Privacy Policy
About this privacy policy
This Privacy Policy explains how we will use the personal data you provide to us. In this Privacy Policy references to "us" and "we" are references to both AQ1443 Ltd (trading as Thema) and EDT Ventures Limited.
How to contact us
If you have any questions about this Privacy Policy, or about how we use personal data, please contact us using the following contact details:
AQ1443 Limited
Address: 843 Finchley Road, London, NW11 8NA, United Kingdom. Contact number: 07521741116. Email address: olivia@aq1440.com
EDT Ventures Limited
Address: The Stables, 23b Lenten Street, Alton, Hampshire, England, GU34 1HG. Contact number: 07521741116 Email address: info@edtventurecapital.com
What personal data do we collect?
We collect certain personal data which is provided to us when the Application Form is completed. This includes, for example, individuals' names, addresses, job titles, dates of birth, tax details and financial details. We may also collect other personal data to process the Application, including for example, passport information and/or other verification documentation as a part of our anti-money laundering, FATCA and CRS reporting and know-your-customer compliance checks.
How do we use the personal data we collect?
We may use the personal data provided to us for the following purposes:
to assess the Applicant's eligibility to subscribe for interests in the Fund;
to allow the Applicant to participate in the Fund;
to provide important information about the Fund, such as annual and quarterly reports, drawdown notices, invitations to investor meetings, and requests for investor consents;
to make distributions or other payments;
to provide information, products and services which have been requested from us;
to improve our business;
to provide information about products and services which we think may be of interest;
to comply with any legal or regulatory obligations, requirements or requests; or
to protect, defend or enforce our legal rights, or those of others.
What is our legal basis for using personal data?
We will only use personal data if we have a lawful basis for doing so. In particular, we will only use personal data:
to perform our contractual responsibilities. For example to process applications to participate in the Fund, to properly manage the Fund, to provide annual and quarterly reports and to pay distributions (the purposes set out in paragraphs 4(a) to 4(e) of this Appendix fall under this legal basis);
to comply with legislation, including for tax compliance purposes such as FATCA and CRS reporting and for compliance with anti-money laundering and know-your-customer legislation (the purpose set out in paragraph 4(h) of this Appendix falls under this legal basis);
if it is in our legitimate interests to use it (for example if we need to use it to develop or improve our business, to provide information about products and services which we think may be of interest, or if we wish to sell the whole or part of our business to a third party) (the purposes set out in paragraphs 4(f), 4(g) and 4(i) of this Appendix fall under this legal basis); or
if we have obtained the relevant individual's consent to use their personal data. If we are relying on the individual's consent to use their personal data, this will be made clear at the time the personal data is collected. If we rely on consent, the individual may withdraw their consent at any time.
Marketing
We strive to provide Applicants with choices regarding certain personal data uses, particularly around marketing and advertising.
Applicants have entered into negotiations to become investors, and we may therefore send Applicants marketing messages related to potential investments, as they are deemed to have provided a "soft opt-in" to such marketing messages. Applicants can opt-out at any time, as set out below.
Third Party Marketing
We will get express opt-in consent before we share personal data with any third party for marketing purposes.
Opting Out
Applicants can ask us or third parties to stop sending marketing messages at any time by emailing us at info@edtventurecapital.com.
Where Applicants opt out of receiving marketing messages, they will continue to receive non-marketing communications relating to their investments.
We may transfer personal data outside the UK or the EEA
We may need to transfer personal data outside the UK or the EEA in order to manage the Fund and process applications to participate in the Fund. This may include, for example, transferring personal data to our suppliers, legal advisers, consultants and subcontractors such as third party process agents or depositaries operating outside the UK or the EEA, to other investors in the Fund, or to tax and/or regulatory authorities or to a court of law outside the UK or the EEA. If we transfer personal data outside the UK or the EEA, we will only do so where one of the following applies:
there is an adequacy decision by the UK in the case of transfers out of the UK or by the European Commission in the case of transfers out of the EEA which means that the recipient country is deemed to provide adequate protection for such personal data;
where the transfer of personal data is to a member of our group, and we have in place binding corporate rules with such member which safeguard the personal data and which have been validated by the Information Commissioner's Office (ICO) or the relevant supervisory authority;
where we have in place standard model contractual clauses with the recipient which have been approved by the European Commission (or the UK in due course). These model contractual clauses include certain safeguards to protect the personal data;
if such transfer is necessary for the performance of a contract we have with an individual investor to whom the personal data relates, or if it is necessary to enable us to carry out steps at such individual's request with a view to entering into such a contract;
if such transfer is necessary to enable us to enter into, or perform, a contract we may have with a third party, in order to provide services relating to the Fund, provided such transfer is in the interests of the relevant individual; or if the individual to whom the personal data relates has entered into, or wishes to enter into, a contract with a third party and it is necessary for us to transfer the personal data in order to enable the individual to do so; or
if the transfer is necessary for the establishment, exercise or defence of legal claims.
If you want to find out more about how we transfer personal data outside the UK or the EEA, please contact us using the contact details set out above.
With whom do we share personal data?
We may share personal data with third parties in the following circumstances:
With third parties which provide services to us, including for example, technical, IT, hosting, logistical, processing, legal, depositary or administrative services, and specifically to the Investment Adviser, the Administrator, the depositary of the Fund, and the Fund's Counsel;
if we are required to do so for legal or regulatory reasons, including defending our legal rights or those of others;
with members of our group, which are involved in the management or administration of the Fund, or which provide services to us (such as IT services); or
for corporate reasons. For example, we may need to share personal data with third parties if we restructure our business or if a third party wishes to acquire the whole or part of our business.
Data Security
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business-need to know. They will only process 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 individuals and any applicable regulator of a breach where we are legally required to do so.
For how long do we keep personal data?
In general, we keep individuals' personal data for as long as they or their organisation (as applicable) participates as an investor in the Fund. We may need to keep some personal data for longer than this for legal, compliance or business reasons.
What choices and rights do individuals have regarding your personal data?
Individuals whose personal data we process may contact us to request that we:
confirm whether or not personal data about them is being processed;
provide them with further details about how we process their personal data;
provide them with a copy of any data we hold about them;
update/correct their personal data;
delete any personal data which we hold about them;
restrict the way that we process their personal data;
consider any valid request to transfer their personal data to a third party provider of services (data portability); and/or
consider any valid objections they may have to the use of their personal data.
If an individual wishes to make a request to exercise any of the rights listed above, they should contact us using the contact details set out above.
We will consider all such requests and provide our response as soon as we can. Please note, however, that certain personal data may be exempt from such requests in certain circumstances, which may include if we need to keep processing the personal data for our legitimate interests or to comply with a legal obligation. Please note that we may request any such information as is necessary to confirm the identity of the individual making the request.
Queries and complaints
If you have a queries or complaints about how we use personal data, we would always prefer that you contact us first. However, you may also make a complaint to the relevant data protection authority. In the United Kingdom, the relevant data protection authority is the ICO. A link to the ICO's website is below.
If you are unsure which data protection authority to contact, please contact us using the contact details above.
Changes to this privacy policy
We may change this privacy policy from time to time. Applicants will be notified of any significant changes we make to our privacy policy, using the contact details provided in this Application Form.