privacy policy 

New Grounds Limited acts as a data controller and processor. New Grounds is referred to as “New Grounds”, “the firm”, “we”, “us” or “our” in this privacy policy statement.

 

New Grounds Limited ("we," "us,") respect your privacy and is committed to protecting it through our compliance with this Privacy Policy. This policy describes:

  • the types of information that we may collect from you when you access or use our Website - www.ngvc.co.uk and other online services (collectively, our "Services"); and

  • our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies only to information we collect through our Services and in the electronic communications sent through or in connection with our Services.


Definitions

New Grounds Limited ("we," "us,") respect your privacy and is committed to protecting it through our compliance with this Privacy Policy. This policy describes:

  • the types of information that we may collect from you when you access or use our Website - www.ngvc.co.uk and other online services (collectively, our "Services"); and

  • our practices for collecting, using, maintaining, protecting and disclosing that information.

 

This policy applies only to information we collect through our Services and in the electronic communications sent through or in connection with our Services.

User
"User" or "you" or "your" refers to you, as a user of the Services. A user is someone who accesses or uses the Services for the purpose of sharing, displaying, hosting, publishing, transacting, uploading information or viewing pictures and includes other persons jointly participating in using the Services.

Content
"Content" will include (but is not limited to) images, photos, audio, video, location data, 'nearby places', and all other forms of information or data.

New Grounds Limited qualifies as a Data Controller under the Regulation (EU) 2016/679 of The European Parliament and of The Council of 27 April 2016 (General Data Protection Regulation (the "GDPR")). As such, we aim to comply with all legal obligations which the GDPR implies on Data Controllers.

New Grounds Limited strives to offer its visitors and Users the many advantages of Internet technology and to provide an interactive and personalized experience. For these purposes, we, from New Grounds Limited, may use personally identifiable information - like your name, e-mail address, address, telephone number, etc., which are subject to the terms of this Privacy Policy. We will not sell, barter, or rent your email address to any unauthorized third parties.

What information do we collect?

New Grounds Limited may collect and use information of and regarding its Users. We collect only data which is essential to our operations and enables us to provide you with better user experience.

The information, through which the person may be identified, may include data, which the User voluntarily enters, uses or provides when using the Services of the New Grounds Website, New Grounds Limited collects and uses the information for the purposes, outlined in this Privacy Policy, as well as to offer new services to the User or to familiarize him with new functionalities on the Website.

We may also use certain performance tracking tools, such as Google Analytics. Through the use of Google Analytics we gather information regarding your behaviour and preferences when using our online platform.

We collect two types of information from and about our Users, including information:

  • by which you may be personally identified; and/or

  • about your internet connection, the equipment you use to access our Services and your usage details (i.e. your Internet Service Provider).

 

Where we collect data that identifies an individual this is classed as “personal data”. Personal data may include (but is not limited to) a name, date of birth, contact address and telephone number.

 

The types of personal data we may request are:

  • Full name and title including any previous names

  • Photographic proof of identity (typically passports or photo driving licences)

  • Proof of address (utility bill)

  • Contact information such as residential address, email address and telephone numbers

  • Tax information (unique tax reference number and national insurance number)

  • Information regarding your investment experience, wealth, source of funds and bank details

  • Information regarding your knowledge of investment and types of transactions undertaken

  • Employment history and salary details

  • Information we learn from you such as requests, transactions, services provided or offered, any advice or recommendations made, a log of meetings, telephone recordings (where permitted and required for regulatory purposes) as well as email exchanges

  • Internet browsing behaviour data, by use of cookies.

 

The above list is not exhaustive and we may periodically require additional information in order to satisfy our legal and regulatory obligations. Where additional information is required we will provide you with a reasonable explanation of why it is required unless we are prevented from doing so by law.

Special category data

Special category data refers to any data that is sensitive and is subject to additional rules and requirements under the General Data Protection Regulations (GDPR). Special category data may include information regarding: criminal convictions and offences, race, ethnicity, religious or philosophical beliefs, political opinions, sexual orientation, trade union membership and information about your health, genetic and biometric data.

As a general rule, we do not collect any Special Category Data about you. However, we are required to request information relating to criminal convictions as part of our recruitment process for staff and contractors undertaking regulated activities and as such we require consent from the individual for this. If we are required by law to request any special category data from you, aside from the reasons mentioned above we will provide you with a reasonable explanation as to the nature and purpose for this request and obtain your consent. We would not be able to proceed without your consent unless there was a lawful reason for doing so.

 

Collection of your personal data

Typically, where we are required to obtain your personal data we will request it from you. However, we may also from time to time receive your personal data through intermediaries where you have authorised the sharing of your personal data with us. Intermediaries may include accountants and solicitors who may be working on your behalf. Personal data may be provided to us via post, in person, email or via a specially created secure data room/platform. The data we collect may be facilitated by way of completing an application form or by responding to information requests from us. We may also receive information from publicly available resources.

We only collect your personal data where we believe we have legitimate business interest with you or we have a lawful purpose to do so. These reasons may include but may not be limited to circumstances where you:

  • are a limited partner in a fund managed by New Grounds

  • are involved with a current prospective or exited portfolio company (e.g. as a management team member)

  • request services from us

  • consent to receiving communications from us

  • have a contractual agreement with us

  • request resources are sent to you

  • give us feedback, or some other form of legitimate business interest with you.

Disclosure

We may share your personal data with the parties set out below for legitimate business interests and lawful purposes, these may include but are not limited to:

  • Other companies in our group

  • Fund, IT and system administration service providers

  • Professional advisers including lawyers, bankers, auditors, tax advisors and insurers who provide consultancy, banking, legal, insurance, tax and accounting services

  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances which may include but is not limited to the Financial Conduct Authority

 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

You may withdraw your consent for collecting your personal information at any time. To do so, please contact us at admin@ngvc.co.uk.


Changing or Reviewing your personal data

If you would like to review, change or delete personal data we have collected from you or you had submitted or permanently delete your account, please contact us.

Security of your personal data

 

We have put in place adequate, proportionate and appropriate security measures as is required of an authorised firm 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 such data. 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 data breaches in accordance with the GDPR and we will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Controlling your personal Data

Other Users may be able to identify you, or associate you with your account, if you include your personal information in any content you post or make publicly available.

If you have any questions regarding the ways you can control your personal data, please contact us at admin@ngvc.co.uk.


Termination

 

As mentioned, you may at any time review or change the personal information we maintain about you by contacting New Grounds Limited. Upon your request, we will delete your contact information and personal data from our active databases.

This Privacy Policy is effective until terminated by either party. If you no longer agree to be bound by this Privacy Policy, you must cease the use of the New Grounds Website. If you are dissatisfied with New Grounds Limited, its content, or any of these terms, conditions, and policies, your sole legal remedy is to discontinue using the Website. New Grounds Limited reserves the right to terminate or suspend your access to and use of the Website, or parts of them, without notice, if we believe, in our sole discretion that such use is in violation of any applicable law, or harmful to our interests or the interests of another person or entity, or where New Grounds Limited has reasons to believe that their use is in violation of this Privacy Policy or the Terms of Use.

Changing the Policy

 

New Grounds Limited reserves the rights to change this Privacy Policy at any time. Please check this page periodically for changes. Your use of the services after any such amendment or change in the Privacy Policy shall be deemed as your express acceptance to such amended/changed Privacy Policy and an assent to be bound by such changed/amended Privacy Policy. Information collected prior to the time any change is posted will be used according to the rules and laws that applied at the time the information was collected.

GDPR personal rights

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data (subject access request)

  • Request correction of your personal data

  • Request erasure of your personal data

  • Object to processing of your personal data

  • Request restriction of processing your personal data

  • Request transfer of your personal data

  • Right to withdraw consent

 

Governing Law

 

This Privacy Policy and the use of the Website are governed by the laws of United Kingdom. The parties undertake to first try to resolve the dispute with by negotiation. If the parties fail to reach an amicable resolution through negotiation, New Grounds Limited agrees to submit the dispute to the competent Court of the United Kingdom.
 

Miscellaneous

 

New Grounds Limited is controlled, operated and administered entirely within the United Kingdom.

 

If you are accessing the New Grounds Website from another jurisdiction, please be advised that you are transferring your personal information to New Grounds Limited in United Kingdom and, by using the Website, you consent to that transfer and to abide by the applicable laws concerning your use of the Website and your agreements with us.

 

This statement and the policies outlined in this Privacy Policy are not intended to and do not create any contractual or other legal rights in or on behalf of any third party.

 

New Grounds Limited may provide a translation of the English version of the Privacy Policy into other languages. You understand and agree that any translation of the Privacy Policy into other languages is only for your convenience and that the English version shall govern your rights and responsibilities. In case there are any inconsistencies between the English version of the Privacy Policy and its translated versions, the English version of the Terms shall prevail.
 

Contact

If you believe New Grounds Limited does not adhere to this Privacy Policy, in order to address a question, to resolve a complaint regarding the Website or the New Grounds Services, or to receive further information regarding the Services, please contact New Grounds via email at admin@ngvc.co.uk.