At the Clean Growth Fund LP (“Clean Growth Fund”), managed by Clean Growth Investment Management LLP, we take privacy seriously and we are committed to protecting it. In the policy, “we” (and corresponding expressions) refers to Clean Growth Investment Management LLP.
This policy explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure. This policy may change from time to time so please check this page occasionally to ensure that you are aware of any changes.
This policy was last updated in October 2021.
Who we are
Clean Growth Investment Management LLP (incorporated under English law with company number OC425057), also referred to in this policy as “CGIM” or “we” (and corresponding expressions), is the data controller in relation to the processing activities described below. This means that CGIM decides why and how your personal information is processed. CGIM is the manager of the Clean Growth Fund, and authorised and regulated by the Financial Conduct Authority.
How we collect your personal information
The personal information we collect and the way in which we collect it are as follows:
Personal information you give to us:
This is information about you that you give to us by entering information via:
- our site at https://www.cleangrowthfund.com;
- social media platforms;
- corresponding with us by phone, email or otherwise,
and is provided entirely voluntarily.
This includes information provided at the time of registering to use our site (including registration for events via our site), subscribing to any services we provide through our site, posting or uploading any material or requesting further services, and engaging in correspondence with us by phone, email or otherwise. We may also ask you for information when you report a problem with our site. If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well.
The information you give us may include:
- your name and job title
- your company / employer’s name
- your postal address
- your email address and phone number
- your enquiry details and records of any correspondence
- your responses to any surveys
event registrations and attendances.
Personal information we collect about you:
We may automatically collect the following information relating to your use of our site, including your visits to our site, traffic data, location data, weblogs and other communication data, and the resources you access. We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see our Cookies Policy for further information. We may also collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Personal information we may receive from other sources:
From time to time, we co-host events and conferences and in these circumstances we may receive personal information of delegates with co-hosts. The personal information received in these circumstances is used for event management and, where legally permissible (and in accordance with all legal requirements to obtain consent), to send you marketing communications concerning the Clean Growth Fund. If you are a delegate of a co-hosted event we or the co-host shall always notify you of the identities of all co-hosts and the basis on which your personal information is shared. Other than this and as set out in our Cookies Policy we do not receive personal information about you from any other person.
TYPES OF PERSONAL INFORMATION WE PROCESS ABOUT YOU
We may process a range of personal information about you. To make it easier to understand the information that we use about you, we have divided this information into categories in the table below and provided a short explanation of the type of information each category covers.
Except as stated in the table below, we do not collect, share or otherwise process sensitive (also known as “special category”) data about you. Types of sensitive or “special category” data include data relating to your ethnic background, sex life, political opinions, religion, trade union membership, criminal record, or genetic and biometric data.
|Category||Personal information included in this category|
|Behavioural||your activities, actions and behaviours, including online activity whilst using our site|
|Contact||information which can be used to address, send or otherwise communicate a message to you|
|Employment||your employer details, where applicable|
|Fraud||information relating to the occurrence, investigation or prevention of fraud|
|Insurance||your insurance applications and any information relating to your insurance claims|
|Identity verification||information required to be obtained in order to verify identity in compliance with anti-money laundering legislation. This may include photo passports and driving licences which may constitute “special category” data where containing or revealing biometric data|
|Legal||information relating to legal claims made by you or against you or the claims process|
|Correspondence||information contained in our correspondence or other communications with you about our products, services or business|
HOW WE USE YOUR PERSONAL INFORMATION
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.
Where you have provided consent
We may use and process your personal information where you have consented for us to do so. We will seek your consent where required to do so by law in circumstances in which we wish to contact you by email or SMS for marketing purposes and your given email address is not that of a corporate entity (such as your employer). This is most likely the case where your given email address is a personal address such as “XXX@gmail.com” or similar.
Where we are processing your personal information on the basis of your consent, you may withdraw that consent at any time. Please see ‘Withdrawing your consent’ section below for further details.
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
- for marketing activities (other than where we rely on your consent as referred to above), including the sharing of your contact details provided to us in connection with your attendance at any event or conference (including any web-based event) with a third party which is co-hosting that event or conference;
- for analysis to inform our marketing strategy, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our website);
- to provide, on an aggregated and anonymised basis, website traffic statistics to our fund investors;
- to correspond or communicate with you;
- to verify the accuracy of data that we hold about you;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- for prevention of fraud and other criminal activities;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- for the management of queries, complaints, or claims; and
- for the establishment and defence of our legal rights.
Where there is a LEGAL REQUIREMENT
We will use your personal information to comply with our legal obligations: (i) to assist the FCA or any other regulatory or public authority or criminal investigation body; (ii) to identify you when you contact us; and (iii) to verify the accuracy of data we hold about you, where legally necessary.
Where it is required to complete a CONTRACT
We may use and process your personal information where we have supplied you (or continue to supply you) with any products or services, where we have arranged for the supply of another company’s products or services to you, or where you are in discussions with us about any new product or service. We will use this information in connection with the contract for the supply of products or services when it is needed to carry out that contract or for you to enter into it.
OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
We may share your information with other companies within our group. They may use your personal information in the ways set out in the “How we use your personal information” section, in connection with the products and services that complement our own range of products and services.
Please see the start of this policy for the details of our group companies with whom we may share your personal information.
Our investors, suppliers and service providers
We may, on an aggregated and anonymised basis only, provide website traffic statistics to our fund investors from time to time.
We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management), advertising agencies and administrative services.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we are under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.
WHERE WE STORE YOUR PERSONAL INFORMATION
All information you provide to us is stored on our secure servers which are located within the United Kingdom (UK) or European Economic Area (EEA).
In addition, from time to time we may engage third party providers or consultants who are based outside the UK and EEA, or who themselves have engaged third party contractors based outside the UK and EEA, and to whom your personal information may be transferred directly or indirectly by us. Also we may at any time in the future, transfer your personal information to, or store it in, countries located outside of the UK or EEA (for example, if our hosting services provider changes).
In such cases, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law and, where applicable, that appropriate assessments have been undertaken relating to any risks relating to that transfer and that the appropriate standard contractual clauses or equivalent protection is in place between us and the entity receiving your personal information. This is because some countries outside of the UK and EEA do not have adequate data protection laws equivalent to those in the UK or EEA.
If you use our services whilst you are outside the UK and the EEA, your information may be transferred outside the UK and the EEA in order to provide you with those services.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under the “How we use your personal information” section above. The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see the “Erasing your personal information or restricting its processing” section below); or
- in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
SECURITY AND LINKS TO OTHER SITES
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Where we collect any sensitive or “special categories” of personal information, including information relating to your ethnic background, sex life, political opinions, religion, trade union membership or criminal record, we will apply additional security controls to protect that data.
Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
We may collect your preferences to receive marketing information directly from us by email or SMS in the following ways:
- if you register online (or via a third party platform engaged by us) to attend an event or conference we are hosting or co-hosting; or
- if you make any enquiries by email, telephone or in person (e.g. at a networking event or conference), or we are introduced by a third party; or
- the Clean Growth Fund is an investor or potential investor in a business for which you are an employee, officer or consultant.
We may contact you with marketing information by post or by telephone or with targeted advertising delivered online through social media and platforms operated by other companies by using your personal information, or use your personal information to tailor marketing to improve its relevance to you, unless you object. We shall process your personal information in the context of marketing activities on the basis that it is necessary for the purposes of our legitimate interests. Where required by law to do so, we shall obtain your consent to receive direct marketing communications by email or SMS.
From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
You have the right at any time to opt-out of, and/or object to, our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see the “Withdrawing your Consent” and “Objecting to our use of your personal information and automated decisions made about you” sections below for further details on how you can do this.
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
- Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Correcting and updating your personal information
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.
- Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under the “How we use your personal information” section, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
- Objecting to our use of your personal information and automated decisions made about you
Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under the “How we use your personal information” section, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.
- Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
- Transferring your personal information in a structured data file
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under the “How we use your personal information” section, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
CHANGES TO THIS POLICY
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.
Please direct any queries about this policy or about the way we process your personal information to our Data Protection Officer using our contact details below. If you wish to write to us, please write to the address given at the start of this policy.
Our email address for data protection queries is firstname.lastname@example.org.