Privacy Policy

References in this privacy policy to "we", "us" and "our" refer to ARIE Capital Ltd. And ARIE Tech LLP (collectively “ARIE”), a company registered in England and Wales under company number 09460487 and registered office at 115 Eastbourne Mews, London W2 6LQ, UK.

 

We respect your privacy and are committed to protecting your personal data in accordance with the applicable data protection laws, including the General Data Protection Regulation and the Data Protection Act 2018. This privacy policy explains how and why we collect personal data about you and how we use it.

 

This Privacy Policy refers to any and all usage of this website (the “Website”), specifically referring to the website containing the Application Form to the ARIE Capital Technology EIS Fund 3 (the “Fund”). References to “you” and “your”, and to "investor" and "investors", collectively refer to any user of the Website, including (but not necessarily limited to) anyone who chooses to submit their personal data via the Website (including investors, their authorised representatives and any other personnel nominated to use the Website either on their own behalf or on behalf of someone else), any visitors to our Website, any other recipient of our services, or any other business contacts.

The Purpose Of Our Website

Our Website has been designed for the specific purpose of allowing investors to subscribe to the Fund.

 

In order to process an investor’s application form, we need to collect certain pieces of information, including personal data about each user. This is standard practice for an application to most reputable funds in the UK, and is necessary in order to satisfy certain financial regulatory requirements, which are in place to protect both the fund and the investor. We have chosen to have a digital version of the application form available online via this Website in order to provide investors with the smoothest possible experience when subscribing to the Fund. As a result, we receive and process various personal information about our users as data controllers of their personal data.

 

If you are an investor, or acting on behalf of an investor, in order for you to subscribe to our Fund, we will require you to complete an application form. This application form serves two primary functions:

  1. To allow us to collect your personal details so that we may process your application;

  2. To allow us to ensure that you meet certain criteria that allow you to qualify to subscribe to out Fund.

Should you not wish to complete the Application Form online via our Website for any reason, you may request a physical copy of the Application Form by contacting Martin Taylor at martin@arietech.co.uk. Please note, however, that you will still be required to supply the same information (including personal data) as you would via the Website, and such data may still be used according to the same terms and conditions as laid in elsewhere on this Website, including (but not necessarily limited to) in this Privacy Policy.

Personal Information That We Collect

If you are an investor, in order to subscribe to our Fund, and whilst you continue to use the Website and any related services, we will collect information about you which will include the following:

  • Profile data: This will include information that you provide to us by completing the application form on the Website, or information that we may receive from your investment manager or your financial adviser in order to create your account and your profile. This could include (but is not limited to) your name, date of birth, postal address, phone number, email address, and certain tax and regulatory information. We only request and collect profile data that is necessary for us to process in order to operate our user accounts and facilitate investment applications you choose to make via the Website.

  • Financial data: We will collect from you certain financial information, such as your net worth and current investments. We only request and collect financial data that is necessary for us to process in order to facilitate investment applications that investors choose to make via the Website.

  • Transaction data: Details about payments to and from you (and, on occasion, your financial adviser) in relation to your investment activity via the Website.

  • Personal information provided by third parties: Occasionally we may receive information about you from other sources (such as credit reference agencies), which we will add to the information that we already hold about you in order to help us comply with our regulatory obligations. We may also receive certain personal information about you from your fund manager and/or financial adviser (if applicable). In certain circumstances, we may be required to carry out enhanced due diligence checks to comply with our obligations under the Money Laundering Regulations 2017. These enhanced checks may reveal information about criminal convictions or information about an individual’s political opinions and associations and/or other sensitive personal data. We will only collect and process such information to the extent necessary to comply with our regulatory obligations and in accordance with the applicable data protection laws.

  • Additional Data: We may collect additional data, including (but not necessarily limited to):

    • Contact data: if you contact us via any of our Websites or our Website, by telephone or by email, we will collect information necessary to identify you and respond to your query.

    • Technical Data: We may also collect technical data about our users, which may include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
    • Usage Data: Usage data collected by us may include information about how you use the Website, our Website and related services.

    • Marketing and Communications Data: We may also collect data that includes your preferences in receiving marketing from us and our third parties and your communication preferences.

    • Aggregated Data: We may also collect, use and share aggregated data such as statistical or demographic data ("Aggregated Data"). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity, and it cannot be used by us to identify you in any way. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Website feature or the number of service types that are purchased.

    • Business Contact Data: If you are not a user of our Website but we are in contact with you in relation to our offering or we have come into contact with you in the course of our business, we may collect your personal data, such as information printed on your business card or other information you give us, in order to stay in touch with you.

 

Other than information that we may receive as a result of enhanced due diligence checks (as noted above), 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 or genetic, or biometric data), or data relating to criminal convictions and offences.

How We Use Your Personal Information

We may collect, store and use your personal information for the following purposes:

  • To verify your identity in order to prevent and detect crime and money laundering;

  • To create and manage your Website account and update the records we hold about you from time to time;

  • To pass onto and liaise with any relevant managers, custodians, nominees, investee companies and/or third party identification checking services in connection with your decision to participate in an investment opportunity through the Website and third-party providers of online investment application processing services;

  • To manage the investment application process, including payments, fees and charges;

  • To provide and administer our Websites, our Website, and related services;

  • To contact you in relation to the use of our Websites, including to provide you with reminders on important usage issues, and/or asking you to leave a review or take a survey;

  • To respond to your queries;

  • To detect and prevent fraud;

  • To conduct "know your customer" checks;

  • To carry out anonymised statistical analysis and market research;

  • To fulfil our regulatory duties, including our reporting obligations;

  • To administer our contract with you;

  • To develop and improve our services and products;

  • To notify you about changes to our service, our terms and conditions and this privacy policy;

  • To manage our business, including for accounting and auditing purposes;

  • To maintain our IT systems and manage hosting of our data;

  • To collect and recover money owed to us;

  • To deal with legal disputes involving you, any relevant manager, financial adviser or our suppliers; and

  • To provide you with information, services that you request from us or which we feel may interest you, when you have consented to be contacted for such purposes.

 

We do not sell your data. From time to time, we may send emails containing information about new features and other news about ARIE, such as suggestions and recommendations about similar services we offer, which we think may be of interest to you. This is considered direct marketing. You have the right to stop us from contacting you for these purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also object to our processing of your personal data for such purposes at any time by contacting us at martin@arietech.co.uk.

Some of the above purposes for processing will overlap, and there may be several grounds which justify our use of your personal information.

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Lawful Processing

We are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:

  • Legitimate Interest: Where applicable law allows us to collect and use personal information for our legitimate interests, and the use of your personal information is fair, balanced and does not unduly impact your rights. We may rely on this ground to process your personal information when we believe that it is more practical or appropriate than asking for your consent. For instance, we rely on the legitimate interest ground to process your personal information in order to protect the security of our networks, e.g. when we receive external emails we will scan such emails for any threats. We will also rely on the legitimate interest ground to communicate with you in most instances and if we need to process your personal data to conduct our business in an efficient, compliant and profitable manner. It may also be necessary to process your personal data for legitimate interest of a third party, such as your fund manager or financial adviser.

  • Contractual Relationship: Where it is necessary for us to process your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract). For instance, we will process your personal data in order to enable you to use our Website.

  • Legal Obligation: Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject. This may be the case for example when we process personal data collected by us in order to comply with our obligations under the Money Laundering Regulations 2017.

  • Consent: Where we ask for your consent for our use of your personal information for a specific purpose. You always have the right to withdraw your consent.

 

Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your personal information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in this Privacy Policy.

Disclosure Of Your Data

We may need to share your personal information with third parties including (but not necessarily limited to):

  • The Fund’s Investment Manager (Prosper Capital LLP), the Fund’s Custodian (Roffe Swayne), and the Fund’s Nominee (Prosper Nominees Ltd.), all of whose details can be found in the Fund’s IM;

  • Our agents and service providers;

  • Credit reference agents;

  • Any relevant investment manager or financial adviser;

  • Our regulators, including the Financial Conduct Authority;

  • Law enforcement agencies in connection with any investigation to help prevent unlawful activity; and

  • In the context of the possible sale or restructuring of our business.

 

We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.

We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Keeping Your Personal Data Secure

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

While we will use all reasonable efforts to safeguard your personal data, you hereby acknowledge that the use of the internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us at martin@arietech.co.uk.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Transferring Personal Data Outside The European Economic Area ("EEA")

We will not transfer the personal data we collect about you outside of the EEA unless expressly agreed with you.

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