Who are we?

We are:

Pembroke VCT plc. Our contact details are as follows:

Mail: 3 Cadogan Gate, London, SW1X 0AS.

Email: info@pembrokevct.com

Telephone: +44 (0)20 7766 6900

Oakley Investment Managers LLP.  We are the manager of Pembroke VCT plc.  We can also be contacted using the above details.

The protection of your privacy is important to us. We want to provide a safe and secure service where we deal with your personal information. This means information that identifies you personally such as your name, contact details, “know your client” information or data that can be linked with such information in order to identify you.

This Privacy Policy describes the types of personal information we collect from our shareholders (and from those interested in becoming shareholders), suppliers, clients, professional and business contacts and from visitors and users of www.pembrokevct.com and other websites or applications that may link to this privacy policy (together, the “Websites”), how we use the information, with whom we may share it and the choices available to you regarding our use of the information.

Quick Guide to Contents

What personal information do we collect about you?

We collect and process your information in the following ways:

Information you give us

If you are potential investor in Pembroke VCT plc, then we may collect the following types of information:

  • personal and business contact information (such as name, postal and email address, and telephone number);
  • “know your client” information (such as copy passports, driving licences and utility bills, date and place of birth and National Insurance number); and
  • the information specified in our investor application form, including tax residence, tax identification number, bank account details and information on the amount you wish to invest.

If you are a shareholder in Pembroke VCT plc then, in addition to the information collected at the application stage (see above), we will hold information on the details of your investment in Pembroke VCT plc, including the number and class of shares held, price paid and share transfers made.

In the course of a business relationship with you (or where such a relationship is possible), we may collect the following types of information:

  • personal and business contact information (such as name, postal and email address, and telephone number);
  • “know your client” information (such as copy passports, driving licences and utility bills, date and place of birth and National Insurance number); and
  • billing and payment information.

The types of information we collect on the Websites includes:

  • personal and business contact information (such as name, postal and email address, and telephone number); and
  • other personal information you submit to us via the Websites.

Information we collect automatically

When you visit our Websites or open our emails, we may collect certain information by automated means, such as cookies, web server logs, web beacons and JavaScript.  The information we may collect in this manner includes IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our Websites, and dates and times of Website visits. Please see our Cookie Policy at pembrokevct.com for more details.

Telephone conversations held with our employees may be automatically recorded in accordance with our regulatory obligations.

How do we use your personal information?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

(a)        To provide a requested service or to perform a contract we have entered into with you.

(b)        Where we need to comply with a legal obligation.

(c)        Where it is necessary for our legitimate interests (or those of a third party) (in particular    communicating with you, improving our business and services to you, improving our             Websites and preventing fraud or misuse of our Websites) and your interests and     fundamental rights do not override those interests.

(d)        Where we have your consent.

Information relating to potential investors

We need the information collected from potential investors in Pembroke VCT plc in order to assess whether you (or the legal entity you represent) are a suitable investor in the company, to communicate with you and to process any application you make to acquire shares in the company.  In using your personal information in this way, we are exercising our legitimate interest to attract potential investors and to assess applicants’ suitability as shareholders.  We also have legal obligations to obtain personal information on shareholders (and certain persons associated with them) under anti-money laundering rules.

Information relating to shareholders

We need the information collected in relation to shareholders (and their representatives) of Pembroke VCT plc in order to manage your investment, to ensure your legal rights as a shareholder are respected and to communicate with you.  This use of your personal information is therefore for the purposes of carrying out Pembroke VCT plc’s legal obligations to you as an investor.

Information collected in the course of a business relationship

We may use the personal information described above for the following purposes:

  • where agreed by you, to send you promotional materials, newsletters and other communications and in certain circumstances where we have a legitimate interest in sending you such material by virtue of our business relationship with you and you have not objected to this;
  • to respond to your enquiries in our legitimate interest;
  • to determine whether to acquire or dispose of portfolio companies, and to monitor Pembroke VCT plc’s existing investments;
  • to perform data analyses in our legitimate interest;
  • to communicate to you about, and manage your participation in, events and programmes in our legitimate interest;
  • to operate, evaluate and improve our business in our legitimate interest;
  • to identify and prevent fraud and other illegal activities in our legitimate interest and in some circumstances where we have a legal obligation to do so; and
  • to enforce and comply with legal rights and obligations, including our terms and conditions

Information collected via Websites

In addition, we use information collected through cookies and other automated means (within our legitimate interest to improve our Websites and provide you with a better browsing experience) for purposes such as:

  • customizing visits to our Websites;
  • managing our Websites and other aspects of our business

We may also use the information described above in other ways for which we provide specific notice at the time of collection.

Balancing test

Where we rely on our legitimate interest as a ground for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to the information contained in these balancing tests on request, and can find out more by contacting us using the details below.

How long do we keep your personal information for?

We only retain your information for as long as is necessary for us to use your information as described above, where it is in our legitimate interest, or to comply with our legal obligations. Please be advised that we may retain some of your information after we cease our relationship with you, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes or to comply with financial services regulations.

When determining the relevant retention periods, we will take into account factors including:

(a)        our contractual obligations and rights in relation to the information involved;

(b)        legal obligation(s) under applicable law to retain data for a certain period of time;

(c)         our legitimate interest;

(d)        statute of limitations under applicable law(s);

(e)        (potential) disputes;

(f)         if you have made a request to have your information deleted; and

(g)        guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer needed.

Who do we share your personal information with?

Fundraising

Personal information relating to potential investors in Pembroke VCT plc (and their representatives) will be shared with third parties who provide services to us in connection with fundraising, such as placing agents, professional advisors, receiving agents and share registrars.  These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.

Business processes

In connection with our day to day business processes, we share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors (including in connection with the acquisition, holding and disposal of portfolio companies), share registrars, the company secretary, Pembroke VCT plc’s sponsor, IT consultants carrying out testing and development work on our business technology systems and function co-ordinators. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.

Sharing with group members and affiliates

We may share your personal information amongst our group members and affiliates in connection with the provision of services to you or for internal reasons, such as for business and operational purposes.  Our group members and affiliates will only use your personal information for the purposes described in this privacy policy.

Other instances of sharing

As we continue to develop our business, we will sell or purchase assets, including portfolio companies.  In the event of the sale of a portfolio company, we may disclose the personal information of persons with a business relationship with that company to potential acquirers and their advisers.  If another entity acquires us or merges with us your personal information will be disclosed to such entity.

Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce contracts or applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our websites, our businesses or the public.

What happens if you do not provide us with the information we request or ask that we stop processing your information?

If you do not provide the personal information necessary, or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide services to you, we will not be able to provide these services to you.

Do we make automated decisions concerning you?

No, we do not carry out automated decision making.

Do we use Cookies to collect personal data on you?

To provide better service to you on our websites, we use cookies to collect your personal data when you browse. See our cookie policy at pembrokevct.com.

Do we transfer your personal information outside the EEA?

No, we do not transfer personal information out of the EEA.

What are your rights?

By law, you have a number of rights when it comes to your personal information. Please contact us using the contact details below to exercise any of your rights. Further information and advice about your rights can be obtained from the data protection regulator in your country.

Rights What does this mean?
1.         The right to object to processing You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
2.         The right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
3.         The right of access You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).

This is so you’re aware and can check that we’re using your information in accordance with data protection law.

4.         The right to rectification You are entitled to have your information corrected if it’s inaccurate or incomplete.
5.         The right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
6.         The right to restrict processing You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
7.         The right to data portability You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
8.         The right to lodge a complaint You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.
9.         The right to withdraw consent If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information for marketing purposes.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

How will we contact you?

We may contact you by phone, post, email or social media. If you prefer a particular contact means over another please just let us know.

How can you contact us?

If you have any enquires you can contact us at: info@pembrokevct.com or by writing to us at:

Amjid Zaman
Oakley Investment Managers LLP
3 Cadogan Gate
London
SW1X 0AS