Privacy policy

MMC take the issue of privacy seriously. We recognise that, when you provide us with information about yourself or your business, you trust us to act in a responsible manner and we are committed to making sure that we earn that trust.

We reserve the right to change this privacy policy from time to time by changing it on the website.  This privacy policy was last updated on 25th May 2018.

This policy relates to current and potential investors and their financial advisers and sets out how MMC:

  • Collects your information
  • Use your information 
  • Communicates with you including for promotional updates
  • Shares your information
  • Stores your information
  • Payment processing
  • Protects your information
  • Keeps your information

We also set out your rights, how we may communicate changes to this policy and how you can contact us with privacy queries.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Terms and Conditions refers to the Terms and Conditions of our Customer Agreement.

For the purposes of European Economic Area data protection law, (the “Data Protection Law”), we, MMC, are the data controller.

The information we collect about you and how we use it:

We set out below examples of the categories of information we collect from you, how we collect this, the purpose for which we collect, and the lawful basis under which we are permitted to collect and process your information.

 

What we collect

How we collect it

Use / Purpose of collection

Lawful basis for collection

Name and contact details

By telephone, may have been recorded, via website or email

If you called us or requested information through the website before you invested to ask for information about our funds we will have taken your name and contact details in order to send that to you and be in contact

We have a legitimate interest in providing you with the requested information and making reasonable subsequent contact to assist you in deciding whether to invest with us. 

Name

 

 

 

 

Application Form

ID/AML documents

 

 

 

 

 

 

We need to collect this information for anti-money laundering purposes.

AML

We are under a legal obligation, pursuant to anti money laundering legislation to collect and process this information.

 

Date of birth

Passport number

Driving licence

Home address

Home address

 

To provide you with quarterly reports, EIS certificates and communications relating to your investment. Without this we won’t be able to provide you with this information.

 

Under our Terms & Conditions, we are obliged to provide you with quarterly and other communications relating to your investment including EIS certificates. We collect your home address in order to be able to fulfil our contractual obligations.

Tax residency

Application form

We need to collect this information for HMRC (AEOI) purposes.

 

We are under a legal obligation, pursuant to applicable tax legislation to collect and process this information.

Phone numbers

Application Form

To provide you with communications relating to your investment. Without this we won’t be able to provide you with this information.

 

Under our Terms & Conditions, we are obliged to provide you with quarterly communications relating to your investment. We collect your phone number in order to be able to fulfil our contractual obligations.

Personal email

Application Form

 

To provide you with communications relating to your investment. Without this we won’t be able to provide you with this information.

 

Under our Terms & Conditions, we are obliged to provide you with communications relating to your investment. We collect your email for this purpose in order to be able to fulfil our contractual obligations.

 

To send you promotional communications which we think might be of interest to you.

 

Where we have your consent to do so, which you can withdraw at any time, we will send you promotional content about our upcoming investments, events and industry news.

Adviser’s name and contact details

Application Form

 

To provide your adviser with communications relating to your investment

Under our Terms & Conditions, we are obliged to provide you with communications relating to your investment. In some cases, investors prefer that their adviser is also kept informed. We collect this information for this purpose in order to be able to fulfil our contractual obligations.

Career history

Application Form

For the FCA appropriateness test

This is a legal obligation to understand whether our product is appropriate for you

Net worth

Application Form

For the FCA appropriateness test

Advised clients: This is an optional part of the form.  By filling in this section you consent to providing us with this information.  We will delete it at any time on request.

 
Direct clients: This is a legal obligation to understand whether our product is appropriate for you.

Investment History

Application Form

For the FCA appropriateness test

Advised clients: This is an optional part of the form.  By filling in this section you consent to providing us with this information.  We will delete it at any time on request.

 
Direct clients: This is a legal obligation to understand whether our product is appropriate for you.

National Insurance Number

Application Form

To assist with accurate record keeping for your investments

We collect your national insurance number in order to be able to fulfil our contractual obligations.

 

Bank details

Email, writing, via telephone from you during your time as an investor

For returning investment disposal proceeds

We collect this information for this purpose in order to be able to fulfil our contractual obligations.

 

MMC investment updates

Writing and Investor Portal

We provide and store information about your investments with MMC on the investor portal and/or by post

 

It is  a legal obligation under FCA requirements to provide reports about your investments

Tax certificates and reports

Writing and Investor Portal

 

We provide and store certain tax certificates and reports on the investor portal and/or by post

 

We provide these certificates and reports as part of our contractual obligations with you

 

We may also collect information from you when you use our website or log in to your Investor portal.

As described in the Terms &Conditions, we are under a legal obligation to monitor and record information relating to your Customer Agreement as they relate to the conclusion of a contract in a financial instrument.

From time to time, including but not limited to, when you voluntarily provide information to us, we may collect other categories of data from you.

Above we set out specific circumstances in which we collect your information how and why we collect this and our lawful basis for doing so. Many of the categories of information we collect primarily to allow us to perform our contract with you and to enable us to comply with legal obligations.  In some cases we may use your personal data to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. We will always let you know if are relying on consent to process your personal data and you have a right to withdraw consent at any time.

Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our services and events that may interest you.

You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to fundenquiries@mmcventures.com. 

How we share your personal information

We are very concerned to ensure that your personal information is only shared with third parties who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. Our selected third parties may include:

• Our corporate nominee, presently Mainspring Fund Services.
• Organisations who support the services we offer you, including through the client portal site. These include: those providing website and data hosting services (presenting including Dropbox, Slack, WordPress, Microsoft, Investran, Sugar CRM), providing fulfilment services, distributing any communications we send (presently including MailChimp, PaperlessPost), supporting or updating marketing lists (presently including MailChimp, PaperlessPost), investment reporting software (presently Tax Efficient Procurement Services) facilitating feedback on our services and providing IT support services (presently AM IT Services) from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual)
• Business partners who provide services to you and with whom we have entered into agreements in relation to the processing of your personal data. For example, IFAs who connect us with you.
• Identification verification agencies for the purposes of assessing your identity
• Our portfolio companies for the purpose of obtaining EIS relief.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
• If MMC Ventures Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of MMC Ventures Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

In accordance with the below section, we may transfer your personal information to countries outside the EEA. At present, the only country outside the EEA to which personal information is sent is the United State of America.

Where we store your information

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) that may not be subject to equivalent Data Protection Law.

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy

We may transfer your personal information outside the EEA:

• In order to store it.
• In order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment and the provision of services by third parties (see above).
• Where we are legally required to do so.
• In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

If you have any questions about data transfer, please do contact us.

Payment Details

Payment details you provide will be encrypted using Transport Layer Security (TLS) technology [before they are submitted to our corporate nominee.

How we protect your information

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data in transmission. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

From time to time, we may provide communications which contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

Your rights

We retain personal data for as long as you are an investor with us (or a financial adviser who has a client invested with us) in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings. For potential investors who do not become investors, we retain your information for one year. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

 How long we keep your information

You have the right under certain circumstances:

• to be provided with a copy of your personal data held by us;
• to request the rectification or erasure of your personal data held by us;
• to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
• to object to the further processing of your personal data, including the right to object to marketing (as mentioned above;
• to request that your provided personal data be moved to a third party.

Your right to withdraw consent:

• Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. You can also change your marketing preferences at any time as described above.

You can also exercise the rights listed above at any time by contacting us at fundenquiries@mmcventures.com or on 020 7938 2220.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

Changes to this policy

Any changes we make to our privacy policy in future will be posted on our website and, in relation to substantive changes or where required by law, will be notified to you in writing where required by Data Protection Laws. This policy was last updated on 25 May 2018.

Contact us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

MMC Ventures Ltd.
FAO: LEGAL (PRIVACY)
2 Kensington Square London
W8 5EP

fundenquiries@mmcventures.com

Cookies

Some parts of the Site may use a ‘cookie’, which is a small text file that is placed on your computer’s hard drive. The cookie captures no personally identifiable information. The Site may use a cookie in order to log which pages you visit or to provide enhanced capabilities during your visit. You can set your browser to refuse to accept cookies; however if you choose to do this, some features of this Site and others may not function properly.

Your rights

You have a legal right under the Data Protection Act 1998 to a copy of all the personal information about you held by us. On request, we will provide you with a copy of this information subject to a fee not exceeding £10. You also have a right to correct any errors in that information. As mentioned above, you have a right to prevent the use of your personal information for direct marketing purposes.

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