Highgate Tech Fund

Website Privacy Policy

Highgate Tech Fund LLP is a limited liability partnership incorporated in England and Wales (number OC351448) with its registered office at Hyde Park House, 5 Manfred Road, London SW15 2RS, and it operates EIS discretionary management portfolios for its clients. When we refer to ‘we’ in this policy we are referring to Highgate Tech fund LLP. We are a ‘processor’ under the General Data Protection Regulation and the Data Protection Act 2018 (together the ‘Regulations’) in respect of the work we carry out for our clients and the data we hold on their behalf. We respect your privacy and are committed to protecting your personal data.

Visitors to our website
In general you may use this website without giving us any information. However we will collect personal information that you voluntarily provide to us if you fill in a ‘contact us’ form on our website. This information may include your contact details that is your name, email address and telephone number. If you complete our ‘contact us’ form then you agree that Highgate Tech fund LLP may use personal information provided by you in accordance with the purpose for which you provided it, that is for us to contact you and for our internal record keeping. We will not share messages with any other organisations without your prior consent. We do not use cookies on our website.

Please find below our full privacy policy.

Basis for Processing
The basis on which we process your personal data is one or more of the following:
• It is necessary for the performance of our contract with you
• It is necessary for us to comply with a legal obligation
• For our own legitimate interests as long as your rights do not override our interests. For example we might use your data in order to comply with fraud and crime protection
• You have given us your consent (this can be withdrawn at any time by advising our Data Protection Manager) although we do not generally rely on this.

What data will we collect?
We will only collect information from you which is relevant to the matter that we are dealing with. When you contact us about descretionary management portfolios we will collect personal information (eg name, address, email, contact details, telephone number). During the course of our work for you, we may collect additional information, for example in the case of making investments where we will also collect passport and other ID documents, in order to comply with our regulatory requirements under Anti Money Laundering regulations. As shareholders in investee companies we will collect names and addresses. This information is known as ‘personal data’ under the Regulations.

We do not collect information which would be referred to as being in a ‘special category’. Special categories of data are those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation shall be prohibited.

How will we use your data?
We may use your information for the following purposes:
• Provision of discretionary management portfolio services including advising and acting on behalf of clients
• Maintaining our accounts and records

We will not use your data for marketing purposes.

Who will we share your information with?
We will not disclose any information you have provided to any third parties other than:
• Where you have given us specific consent
• Other professional advisors or third parties where necessary to carry out your instructions eg. your bank, solicitors or accountants, or Companies House
• If we need to do this as a result of a legal or regulatory duty to disclose the information.

How long will we keep your information for?
• We will normally keep your information throughout the period of time that we do work for you and afterwards for a period of six years as we are required to by law
• More information is set out in our data retention policy which is available on request from our Data Protection Manager.

Transfers to countries outside the European Economic Area (EEA)
• We may from time to time transfer your personal data to a country outside of the EEA
• Normally this will only happen as part of the performance of your contract with us as per your instructions
• If it is necessary for any other reasons we will ensure that appropriate safeguards are in place at all times.

Security Arrangements
• We shall ensure that all the information that you provide to us is kept secure using appropriate technical and organisational measures
• In the event of a personal data breach we have in place procedures to ensure that the effects of such a breach are minimised and shall liaise with the ICO and with you as appropriate
• We cannot guarantee that any email sent to us will be received or that the contents will remain private during transmission. If you are concerned about this you may wish to consider using other means of communication.
• More information is available from the Data Protection Manager.

What rights do you have?
You have the following rights under the GDPR
• Right to be informed
• Right of access
• Right to rectification
• Right to erasure
• Right to restriction of processing
• Right to data portability
• Right to object
• Rights concerning automated decision-making and profiling.

Right of Access
• You have a right to see the information we hold about you
• To access this you need to provide a request in writing to our Data Protection Manager, together with proof of identify
• We will usually process your request free of change and within 30 days but we reserve the right to charge a reasonable administration fee and to extend the period of time by a further two months if the request is manifestly unfounded or vexatious and /or is very complex
• Full details are available in our data subject access policy which is available on request from the Data Protection Manager.

Right to erasure
• You have a right to ask us to erase your personal data in certain cases (details my be found in Article 17 of the GDPR)
• We will deal with your request free of charge and within 30 days but reserve the right to refuse to erase information that we are required to retain by law or regulation, or that is required to exercise or defend legal claims
• To exercise your right to erasure please contact our Data Protection Manager.

Who can you complain to?
• If you are unhappy about how we are using your information or how we have responded to your request then initially you should contact our Data Protection Manager (dpm@highgatetechfund.com)
• If your complaint remains unresolved then you can contact the Information Commissioner’s Office, details available at www.ico.org.uk