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ICG Enterprise Trust plc Privacy Policy
At ICG Enterprise Trust plc, we are committed to maintaining the confidentiality, integrity, and security of the personal information of all individuals who engage with us in any capacity whether as shareholder, investor, prospective investor or prospective employee. We have designed this privacy policy to inform you about the way in which we manage your personal data.
In the course of providing you with funds and services, we collect personal data from:
- our shareholders and prospective shareholders;
- suppliers and prospective suppliers;
- companies or funds in which our fund make investments (or have previously made investments or are contemplating making investments) and individuals involved in the management of those companies or funds;
- job applicants; and
- any other person who provides their details to us or otherwise contacts us or is contacted by us by phone or email.
This makes us, ICG Enterprise Trust plc, data controller of your personal data. Accordingly, we owe you certain obligations as set out below.
What data do we collect?
We may hold some of the below types of data on you.
| SHAREHOLDERS AND PROSPECTIVE SHAREHOLDERS DATA |
| Contact details: Name, address, email address, phone number, job title, employer or associated entity |
| Financial information: bank account details, payment details and confirmations |
| Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations. |
| Date of birth |
| National Insurance number or similar national registration number |
| Identity documents (including all data): Passport, driving licence, utility bill, other proofs of address or identity |
| Any additional data voluntarily provided by you |
| SUPPLIERS AND PROSPECTIVE SUPPLIERS DATA |
| Contact details: Name, address, email address, phone number, job title, employer or associated entity |
| Financial information: bank account details, payment details and confirmations |
| Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations. |
| Any additional data voluntarily provided by you |
| INVESTEE, FORMER INVESTEE AND PROSPECTIVE INVESTEE DATA |
| Contact details: Name, address, email address, phone number, job title, employer or associated entity |
| Financial information: bank account details, payment details and confirmations, salary and bonus details |
| Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations. |
| Employee HR records |
| Date of birth |
| National Insurance number or similar national registration number |
| Identity documents (including all data): Passport, driving licence, utility bill, other proofs of address or identity |
| Any additional data voluntarily provided by you |
| JOB APPLICANT OR DIRECTOR APPLICANT DATA |
| Contact details: Name, address, email address, phone number, job title, employer or associated entity, education and employment history |
| Financial information: current salary and package |
| Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations. |
| Date of birth |
| National Insurance number or similar national registration number |
| Identity documents (including all data): Passport, driving licence, utility bill, other proofs of address or identity and right to work documentation |
| Any additional data voluntarily provided by you |
| PERSONS WHO PROVIDE THEIR DETAILS TO US OR WHO WE CONTACT |
| Contact details: Name, address, email address, phone number, job title, employer or associated entity |
| Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations. |
| Any additional data voluntarily provided by you |
Unless (a) we separately obtain your freely given, specific, informed and unambiguous consent for use for a specific purpose or (b) such collection is required by law or regulation, we do not collect from you any sensitive personal information (which includes, for example, information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, biometric data or health).
How do we collect personal data?
The personal data you submit to us may come in a variety of physical or electronic formats. Through the use of cookies (listed below), we also collect generic information about the way in which you use our internet website. Because of the financial services that we provide, we are also required by law to record certain telephone conversations held by our employees.
Data collected
We may automatically process some technical data such as your Internet Protocol (IP) address to identify what companies have interacted with the website. This processing only identifies a company name and will not be used to identify an individual.
What do we do with your data?
We aim to collect only personal information that we can justify we need for our legitimate business purpose in order to provide to you our financial services. We collect, store and process your personal information for the following purposes:
| TYPE OF DATA | PURPOSE FOR COLLECTING | DATA RETAINED FOR HOW LONG? | DISCLOSED TO WHICH THIRD PARTY? |
| SHAREHOLDER DATA |
|
For seven years after you cease to be a shareholder | Our managers, ICG Alternative Investment Limited (“ICG AIL”), our registrars, brokers and other advisors and service providers where we have a legitimate business need for them to know this. Governmental or regulatory bodies (eg Companies House) to the extent required by law. |
| SUPPLIERS AND PROSPECTIVE SUPPLIERS DATA |
|
For seven years after we cease to deal with you | ICG AIL, our fund administrators and lawyers and other advisors and service providers where we have a legitimate business need for them to know this. |
| INVESTEE, FORMER INVESTEE AND PROSPECTIVE INVESTEE DATA |
|
For seven years after we cease to deal with you | ICG AIL, our fund administrators and lawyers and other advisors and service providers where we have a legitimate business need for them to know this Governmental or regulatory bodies (eg the Financial Conduct Authority) to the extent required by law. |
| JOB APPLICANT AND DIRECTOR APPLICANT DATA |
|
For two years | ICG AIL, our fund administrators and lawyers and other advisors and service providers where we have a legitimate business need for them to know this. |
| DATA FROM OTHER PERSONS WHO PROVIDE THEIR DETAILS TO US OR WHO WE CONTACT |
|
For seven years after we cease to deal with you | Governmental or regulatory bodies (eg the Financial Conduct Authority) to the extent required by law. |
Our arrangements with parties to whom we need to disclose your data
We may share your personal data with the third parties described above where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so or where required by law to do so.
Our Affiliates are our group companies listed in the appendix hereto.
All third parties (including our Affiliates) to whom we disclose your personal data are also legally obliged to take appropriate security measures to protect your personal information in line with ICG’s data protection and security policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Transfer of personal data outside the European economic area
We may transfer the personal information we collect about you to the following countries outside the EEA order to perform our contract with you or to continue the operation of our business:
- Hong Kong, United States, Canada, Singapore, Japan, South Korea, Australia
To ensure that your personal information receives an adequate level of protection we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection:
- The use of binding Corporate Rules for inter-group transfers
- The adoption of standard contractual clauses where required
- The EU/US Privacy Shield
What are your rights?
Changes to your personal data
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us (for example if you change your email address or if you wish to cancel a request for information).
Under certain circumstances, by law you have the right to:
| Request access to your personal information (commonly known as a "data subject access request") | This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. |
| Request correction of the personal information that we hold about you | This enables you to have any incomplete or inaccurate information we hold about you corrected |
| Request erasure of your personal information | This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). |
| Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. | You also have the right to object where we are processing your personal information for direct marketing purposes. |
| Request the restriction of processing of your personal information | This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. |
| Request the transfer of your personal information to another party. | This enables you to seek a transfer of your personal data to a third party elected by you. |
| Complain to the Information Commissioner’s Office (ICO) or other EU domiciled Supervisory Body | If you have a complaint about the way in which we are managing and processing your personal data. |
How we look after your data
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and the ICO of a suspected breach where we are legally required to do so.
Changes to this policy
If we change our privacy policy we will post the changes on this page, and may place notices on other pages of the website, so that at all times you may be aware of the information we collect and how we use it.
If you have any questions about this privacy notice, please contact us at icgservicedesk@icgam.com.
Use of Cookies by ICG
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why.
Persistent or Necessary (3 cookies)
| Name | Provider | Purpose | Expiry | Type |
| ARRAffinity | icg-enterprise.co.uk | Used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session. | Session | HTTP cookie |
| smContent |
icg-enterprise.co.uk |
Store the user's cookie consent state for the current domain | 1 year | HTTP cookie |
| accept_disclaimer | icg-enterprise.co.uk | Store the user's disclaimer consent state for the current domain | Session | HTTP cookie |
Analytics (3)
| Name | Provider | Purpose | Expiry | Type |
| _ga | icg-enterprise.co.uk | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 2 years | HTTP cookie |
| _gat | icg-enterprise.co.uk | Used by Google Analytics to throttle request rate. | Session | HTTP cookie |
| _gid | icg-enterprise.co.uk | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | Session | HTTP cookie |
How do we use Your IP address?
We use your IP address to track traffic flows and to make our websites easier for you to use and to better understand how our websites are used. This IP address is sent to an external service provider (Investis) to help us understand this usage.
How do I change my cookie settings?
Your consent applies to the following domains: www.icg-enterprise.co.uk
You can view and change your cookie settings at any time.
We sometimes embed photos and video content from websites such as Flickr, Instagram, Twitter, Vimeo, and YouTube. Pages with this embedded content may present cookies from these websites.
Similarly, when you use one of the share buttons on this website, a cookie may be set by the service you have chosen to share content through. We do not control the dissemination of these cookies and we will not block cookies from those websites. You should check the relevant third-party website for more information about these.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit tools.google.com/dlpage/gaoptout.
About third party links on our website
ICG Enterprise Trust offers links to other third party websites that may be of interest to our website visitors. The links provided in our website are provided solely for your convenience and may assist you in locating other useful information on the Internet. When you click on these links you will leave the ICG Enterprise Trust’s website and will be redirected to another site. These sites are not under the control of ICG Enterprise Trust.
ICG Enterprise Trust is not responsible for the content of linked third party websites. We are not an agent for these third parties nor do we endorse or guarantee their products. We make no representation or warranty regarding the accuracy of the information contained in the linked sites. We suggest that you always verify the information obtained from linked websites before acting upon this information.
Also, please be aware that the security and privacy policies on these sites may be different than ICG Enterprise Trust’s policies, so please read third party privacy and security policies closely.
If you have any questions or concerns about the products and services offered on linked third party websites, please contact the third party directly.