We collect different types of information online:
- About you – the information you type in
- About how you use our site – we track this using cookies
The main ways we use this information:
- To tailor how our site can help you
- To fulfil your requirements and deliver what you have asked us for
- To treat you more personally
- To maintain your records
- To send you appropriate marketing communications
- For analysis about how each of our customers use the site
The main way we let other selected companies use this information:
- To help fulfil your requirements and help deliver what you have asked us for
References to “BCI” or “us” or “we” or “our” are references to BCI Finance Limited (company number 8592577 whose registered address is at 1 Hammersmith Broadway, London, W6 9DL. References to “you” are references to you as the user of our Investment Management and Advisory services (our “Services”).
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
The Product is not intended for children and we do not knowingly collect data relating to children.
The Product is developed by BCI who is the controller of, and is responsible for, your personal data. This notice is intended to cover all of the Funds or entities to which BCI Finance is either the manager of or advisor to. This includes but is not limited to the following:
*BCI Credit Opportunities Fund
*BCI Alpha ICC (incorporating Alpha 1, Alpha 2, Alpha 3)
**BCI International Limited
BC Venture Builder Club
BC Venture Co-investment Club
*These funds are considered as Data Controllers in respect of the Data that they hold or which is held on their behalf.
**BCI International Limited is the Investment Manager of the BCI Credit Opportunities Fund and BCI Alpha ICC. BCI International Limited is the Data Processor on behalf of the funds which it manages.
Full name of legal entity:
BCI Finance Limited
Name and/or title of DPO:
David Devlin, Compliance Officer
1 Hammersmith Broadway, London, W6 9DL
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated on 8th May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account details.
- Transaction Data includes details about payments to and from you and other details of products and services you have engaged with us.
- Technical Data includes your login data and other technology on devices you use to access this website.
- Profile Data includes your username and password, investments or subscriptions made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving communications from us and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences unless this is in respect of Anti Money Laundering.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Complete and submit subscription or investment applications
- Create an account on our Product;
- Subscribe to our service or investor updates;
- Request communication and performance updates to be sent to you;
- Give us some feedback.
- Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, SDKs and other similar technologies.
- Third-parties or publicly available sources: When you choose to log in with a third-party provider, we will receive your email and name from such third-party in order to create your account with us. If you are an author of one of the articles displayed on the Product, we may use publicly available sources to identify and contact you. You can easily opt out of this by following the steps in Opting Out below.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Please see the table below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending thirdparty direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table overleaf.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new investor
Performance of a contract with you between BCI Finance Limited acting as Investment Manager or Investment Advisor and yourself as an investor
To process and deliver your order including:
(a) Manage payments, investments, fees and charges
(b) Collect and process investment subscriptions
(e) Marketing and Communications
Performance of a contract with you between BCI Finance Limited acting as Investment Manager or Investment Advisor and yourself as an investor
To manage our relationship with you which will include:
(b) To carry out the appropriate background checks to fulfil our legal and regulatory investor due diligence requirements
(a) Performance of a contract with you between BCI Finance Limited acting as Investment Manager or Investment Advisor and yourself as an investor
(b) Necessary to comply with our legal and regulatory obligation
(c) Necessary for our legitimate interests (to keep our records updated and to maintain current and accurate investor records)
To deliver relevant website content and information to you and measure the effectiveness of the materials and communications we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions to you about services or investments that we believe may be of interest to you
Necessary for our legitimate interests to develop our services and grow our business
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or have consented to at registration and, in each case, you have not opted out of receiving that marketing. Marketing from ourselves will only be directed to those individuals whom we believe are appropriate to receive such information.
We will get your express opt-in consent before we share your personal data for marketing purposes with any company outside of BCI Finance for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by Contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Financial Regulators, specifically the UK Financial Conduct Authority (“FCA”) and the Jersey Financial Services Commission (“JFSC”). Both the FCA and JFSC, may from time to time, request information on our investors in order to review and test Anti-Money Laundering and Financial Crime controls and procedures. Both the FCA and JFSC have strong data protection policies and procedures and as such we are confident that your data would be safely and securely. As part of our regulatory requirements, we may be required to send your data to a regulatory body not listed above; in this case we will endeavour to inform you of this however due to the nature of the request this may not always be possible.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your 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 you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties means other companies founded or controlled by Blenheim Chalcot group of companies that may act as joint controllers or processors and who are based in the UK and Jersey and provide IT and system administration services and undertake leadership reporting.
External Third Parties means:
- Service providers acting as processors based in the UK and Jersey who provide administrative, custodial and transfer agency services to the funds and investment vehicles of which we manage and advise upon.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK and Jersey who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based [in the United Kingdom and Jersey who require reporting of processing activities in certain circumstances.
- Third-party marketing consultants who act under instruction from BCI to discuss certain investment opportunities that BCI considers appropriate.