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Privacy policy and cookies

Updated May 2018

At Intermediate Capital Group, 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 investors (including any employees or agents of our investors) and prospective investors;
  • our shareholders;
  • suppliers and prospective suppliers;
  • companies in which our funds make investments (or have previously made investments or are contemplating making investments) and individuals involved in the management of those companies;
  • 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, Intermediate Capital Group, data controller of your personal data. A list of our entities is appended to this document.  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.

INVESTORS AND PROSPECTIVE INVESTORS 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

SHAREHOLDER DATA

  • Contact details: Name, address, email address, phone number
  • 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 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 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

DATA FROM OTHER 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. Such data may also be transferred to, or processed by, MailChimp, the online portal distributor; this will be held in compliance with applicable law. Through the use of cookies, 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.

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?
INVESTOR AND PROSPECTIVE INVESTOR DATA
  • To perform the services that you have asked us to and to conduct our investment activity
  • To perform a contract to which you are a party
  • To answer questions and enter into discussions with you about the services and funds that we offer.
  • To conduct identity and credit checks in line with our obligations under legislation
  • To comply with other legal obligations to which we are subject as a provider of financial services
For seven years after we cease to deal with you

ICG affiliates, 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 (e.g. the Financial Conduct Authority) to the extent required by law.

SHAREHOLDER DATA
  • To manage your shareholding
  • To perform a contract to which you are a party
  • To answer questions and enter into discussions with you
  • To comply with other legal obligations to which we are subject under company law
For seven years after you cease to be a shareholder

ICG affiliates, our group registrars, brokers and other advisors and service providers where we have a legitimate business need for them to know this.

Governmental or regulatory bodies (e.g. Companies House) to the extent required by law.

SUPPLIERS AND PROSPECTIVE SUPPLIERS DATA
  • To consider whether to enter into a contractual arrangement with you
  • To perform a contract to which you are a party
  • To answer questions and enter into discussions with you about the services provided
  • To comply with other legal obligations to which we are subject as a provider of financial services
For seven years after we cease to deal with you ICG affiliates, 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
  • To consider whether to enter into a contractual arrangement with you
  • To perform a contract to which you are a party
  • To answer questions and enter into discussions with you about the investment made
  • To comply with other legal obligations to which we are subject as a provider of financial services
For seven years after we cease to deal with you Governmental or regulatory bodies (e.g. the Financial Conduct Authority) to the extent required by law.
JOB APPLICANT DATA
  • To consider whether to offer your employment
  • To comply with other legal obligations to which we are subject as a provider of financial services
For two years ICG affiliates, 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
  • To engage with you
  • To comply with other legal obligations to which we are subject as a provider of financial services
For seven years after we cease to deal with you Governmental or regulatory bodies (e.g. 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.

See more information on the cookies used by ICG.

Group entities

See the list of Group entities who may process your data.