Privacy Policy

We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This website Privacy Policy is divided into the following sections:

• Who are we

• Our website

• Our collection and use of your personal information

• Transfer of your information out of the UK and EEA

• Cookies and similar technologies

• Marketing

• Your rights

• Keeping your personal information secure

• How to complain

• Changes to this website privacy policy

• How to contact us

• Do you need extra help?

WHO WE ARE

This website is operated by VCAP Capital Limited. We are a public limited company incorporated in England with company registration number 10905629.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union and the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

OUR WEBSITE

This privacy policy relates to your use of our website, www.vcapcapital.com.

Throughout our website we may link to other websites owned and operated by certain trusted third parties, who may be involved in delivering our services to you (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION

We collect personal information about you when you access our website, register with us, contact us, send us feedback, enquire about products or service, and complete customer surveys via our website.

We collect this personal information from you either directly, such as when you register with us, contact us or purchase investments from our corporate partners, such as your browsing activity while on our website (see 'Cookies' below)

We also collect personal information about you from other sources as follows:

• if you use any of the other websites we operate or other services we provide

• credit reference agencies when we carry out "know-your-client" due diligence

The personal information we collect about you depends on the particular activities carried out through our website. This information includes:

• your name, address and contact details

• date of birth

• bank account and payment details

• details of any feedback you give us by phone, email, post or via social media

• information about the services we provide to you

• your account details, such as username, login details

• your self-certification information

We use this personal information to:

• create and manage your account with us

• verify your identity

• provide services to you

• customise our website and its content to your particular preferences

• notify you of any changes to our website or to our services that may affect you

• improve our services

This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.

OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose

• contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract

• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)

• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).

WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We routinely share your name, address and contact details and documentation proving your identity with the following third parties:

• Propiteer Limited - to help administer your account with us

• Propiteer Capital PLC - to help administer your account with us

• Walled Estates Limited - to help administer your account with us

• Selected KYC and KYB Partners

This data sharing enables us to administer your account or subscription with us and for us to be able to provide you with updates on the performance of your investments. Some of these third parties will require you to set up your own separate account with them. Once you have set up your account with these third parties, the processing of your personal data will be subject to the relevant third party's own policies.

Some of those third party recipients may be based outside the United Kingdom and European Economic Area, or have servers located outside of these areas — for further information including on how we safeguard your personal data when this occurs, see 'Transfer of your information out of the UK and EEA'.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

WHETHER INFORMATION HAS TO BE PROVIDED BY YOU, AND IF SO WHY

We require you to provide your name and other personal details together with your contact details (such as address, telephone number and email address) to enable us to set up your account with us and to allow us to run credit checks and a process known as “know your client”, which is used to verify your identity. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

TRANSFER OF YOUR INFORMATION OUT OF THE UK AND EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK and/or European Economic Area (EEA), eg:

• with our service providers located outside the UK/EEA

• if you are based outside the UK/EEA

• where there is an international dimension to the services we are providing to you

These transfers are subject to special rules under European and UK data protection law.

These non-UK/EEA countries may not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.

COOKIES AND OTHER TRACKING TECHNOLOGIES

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us by storing some information about your preferences or past actions, in order to provide you with a good experience when you browse our website. Cookies also help us to recognise you and your device, so that you can log into your account more easily.

For further information on cookies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy

MARKETING

We would like to send you information about our other products and services, current and pipelined projects and general news about us and our corporate partners, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone or text message (SMS).

We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes when you register to use our website/become a member of any of our services.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

1. contacting us at info@vcapcapital.com

2. using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

For more information on your rights in relation to marketing, see ‘Your rights’ below.

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• fair processing of information and transparency over how we use your use personal information

• access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address

• require us to correct any mistakes in your information which we hold

• require the erasure of personal information concerning you in certain situations

• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

• object at any time to processing of personal information concerning you for direct marketing

• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

• object in certain other situations to our continued processing of your personal information

• otherwise restrict our processing of your personal information in certain circumstances.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to us

• let us have enough information to identify you (eg account number, user name, registration details)

• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and

• let us know the information to which your request relates including any account or reference numbers, if you have them.

KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

HOW TO COMPLAIN

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.

CHANGES TO THIS WEBSITE PRIVACY POLICY

We may change this website Privacy Policy from time to time, when we do we will inform you via a notice on our website.

HOW TO CONTACT US

Please contact us, if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us, please send an email to info@vcapcapital.com, write to us at Olivers Barn, Maldon Road, Witham, Essex CM8 3HY or call 01376 315740.

DO YOU NEED EXTRA HELP?

If you would like this website privacy policy in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).