Investase Privacy Notice
August 2019
We are committed to protecting and respecting your privacy. This notice describes the basis on which we process your personal data and tells you about your privacy rights.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below:
1. Introduction
2. The types of data that we collect and how we collect it
3. How we use your personal data
4. Providing your personal data to others
5. International transfers of your personal data
7. Retaining and deleting personal data
8. Your rights
"We", "us" and "our" refer to Investase Limited. We are registered in England and Wales under registration number 11775496, and our registered office is at 10 Victoria Road South, Southsea, PO5 2DA. We are a strategic advisory firm providing investor relations (IR) and communications services to companies in the healthcare industry.
Investase Limited is the controller and responsible for your personal data.
Please contact us at privacy@investase.com with any questions in relation to this notice or your privacy rights.
Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.
2. The types of data that we collect and how we collect it
Personal information, or personal data, 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 collect from various sources as described below:
● Identity Data includes first name, last name, employer or business in which you are invested or represent and position/title.
● Contact Data includes name, email address, business address and telephone numbers.
● Marketing and Communications Data includes your preferences in receiving marketing communications from us.
Investase does 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.
We use different methods to collect data from and about you including through:
Direct interactions . You may give us your Identity Data, Contact Data and Marketing and Communications Data by corresponding with us by phone, email and at industry events. This includes personal data you provide when you give us your business card so that we may contact you or you communicate with us about our services and the businesses we are representing.
Third parties or publicly available sources. We may receive personal data about you from your employer, from a business you represent or in which you are an investor or have met with previously. We may also receive your contact data from personal introductions and we may collect Identity Data and Contact Data from publicly available sources such as your employer’s website or professional networking sites such as LinkedIn.
3. 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 it is necessary for the performance of a contract 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.
● Where you have given your consent to the processing of your personal data for a particular purpose.
Purposes for which we will use your personal information
The purposes for which we will process your personal information and the lawful basis of processing on which we rely are described below.
|
Purpose/Activity |
Lawful basis for processing including basis of legitimate interest |
|
Enabling us to engage with the investment community in order to provide IR services such as, facilitating management access (e.g. arranging meetings, calls), assisting with information requests and follow up, gathering feedback, generating awareness, increasing visibility |
Necessary for our legitimate interests (so that we can perform IR services) |
|
Building and maintaining a network of contacts in the investment community |
Necessary for our legitimate interests (so that we can perform IR services) |
|
Building and maintaining a network of corporate contacts and prospects who might be interested in our services and to inform our marketing and sales activities |
Necessary for our legitimate interests (so that we can market and sell our services) |
|
Providing you with services you have requested from us or are in discussions regarding, including communications, managing the provision of our services, managing and collecting fees, enabling interactions with prospective customers |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover amounts due to us) |
|
Inviting you to our events and sending you our marketing communications |
(a) Necessary for our legitimate interests (so that we can market our services to corporate subscribers) (b) Your consent (if your consent is required) |
|
Managing our relationship with you including: (i) Notifying you about changes to our terms or privacy notice; (ii) asking you to update your information; and (iii) dealing with any issues or feedback you may have |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated, to manage and improve our services and the efficient running of our business) |
|
Administering and protecting our business and website (including troubleshooting, reporting and hosting of data) |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
Marketing and Opting out
You may receive our communications or invitations to our events if you have requested information from us, if you provided us with your details or if we have identified you as someone who may be interested in our services or in learning more about our clients and you have not unsubscribed from our marketing communications.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing privacy@investase.com at any time.
Cookies
Our website does not use cookies.
4. Providing your personal data to others
We may share your personal data with the following parties:
· businesses which are our clients for the purposes of providing IR services as instructed by you
· service providers acting as processors who we use to help manage our business. We use Google GSuite, Microsoft OneDrive and Dropbox as cloud hosting providers to manage and store our contacts, communications and documents
· insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims
· HMRC, regulators, law enforcement agencies and other authorities if required by such authorities or by due process of law
· third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets
5. International transfers of your personal data
Some of your personal data may be transferred, stored and/or processed outside of the UK and the European Economic Area (EEA) as our suppliers sometimes operate from outside of these jurisdictions, including from the US. We will only transfer your data outside of the UK and the EEA on the basis of an adequacy decision if appropriate or suitable safeguards are in place to protect your data.
Please email privacy@investase.com if you would like details of the appropriate safeguards we have in place for transfers of data outside of the UK or EEA.
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.
7. Retaining and deleting personal data
We will retain your personal data for as long as necessary to provide you with our services. We will also retain your personal data as necessary to fulfil our contractual obligations and to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will retain personal data that is part of our investment community network for a period for which we think that information is relevant. We actively manage our investment community network so that only relevant personal data is retained.
Where we no longer need to process your personal data for the purposes set out in Section 3 of this privacy notice, we will delete your personal data from our systems unless we need to retain a limited amount of information to make sure that we act in accordance with your wishes.
Where permissible, we will also delete your personal data on your request. Information on how to make a deletion request can be found in Section 8, Your rights.
Please email privacy@invetase.com if you would like details of our data retention policies.
You have certain legal rights with respect to your personal information which you can exercise at any time by contacting us at privacy@investase.com.
|
Your Rights |
What does this mean? |
|
Right of access |
You have the right to access any personal data we hold about you: we will provide a copy of your personal data that we hold together with details of the purposes of the processing, the types of personal data we hold and the people to whom your personal data has been disclosed. |
|
Right to rectification |
You have the right to have inaccurate or incomplete personal data corrected or to restrict the processing of personal data whilst the accuracy is checked. |
|
Right to erasure |
You have the right to ask to have personal data we hold about you erased. 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 law. |
|
Right to data portability |
In certain circumstances, you have the right to have data we hold about you transferred to yourself or another data controller. Note, this right only applies to information that is processed by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you. |
|
Right to object |
You have the right to: ● ask us not to process your personal data for direct marketing purposes ● object to the 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. |
|
Right to withdraw consent |
You have the right to 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. |
|
Right to complain |
You have the right to lodge a complaint with the UK Information Commissioner’s Office https://ico.org.uk/concerns/ or other data protection supervisory authority applicable to you if you are unhappy with the way we are handling your personal data. |
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.
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.