Crowd for Angels (UK) Limited, a company incorporated in England and Wales under No. 03064807 whose registered office is at 8 Little Trinity Lane, London, United Kingdom, EC4V 2AN hereinafter referred to as ‘CfA’ or ‘We’ have created this privacy statement (‘Statement’) in order to demonstrate our firm commitment to the privacy of the details that You provide to us when using Site and the CfA Platform. In this Statement, references to ‘You’ and ‘Your’ are references to the CfA User who may or may not be a registered CfA Member. When You use the Site, You are consenting to the practices set forth in this Statement. Unless otherwise indicated, all definitions used in the Membership Agreement or Membership & Nominee Agreement as applicable shall apply to this Statement.
2. Your Acceptance of the Statement
This Statement governs Your use of the Site and the CfA Platform, including any dispute concerning privacy. By using the Site and the CfA Platform, You accept this Statement in full. You should read the Statement carefully and ensure that You understand its effect before proceeding to use the Site. We reserve the right to modify this Statement at any time due to a change in the law or otherwise without notice by posting the changes on this page. Your continued use of any portion of the Site following the posting of the updated Statement will constitute Your acceptance of the changes. If we make any material changes, We will notify You by email.
3. Collecting Your Data
As part of the process of using the Site and the CfA Platform, We may collect certain data from You including but not limited to
- Your contact details upon registration to become a CfA Member including Your first and last names, email address and other CfA Account details;
- Information required to create Your CfA Profile and CfA Login;
- Pitch Information to be provided by an Investee Company in respect of the Pitch Application and the Pitch Creation Form;
- Your payment information such as credit or debit card details via the Site;
- Your visits to the Site, the resources and CfA Content that You download;
- Information that You provide to us by written communication by post or email;
- Information that You provide to CfA or a CfA Member via the CfA Discussion Board;
- Information that You provide to us when We speak to You by telephone. We may keep a record of the information that You share with us;
- Information that You provide to us by completing surveys; and,
- Details of investments You carry out as a CfA Investor through the Site and the CfA Platform and the information We provide to Your Nominee to procure the Nominee Services.
4. Collecting Your Financial Data
As a CfA Investor, when You wish to deposit investment funds in Your CfA Account, You do so in one of two (2) ways i.e. by bank transfer or by way of direct debit via a third party partner i.e. Go Cardless. For this, You will be required to provide Your bank details in order for payment to be processed, for example, You will be required to provide Go Cardless with Financial Data in order to authorise payment. When You wish to transfer monies via the Site, Your consent is given to provide Your Data necessary to process the payment with CfA to this third party directly. To make and complete the transaction via a third party such as Go Cardless, their policies shall be applicable to You. We will not share Financial Data with any other third parties without Your prior consent.
5. Other Data
Other de-personalised data which does not record Personal Data or Financial Data as such, rather information such as the date of the visit to the Site, the path taken, the browser used, the IP address etc is used primarily to aid the technical administration of the Site, to better understand how the Site is functioning for CfA Visitors and CfA Members and to draw conclusions upon demographic information.
6. How is Your Data Used?
You acknowledge that Your Data may be used by CfA to contact a CfA User by post, phone or by electronic mail when necessary in connection with CfA Membership (including CfA Login and CfA Account), the CfA Listing process and the investment process in general.
From time to time, CfA may contact You by electronic mail by way of sending You periodic marketing emails with the latest Pitches, Updates, funding news and Lead Director comments or any other newsletter or information or offers regarding upcoming products, promotions, services, specific events, case studies or customer surveys. We will not e-mail you for marketing purposes unless you have given us your consent to do so or if we have a legitimate interest in doing so (for example, if we already have a relationship with you as a customer and we are letting you know about a similar product to one previously purchased).
If Data has been passed to third parties with Your consent, You may need to contact them separately if You change Your mind in relation to their use of Your Data.
The other principal purposes for which We process and store Your Data are:
- To confirm Your identity in order to create Your CfA Membership, CfA Login and CfA Account and to ensure that You satisfy the CfA Membership Criteria to use the services provided on the CfA Platform.
- To conduct required anti-money laundering checks on You in connection with certain transactions You may conduct via the Site.
- In the case of an Investee Company, to review and approve Your Pitch in order to have Your CfA Listing posted, promoted and published on the CfA Platform.
- In the case of potential CfA Investors looking to allocate funding to an Investee Company in respect of a Pitch, to confirm that You are authorised and eligible to make investments through the CfA Platform.
- To monitor, improve and administer the Site and the CfA Platform.
- To enable us to comply with our legal and regulatory obligations.
- To be able to pass Your Date on to third party companies or service providers in respect of Legal Services and Nominees Services in particular (including Innvotec Limited, the company who is authorised by the FCA to hold investment monies and its subsidiary, Innvotec (Nominees) Limited who acts as Nominee (‘CfA Partners’) for the sole purpose of fulfilling the services required throughout the investment process. We will take reasonable precautions to ensure that these parties are obligated to keep confidential any of Your Data that they use.
7. Who has access to Your Data?
To minimise the risk of unauthorised access to Your Data, We use some of Your Data to authenticate You when using the Site. For our daily operations, We use the services of third parties to provide some of our business and operational functions. Some of these services are provided by our CfA Partners. For the avoidance of doubt, Your Data is used solely by CfA (and its group companies and the CfA Partners) for the sole purpose and to the extent necessary to enable CfA to effectively provide You with all the functionality required by the CfA Platform throughout the life of the investment process) and is not shared with any person or company without Your express consent. Any Data that is held with CfA shall be retained in accordance with the Data Protection Act 2018, General Data Protection Regulation (GDPR) and related legislation and/ or our retention and destruction policy culminating in its permanent deletion.
Disclosure of Your Data in Compliance with Laws
You should be aware that We may release Your Data when We believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transacted with CfA or a CfA Partner, or to protect the rights, property or safety of CfA, CfA Members or third parties. This includes any requirements of the Financial Conduct Authority (“FCA”).
Transfer of Your Data outside of the EEA
From time to time, We may transfer Your Data to a related company, agent or contractor in order to improve our services or to assist our security, credit risk or fraud protection activities. Such companies may be located outside of the EEA and You consent to the transfer of Your Data to such companies for the purposes set out here in accordance with this Statement and as permitted by the Data Protection Legislation from time to time.
Transfer of Data in the Event of the Sale of Crowd for Angels or its Assets
In the event that Crowd for Angels is sold or transfers some of its assets to another party, Your Data could be one of the transferred assets. If Your Data is transferred, its use will remain subject to this Statement. Your Data will be passed on to a successor in interest in the event of a liquidation or administration of CfA.
Other Sites and their Privacy Policies and Cookie Policies
The Site may contain links to other websites. CfA is not responsible for the privacy practices or the content of such websites or for the privacy policies, cookie policies and practices of other third parties, so You should be careful to read and understand those website policies independently.
8. Security of Your Data
We endeavour to take all reasonable steps to protect Your Data, including the use of encryption technology. When You enter sensitive information such as bank account information, We encrypt the transmission of that information using secure socket layer technology (SSL). However, We cannot guarantee the security of any Data you disclose online. In using the Site, You accept the inherent security implications of engaging in transactions over the Internet, and You agree that You will not hold CfA responsible for any breach of security unless We have been grossly negligent or in wilful default. If You have any questions about security on our Site, You can contact us at [email protected]. You acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect Your Data, We cannot ensure or warrant the security of any Data You transmit to us, via, to, or from our Site. You accept that CfA cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. You transmit all such Data at Your own risk.
10. Communications between You and Crowd for Angels
We may intercept, record and/or monitor any communication(s) (including telephone calls or other electronic communications) between You and us. We may do so in order to resolve queries in the future and for the purposes of ensuring security, staff training and complying with our regulatory and legal responsibilities.
11. Opting Out
If You do not wish to be contacted by CfA in respect of future marketing communications (excluding any mandatory communications which are a necessary part of being able to use the CfA Platform which cannot be opted out of), We will give You the opportunity to unsubscribe to the receipt of such communications in every electronic mail communication that We send You.
12. Obtaining Copies of Your Data
You can see some of the Data We hold about You in the "My Profile" section of the Site (if You are a CfA Member). In the event that You wish to see a copy of all of Your Personal Data held by us, please write to:
Crowd for Angels (Data Protection Officer)
8 Little Trinity Lane
If You request a copy of Your Data, We may charge You a small administrative fee to cover the costs of providing it to You.
We will retain Your information for as long as Your CfA Membership is still valid or as needed to provide You with our services. We will retain and use Your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, which may require varying retention periods.
13. Changes to Your Data
If You see that any of Your Data that is included in the "My Profile" section of the Site is inaccurate, please revise or update it using the functionality provide by the Site where applicable and permissible by the CfA Platform. Alternatively, You may contact us at [email protected] to correct or delete the information. It is Your responsibility to ensure that any Data You have provided to us remains accurate and to notify us if there are any changes in Your Data.
We have made every effort to ensure that this Statement adheres strictly with the relevant provisions of the Data Protection Legislation and other applicable laws. However, in the event that any of these provisions are found to be unlawful, invalid or otherwise unenforceable, that provision is to be deemed severed from this Statement and shall not affect the validity and enforceability of the rest of the Statement.
15. No Waiver
In the event that either You or We fail to exercise any right or remedy contained in this Statement, that does not mean that You or We (as applicable) have waived that right or remedy and so shall not be construed as a waiver.
16. Complaints or Queries
CfA tries to meet the highest standards when collecting and using Data. For this reason, We take any complaints We receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of Data is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. This Statement does not provide an exhaustive detail of all aspects of CfA’s collection and use of Data. However, We are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below or to our customer support team by email at [email protected]. If You are not happy with the way in which Your Data is being handled by CfA, You can complain to the Information Commissioner whose details can be found at: https://www.ico.org.uk/
17. Choice of Law
This Statement shall be governed by and construed in accordance with the laws of England and Wales.
You agree to submit to the exclusive jurisdiction of the courts of England and Wales. This means that if You want to bring a legal action against us, or we want to bring a legal action against You, it must be done in one of these courts.
19. Forum (CfA Discussion Board)
Our Site offers a publicly accessible Discussion Board for CfA Members only. You should be aware that any information You provide in these areas may be read, collected, and used by other CfA Members who access them. To request removal of Your UGC or Date, please contact us at [email protected]. In some cases, we may not be able to remove the same once published, in which case We will let You know if We are unable to do so and why.
We keep our Statement under regular review. This Statement was last updated on 04 April 2018.