Privacy Policy

About Barcapel.com

This Privacy Policy sets out how we collect, use and protect your personal information.

‘Personal information’ is information which directly identifies or is capable of identifying a specific person.

For the purposes of data protection law, we will be a controller of your personal information. This means we make decisions about how and why your information is used and have a duty to ensure your rights are protected.

The data controller, as defined under the General Data Protection Regulation (“GDPR”) for Barcapel.com is Outrun Services Limited. We are registered as a data controller with the Information Commissioner’s Office and our registration number is A8427312.

The website may contain links to the websites of portfolio companies and third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We recommend you check these policies before you submit any personal information to these websites.

Please take the time to read this Privacy Policy. If you have any questions about this Privacy Policy or our use of your information you can contact us at privacy@barcapel.com

About this Privacy Policy

We take your privacy seriously and are committed to maintaining the privacy and security of information you provide to us, and the choices you have regarding our collection and use of your
information. This Privacy Policy explains how we collect, store and use that personal information and sets out our approach to the GDPR and UK laws such as the Data Protection Act. By visiting our website, you are accepting and consenting to the practices described in this Privacy Policy.

General Storage and Security of your Personal Information

The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). We use Dropbox for Business which has Privacy Shield Certification and is and approved mechanism for the transfer of data outside of the EEA. By the using the website and/or sending us any information directly or via the website, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. When you submit your data to us, we use industry standard Secure Sockets Layer (“SSL”) encryption technology to guard your information.

Once we have received your information, we will use strict procedures and security features put in place to protect our paper based and computerised systems from loss and misuse, and only allow access to them when it is absolutely necessary to do so and then under strict guidelines as to what use may be made of the personal information contained within them. Our staff receive data protection training and we have a set of detailed data protection policy procedures which personnel are required to follow when handling personal data.

Unless specified in more detail below, we will keep your information stored on our systems for as long as it takes to provide the services to you. The third parties we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you.

We will not store your information for longer than is reasonably necessary or required by law. We regularly review what data we have and delete that which is no longer necessary. The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation.

We cannot absolutely guarantee the security of the internet or external networks or your own device. Accordingly, any online communications (e.g. information provided by email or through our website) are at your own risk. You accept the inherent security risks of providing information online over the Internet and will not hold us responsible for any breach of security unless this is due to our negligence or willful default.

Business Contacts

As a part of our day to day operations we meet large numbers of business contacts at meetings and receive emails about investment opportunities. We are likely to receive and store personal
information on those we meet.

If you have had contact with us, for example through emailing us or meeting a colleague, it is likely that we will want to make a note of that email or meeting and may store limited amounts of personal information relating to you, such as your name, job title, employer organisation and contact details.

We will collect and store this personal information for the purposes of:

  • maintaining a record of contacts;
  • providing periodic business updates;
  • drawing to your attention working opportunities which may be of mutual benefit to us as described below; and/or
  • organising meetings with you.

The personal information we hold about business contacts may be shared with:

  • professional advisors; and/or
  • companies who hold or process personal information on our behalf, or cloud based
    products such as Dropbox Business.

The legal basis for collecting and storing such personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.

Personal Information of Suppliers and Professional Advisors

As a part of our day to day operations we are likely to receive and store personal information to enable us to buy office and other supplies or engage with professional advisors.
If you are a supplier or professional advisor to us, we will capture and use limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation and contact details. We will store this personal information for the purposes of administering and maintaining records of services or advice we have received, and commissioning further services.

The personal information we hold about suppliers and professional advisors may be shared with:

  • other professional advisors (Midmar Capital LLP, NCM Fund Services Limited, EY, Addleshaw Goddard); and/or
  • companies who hold or ‘process’ personal information on our behalf, or cloud based
    products such as Dropbox Business

We store and process information in this way because it is necessary to:

  • perform a contract to which you are likely to be a party;
  • comply with a legal or regulatory obligation; and/or
  • protect our legitimate interests in running and promoting our business.

Personal Information Collected During Investment Presentations

We are likely to receive and store personal information as part of the investment evaluation process. If you send or otherwise present to us an overview of your company (a “pitch”), we may store personal information relating to you in our Client Relationship Management (“CRM”) or other such system. This may include your name, email address and gender. This data is used for in-house analysis and for any analysis which we may share externally, all information will be anonymised and aggregated before being shared. The pitch deck will be kept on file for future business opportunities.

If we decide to offer a term sheet, further information collected and stored might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out.

We collect and store this information for the purposes of:

  • evaluating a transaction and your role in it;
  • executing transactions;
  • managing an investment once made;
  • maintaining records of investments;
  • meeting regulatory and legal obligations e.g. KYC checks;
  • safeguarding our legal rights and interests;
  • seeking and receiving advice from our professional advisors, including accountant’s lawyers and other consultants; and/or
  • providing periodic business updates, as described below.

The personal information we hold about the members of a management team may be shared with:

  • professional advisors, such as accountants, lawyers or other consultants;
  • financial intermediaries;
  • credit and other reference agencies;
  • other persons who have an interest or involvement in, or who are considering an interest or involvement in, a transaction, including co-investors, other providers of finance and
    investors in our funds; and/or
  • companies who hold or ‘process’ personal information on our behalf, or cloud based products such as Dropbox Business.

We store and process information in this way because it is necessary to:

  • perform a contract to which you are likely to be a party;
  • comply with a legal or regulatory obligation; and/or
  • protect our legitimate interests in running and promoting our business.

Personal Data Collected During Visits to Our Website

When you interact with our digital platforms, we may also automatically collect the following information about your visit. This is primarily to help us better understand how people use our digital platforms and to enable us to create better content and more relevant communications:

  • your browser type, versions and plug-ins, and your operating system;
  • your journey through our digital platform, including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information; and/or
  • information collected in any forms you complete.

Sensitive or Special Category Personal Data

We avoid wherever possible receiving information on race, religion, political views and your mental or physical health.

Your rights

We want you to remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:

  • where data is processed on the basis of consent, the right to withdraw that consent;
  • the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal data;
  • the right to have inaccurate data rectified;
  • the right to object to your data being used for marketing or profiling, or on the basis of our or a third party’s legitimate interest;
  • the right to restrict how your personal information is used; and
  • the right to be forgotten, which allows you to have your data erased in certain circumstances (though this is not an absolute right and may not apply if we need to continue using the information for a lawful reason).

If you would like to exercise your rights, please contact us at privacy@barcapel.com

Sometimes you may be asked to provide proof of identity before we show you your personal information so that we can prevent unauthorised access.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).

We may update this Privacy Policy at any time. We encourage users to check this page frequently for any changes to stay informed about how we are helping to protect the personal information we collect.

Where to Make A Complaint

If you have a complaint regarding any aspect of your personal data or this privacy policy, please write to us at the address below.

The Data Controller
Outrun Services Limited
Kemp House
160 City Road
London
EC1V 2NX

If you are still not satisfied with the outcome of your complaint, you may write to the Information Commissioner’s Office at the following address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

You can also contact the Information Commissioner’s Office using their online form: https://ico.org.uk/global/contact-us/email/

Legal Disclosure

In some cases, we may be required to disclose your personal information to comply with legal requirements.

Cookies

Our Website uses cookies. A “cookie” is a small file of letters and numbers that is sent to your computer by a website and automatically saved on your computer by your web browser (e.g. “Google Chrome”). Each time you request a page from the Website, your web browser sends this cookie back to the Website server.

The cookies we use are “analytical cookies” sent by Google Analytics. They allow us to recognise and count the number of visitors and to recognise and track which parts of our Website you visit when you are using our Website. This helps us to improve the way our Website works, for example by making sure visitors are finding what they need easily.

We may also use the information collected from our use of cookies to estimate our audience size, analyse trends and general usage patterns of our Website, optimise our Website, and for other research and marketing purposes. This is statistical information and does not identify any individual.

An overview of Google Analytics is available at http://www.google.co.uk/intl/en/analytics/privacyoverview.html

You are not obliged to accept cookies. If you wish, you can set your browser to notify you before you receive a cookie, so you have the chance to accept it and you can also set your browser to refuse to receive or send all cookies.

The website www.allaboutcookies.org (run by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users.

Google Analytics also uses web beacons (also known as web bugs). A “web beacon” is a clear picture file which keeps track of your navigation through the website. Turning off the Website’s cookies as detailed above will prevent web beacons from tracking your specific activity. The web beacon may still record an anonymous visit from your IP address, but unique information will not be recorded.

If you wish to opt out of being tracked by Google Analytics across all websites you can visit http://tools.google.com/dlpage/gaoptout and download the Google Analytics Opt-out Browser Add-on.

By using our Website without disabling cookies you are consenting to our use of cookies and web beacons as described in this policy.

More information on cookies and web beacons is available at the website www.allaboutcookies.org.

This Privacy Policy was last updated on 17th December 2018.

Barcapel Equity is an appointed representative of Midmar Capital LLP, which is authorised and regulated by the Financial Conduct Authority, in respect of UK investment advisory and arranging activities.

Address

Find Us

Barcapel Equity
Kemp House
160 City Road
London
EC1V 2NX
United Kingdom

E contact@barcapel.com

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