Privacy & Cookie Policy | Coller Capital

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Our Commitment to Your Privacy

Coller Capital Limited (“CCL” or “we”) is committed to protecting the privacy of current and prospective counterparties, investors, suppliers and other business contacts as they interact with the firm in person, through the internet, or by other means. CCL is sensitive to the privacy concerns of individuals with whom the firm interacts and has a long-standing practice of protecting the confidentiality and security of personal information.

This Privacy Notice and Cookies Policy (this “Privacy Policy”) is designed to tell you about CCL’s practices regarding collection, use, storage, and disclosure of information collected via the firm’s websites or any of its mobile applications and the consent required for those activities. This Privacy Policy applies to any of the websites, applications, products, software or services that display a link to this Privacy Policy (collectively, the “Websites”). Please be sure to carefully read this Privacy Policy in its entirety before using or submitting information to this site.

Additional information regarding privacy issues may be provided to you in connection with a particular product or service provided or contracted by us or any of our affiliates, whether through a website, by telephone, or in writing. Such additional information may be required by applicable law or as a result of the type or nature of the product or service in question. You are encouraged to read all information provided to you in connection with the use of your information.

Your Use of this Site

Use of this site constitutes your agreement to the terms of this Privacy Policy and the application of any applicable laws and regulations. Whenever you submit Personal Data and any other information via this site, you acknowledge that data and information will be collected, used and disclosed in accordance with this Privacy Policy.

European Data Protection Legislation

For the purposes of this Privacy Policy, “European Data Protection Legislation” means all applicable legislation relating to data protection in the European Economic Area (“EEA”), including the EU General Data Protection Regulation 2016/679 (“GDPR”) and all legislation implementing or made under or pursuant to or replacing or superseding the GDPR. Where this Privacy Policy uses terms which are defined in the GDPR (which terms may be identified by the capitalisation of the first letter), the definitions set out in the GDPR will apply.

“Personal Data” means data relating to you from which you can be reasonably identified. Examples of Personal Data include your full name, email address, postal address, telephone number, job title or the company you work for. We recognise that your Personal Data is valuable and we process it in accordance applicable law, and to the extent that it applies to your Personal Data, with European Data Protection Legislation.

Controller

CCL is the Controller responsible for the processing of your Personal Data collected from Websites under the European Data Protection Legislation (to the extent that it applies to Personal Data collected about you) and other applicable law.

What Information We Collect

We collect Personal Data to allow us to provide you with services and deliver information on the products and/or services offered by us. We make sure that the Personal Data we collect from you is necessary for and directly related to this purpose. We will use and process your Personal Data lawfully, fairly and in a transparent manner.

The Personal Data we collect from you may include but are not limited to your name, address, e-mail address and phone number, business affiliation and other relevant personal details. Personal Data may be collected when you access our public website or any other site we use, enquire about our business, speak, meet or correspond with our employees or representatives, subscribe to a service, search for a publication, or otherwise interact with us.

How we Use the Information You Provide to Us

This is information you give to us when you enter your personal details on the Website (for example during registration or application for services) or by contacting us via post, phone, e-mail or otherwise, in the context of your communications with CCL or any of its affiliates. We will use your Personal Data to:

  • identify you and verify your identity and/or eligibility when using and/or applying for any services offered on this Website and/or by us.  We will do this because it is in our legitimate interests to make sure that your enquiry is genuine and is not being made for fraudulent reasons or is spam. We will also do this where we are subject to legal obligations which require us to confirm the details that you provide to us before entering into a relationship with you;
  • create an account when you register for the services offered on this Website and maintain such account.  We will do this because it is in our legitimate interest to use your Personal Data to communicate with you, to respond to your requests and to develop the relationship between us in the context of establishing and operating your account. If you submit Personal Data comprising an e-mail address to CCL or any of its affiliates, we may send you service related e-mails (e.g. transactional e-mails, service and policy updates in respect of matters related to or arising from the use of services offered on this Website and/or the firm) because it is in our legitimate interests to keep you informed of your account activities or service changes.  It may also be necessary for us to use your Personal Date to:
    • perform an agreement with you, where we would be unable to provide those services without that information; or
    • comply with a legal obligation relating to how we manage our relationship with you;
  • provide, administer and manage services and carry out obligations arising from any contracts entered into between us.  In these circumstances, we will use your Personal Data to perform an agreement with you because we would be unable to provide those services without that information;
  • monitor your use of the Website to ensure that content from our Website is presented in the most effective manner for you to view given your device and to help the further development of the Website by compiling aggregate statistics about our users to analyse Website usage.  We do this because it is in our legitimate interests to understand user behaviour so that we can ensure that we present information on the Website that is of most interest to users and to ensure that information is displayed to you correctly and in a user friendly way;
  • enable CCL to conduct research and/or analysis on the use of its services and to evaluate and improve the services offered.  We do this because it is in our legitimate interests to understand the trends in the use and popularity of our services so that we can adapt existing and offer new services based on this research and analysis;
  • conduct communications between you and CCL and respond to feedback with regard to your needs and expectations of the services and/or products offered by CCL.  We will do this because it is in our legitimate interest to use your Personal Data to communicate with you, to respond to your requests about the services and facilities you require and to develop the relationship between us in the context of your use of our services and facilities;
  • determine your eligibility in respect of any services and other privileges, benefits and other advantages offered by CCL and consider what may best suit your needs, comparing your Personal Data with all Personal Data previously provided to CCL. We will do this because it is in our legitimate interest to use your Personal Data to develop the relationship between us in the context of your use of our services, facilities and other privileges, benefits and other advantages we offer; and
  • provide you with information related to CCL and its affiliates, including products, services and other privileges, benefits and other advantages from time to time offered, and share information about relevant services, news and events in relation to CCL’s offering.

You are entitled to amend your communication preferences by contacting us at the email address listed under Contact Information below.  If you subsequently decide that you do not want to receive correspondence from us about the services we could provide, you may do so by clicking the “unsubscribe” link provided in a promotional email message, by amending your communication preferences, or by post at info@pwss.collercapital.com and/or by post at Coller Capital Limited of Park House, 116 Park Street, London, W1K 6AF, Attention: Marketing department.

We will let you know where you must provide us with Personal Data in order for us to be able to perform an agreement with you or to comply with a legal obligation. If you do not provide us with the Personal Data in these circumstances, we will be unable to respond to your enquiry and/or engage in further communications with you.

In addition, we may from time to time notify you of other purposes for which we may process your Personal Data and ask for your consent where required by law.

Information We Collect From Third Parties

We may combine information we obtain from other sources with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Information We Collect From Your Browser and Your Device

When you visit the Website, we may automatically collect information about your interaction with the Website such as your IP address, traffic data, clickstream information, time stamp, location data, web logs, other communication data and the resources that you access. We automatically collect this data using technologies such as cookies, as described below. This data is primarily used for delivering and optimising services offered by us, such as:

  • authenticating your identity and confirming whether you are currently logged in for the purposes described under “How we use the information you provide to us” above;
  • providing you with relevant, personalised content in order to help us focus on what you are most interested in; and
  • improving our services, whereby we may occasionally display different versions of content to you and measure your usage of our Website pages.

To the extent this information constitutes Personal Data, we use it to ensure that content from the Website is presented in the most effective manner for you and your device because it is in our legitimate interest to improve our customers’ online experience in relation to the Website.

 

Cookies

We may obtain and use information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer, mobile or other handheld device. Cookies contain information that is transferred to your computer’s hard drive. They help us improve your use of our Website, to monitor your activity during your visit(s) to the Website, to distinguish you from other users and to deliver a better and more personalised service. By continuing to use the Website you consent to our use of cookies as explained in this Privacy Policy.

The following table sets out the types of cookies used on the Website and provides detail about what they are used for. When you use the Website for the first time, cookies which are essential to make the Website operate (see those identified as “necessary cookies” below) will have been set but other cookies will not have been set unless you agreed to those cookies being set at that time. If you have agreed to accept cookies, then the Website will remember this and continue to set cookies each time you visit. If you do not want cookies to be stored, then you may turn off certain cookies listed below individually or you can select the appropriate options on your web browser to delete some or all cookies. Please note, however, that if you block some or all cookies (including necessary cookies), you may not be able to use or access all or parts of the Website, such as being able to log on to member specific areas.

 

If you would like to disable cookies, you can set your web browser to reject cookies. However, if you disable the cookie function, you may not be able to access or receive all the information contained on the Website. How to alter your cookie setting will depend on the type of browser you use. We have provided examples of how to disable cookies on the most popular browsers below:

Microsoft Internet Explorer:

  • choose the “tools” menu then “Internet Options”;
  • click on the “privacy” tab; and
  • select the appropriate setting.

Mozilla Firefox:

 

  • choose the “tools” menu then “Options”;
  • click on the “privacy” menu then “Options”;
  • click on the “privacy” icon; and
  • find the “cookie” menu and select the relevant options.

Please note that Google and other third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies as a result of you visiting other websites, over which we have no control.

Disclosure of Your Personal Data

We may disclose any of your Personal Data to our affiliated companies, where required by law or as set out in this Privacy Policy. We will not sell, trade or rent your Personal Data to others.

However, we may make certain disclosures in answering any query from you or providing you with services. By visiting the Website, you agree to disclosures to the following third parties:

  • in connection with fund transactions, investor financial or other reports, or for other purposes related to raising, managing and operating private investment funds, or for providing related advice or other services, to our affiliates or third parties, including the following:
    • financial service providers, such as placement agents, other broker-dealers, custodians, banks and others used to facilitate transactions for private investment funds or such funds’ limited partners;
    • other service providers to private funds, their general partners or managers, or their respective affiliates, such as administrators, depositaries, custodians, or providers of legal, accounting or tax preparation services;
    • managers or administrators of, or advisors to, portfolio investments, as well as co-investors in portfolio investments and their advisors, if requested in connection with an investment; and
    • investors in private funds or alternative investment vehicles in connection with closing documentation, investor reports, financial statements or other investor communications.
  • other companies and individuals which we employ to provide certain services such as email marketing services (e.g. analysing customer lists, deliverability statistics, opens and clicks), marketing assistance or consulting services. These third parties may have access to information needed to perform their function but are not permitted to use that information for any other purpose;
  • our service providers and sub-contractors for the performance of any contract we enter into with them or you;
  • credit reporting agencies and other financial institutions including our own bankers, service providers; our professional advisers, such as our accountants, auditors and lawyers, insurers and industry groups having a legitimate reason to receive such information; and/or
  • a purchaser or successor entity in the event of a sale or other corporate transaction involving all or part of our business or as needed to effect the sale or transfer of business assets, or as needed for external audit, compliance or corporate governance related matters.

We also reserve the right to release information when we believe that release is necessary or appropriate in order to comply with the law, applicable regulations, to enforce or apply our terms of use and other agreements or to protect the rights, property or safety of the Coller Capital group of companies or directors, managers or employees of group companies. This includes exchanging information with other companies and organisations for the purpose of protecting against financial crime.


Retention and Data Integrity

We will keep a record of the Personal Data that we receive from you in order to answer any queries from you, respond to any requests for more information about the services and facilities we provide, and/or in order to provide those services and facilities. We will only retain the Personal Data collected from you for as long as your account is active or has otherwise not been cancelled and you have not requested that your Personal Data be deleted. We will retain Personal Data to fulfil the purposes for which we have initially collected it, unless otherwise required by law. We will retain your Personal Data for no longer than is necessary and reasonable to fulfil such purposes and/or to comply with our legal or regulatory obligations.

Our policies and procedures address the retention of written and electronic documents, including those documents containing Personal Data about our contacts. We will make reasonable efforts to keep your Personal Data accurate, complete and current.

We will delete our copy of your Personal Data within an appropriate time period after our last contact with you although we may retain a record of the existence of the relationship, to the extent and for so long as we are required to do so by law or regulation. For example, if you have contacted us to ask us for the processing of your Personal Data to be erased, we will retain a record of your request in order to ensure we comply with your wishes.

Information Security

We use appropriate technical, organisational, administrative and physical security measures to reduce the risks of loss of, unauthorised access to, or inadvertent destruction of, your Personal Data. We train our employees to handle personal and business information in accordance with approved policies and procedures that we have established to ensure compliance with applicable laws, regulations and internal policies for protecting Personal Data. Only those employees with proper authority and training are allowed access to your Personal Data.

You acknowledge that the transmission of information via the internet is not secure. We cannot guarantee the security of your data transmitted to our public website, any other site used by us and accessible by you or through electronic communications, and any transmission is at your own risk.

International Transfers of Personal Data

If you provide Personal Data to us, it may be transferred to, processed in, stored at or accessible from one or more destinations outside the European Economic Area (“EEA”), including territories which have not been deemed to offer adequate data protection by the European Commission. It may also be processed by staff operating outside the EEA who work for us or for another Coller Capital group company or a third party service provider. Such staff may be engaged in, among other things, the provision of support services.

All practical steps are taken to ensure that all data is treated confidentially, kept secure and protected against unauthorised or accidental access, processing, erasure or other use and is maintained and kept no longer that is necessary for the purpose for which it is intended.

If you provide your Personal Data to us in circumstances where our processing of it is subject to European Data Protection Legislation, please note that you are doing so on the basis that you explicitly consent to the transfer of your data outside the EEA. The potential consequence of you explicitly consenting to this are that there is a risk that your Personal Data will not be protected in a manner that complies with European Data Protection Legislation. You can withdraw your consent for this reason at any time by contacting us as detailed under the heading “Contact Information” below. Withdrawing your consent will not affect our use of the Personal Data prior to your withdrawing that consent, but it will mean that we will not be able to contact you about the services we may be able to offer you in the future.

Where we pass your Personal Data that is subject to European Data Protection Legislation from a location inside the EEA to parties located outside the EEA that do not offer adequate protection as determined by the European Commission, and if they are not subscribed to an approved data protection framework, such as the EU-US Privacy Shield that permits us to transfer the Personal Data to them from the EEA, we will enter into agreements which enable us to transfer Personal Data to them and that enable you to exercise your rights in accordance with the European Data Protection Legislation. A copy of these terms can be obtained by contacting us as detailed under the heading “Contact Information” below.

Your Rights

With respect to the Personal Data that CCL collects about you as detailed in this Privacy Policy, to the extent that you are located in the EEA, under the European Data Protection Legislation you have the right to:

  • request access to that Personal Data;
  • receive a copy of the Personal Data that you have provided in a structured, commonly used and machine readable format so that you can share it with others;
  • request the transfer of your Personal Data to another party;
  • ask that Personal Data be erased;
  • object to us possessing your Personal Data by asking for the processing of that Personal Data to be restricted or stopped; and/or
  • make a complaint to a European data protection authority about the manner in which CCL processes your Personal Data.

Please contact us by e-mailing CCcompliance@pwss.collercapital.com if you wish to exercise these rights.

In addition to the above, you have the right to review, update, and correct your account information and preferences at any time.  You may do so by clicking “unsubscribe” links provided in promotional email message, by amending your communication preferences, or by post at info@pwss.collercapital.com and/or by post at Coller Capital Limited of Park House, 116 Park Street, London, W1K 6AF, Attention: Marketing department.

If at any time you wish your Personal Data to be completely removed from all our systems, for example when there is no longer a legitimate or legal reason for us to keep your Personal Data, please contact us by e-mailing CCcompliance@pwss.collercapital.com. Please note that we may be required to retain certain Personal Data, but we will not retain such information for longer than is necessary for the relevant purposes. Please note, however, that we require certain key Personal Data from you in order to provide you with information or services and if you ask us to remove all or part of such information, you may no longer be able to use or access such information or services, including our public website or parts of it.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy and any other relevant policies or procedures at any time. Any changes we may make to this Privacy Policy will be posted on this page. You should regularly check and review this on this Website to ensure you understand how we may be processing Personal Data. Any changes we may make to this Privacy Policy (which will, unless otherwise indicated, apply to Personal Data already obtained before the changes were made) will be effective from the date on which those changes have been posted on this page. Where we decide it is appropriate to do so, we may also notify you of any changes we have made by e-mail.

Contact Information

If you have any questions concerning this Privacy Policy or the policies or procedures referred to above, please contact us by emailing CCcompliance@pwss.collercapital.com and/or by post at Coller Capital Limited of Park House, 116 Park Street, London, W1K 6AF, Attention: Legal and Compliance department.

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