our obligations under our contracts with you or others, we may use your personal data:
- For the processing and administering of payments and investments that are connected with the services offered on the Website,
- To approve the process of seeking capital for entrepreneurs from the potential investors,
- to facilitate investment transactions,
- For the creation of and maintenance of a register of Clients and investments
We have a legitimate interest in ensuring that the Website and our services operate effectively, and to do this we may use personal data:
- to provide our services (which may include the detection, prevention of security and technical issues), and to monitor, improve and administer the Website,
- to respond to customer support requests and enquiries, and to ensure customer satisfaction, administering orders and any accounting that is related to our Clients,
- to maintain information as a reference tool or more general resource,
- to manage Clients’ accounts with our payment services provider (Mangopay S.A.), this includes the payments made to third parties from an account upon Clients’ instructions,
- to provide information to you about products and services,
- to provide administrative and software support for product providers with whom you’ve invested with or for other entities assisting them with this process.
Your Personal Data may be profiled in kind of automated processing.
VeniCap as a processor
VeniCap is a processor of personal data and acts as an agent on behalf of product or services providers, adhering to the provisions set out in article 5 of the GDPR (that information is processed lawfully and fairly), and in articles 28 and 29 of the GDPR. In particular, we:
- offer sufficient guarantees to implement the correct technical and organisational measures in such a manner that processing will adhere to requirements of the GDPR and make sure your rights are protected;
- make sure that our processing is governed by a contract that binds us with regard to the controller and that reveals the duration and subject matter of the processing, the purpose and nature of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller;
- makes sure that persons authorised to process the personal data commit themselves to confidentiality or are under the correct statutory obligation of confidentiality;
- erase or return all the personal data to the controller at the end of the provision of services relating to the processing.
- Respect the conditions referred to in art. 28 and subsequent articles of GDPR, VeniCap may engage another processor.
VeniCap as a Controller or Joint-Controller of personal data
VeniCap is also a controller of personal data. This means that we decide upon the purposes and means of the processing of personal data. VeniCap is registered as a data controller under the Data Protection Act 1998 with the Information Commissioner’s Office in the UK.
If you have given us your personal details and you wish to change your preferences you need to inform us at the address provided below if you wish to no longer receive information about:
- our products or services,
- products or services offered by other companies within our group,
- products or services offered jointly with or on behalf of other organisations.
As an alternative, you may opt-out of receiving additional information from VeniCap or related third parties at any point by emailing email@example.com, or by phoning us on 0203 006 5050 or by writing to us at: VeniCap, Heron Tower, 110 Bishopsgate, London EC2N 4AY.
VeniCap may also decide to use and share information in aggregate (so that no individuals are identified) for marketing and strategic development reasons.
VeniCap will only disclose personal information to other companies within its group of companies, business partners, government bodies and law enforcement agencies, successors in title to its business and suppliers engaged to process information on its behalf. Your details will never be sent to any third party.
VeniCap may disclose personal data:
- to service providers to VeniCap, we will take precautions to make sure that these service providers have to keep your personal data secure and confidential, in compliance with all legal requirements relevant;
- to HM Revenue & Customs and the Financial Conduct Authority – only if we have reason to believe we must do so by law – or the order of any legitimate government body or arbitration panel;
- in the scenario that we intend to enter into a major corporate transaction, such as a sale of control of our or another business, we may divulge certain aspects of your personal data to potential buyers, underwriters or advisors.
If we share personal data with other entities, we will take precautions to make sure that the recipients of your personal data are required to keep it confidential and secure, in compliance with relevant legal requirements.
Given that the Internet is a global entity, using the Internet to process and collect personal information necessarily involves the transmitting of information on an international basis. Therefore, by browsing the website and communicating electronically with us, you agree and acknowledge to VeniCap personal information being processed in this way.
Subject access rights
You have the right to request from VeniCap, as a Controller, access to and rectification or the deletion of Personal Data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability.
You have a right to details and a copy of the personal information held about you, this includes the purposes of the processing and the categories of personal data. To obtain a copy of the personal information VeniCap holds about you, please write to us at VeniCap, London . A charge of £10.00 will be made by VeniCap for providing this information.
Information on the Data Protection Act 1998 is also on the Information Commissioner’s website at ico.gov.uk.
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