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KELVIN CAPITAL LIMITED

PRIVACY POLICY

Kelvin Capital Limited (“We“, “Kelvin“) are committed to protecting and respecting the confidentiality, integrity and security of personal information about individuals whose data we hold.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and how Kelvin Capital Ltd. complies with its responsibilities under applicable data protection laws, including, when and to the extent in force,  the Data Protection Act 1998, the General Data Protection Regulation (Regulation (EU) 2016/679) and the Privacy and Electronic Communications Regulations 2003 (“Data Protection Laws“). Please read this policy carefully.

Data Controller

For the purpose of the Data Protection Laws, the data controller is Kelvin Capital Limited of 163 Bath Street, Glasgow.

Personal data collection

We hold personal data about you which you provide to us in the course of meetings or correspondence between you and us, or (where you are a member or potential member) via our membership forms. We may, on occasion, be provided with information by your or our solicitor or by an existing member or board member. We will promptly notify anyone whose data we receive that we are holding that data.

We may collect the following information from you:

  • name;

  • address;

  • contact details;

  • date of birth;

  • financial information (including details of funds invested in); and

  • bank account details.

Use of personal data and legal basis for processing

All personal data we hold about you will only be used for the purposes set out below or for any other purpose specifically permitted by the Data Protection Laws or which you may authorise (which may include direct marketing, if you authorise us to do so).

If you are a member or a shareholder, we may use information you provide to us to:

  • update you on investee companies in which you have an investment;

  • provide you with access to our investment portal;

  • send you a copy of our email newsletter (if you agree);

  • pay you any returns on your investment;

  • inform you of investment opportunities;

  • facilitate the entering into of investment agreements; and

  • invite you to Kelvin Capital events.

If you are an investee company or are seeking investment for your business, we may use information you provide to us to:

  • communicate with you regarding the management of the company and/or investment proposals;

  • invite you to Kelvin Capital events; and

  • send you a copy of our email newsletter (if you agree).

Where you provide personal information to us, we are processing it in order to perform our obligations under our agreement with you or in order to take steps at your request prior to entering into a contract or you becoming a member.

Where you provide personal information to us, you will be asked if you consent to us adding you to our distribution list for our email newsletter. If you give your consent, we are processing your information for that purpose on the basis of your consent.

Access and other rights

You may request to view records held about you at any point by making a request in writing to us at theteam@kelvincapital.com.  This request will be responded to within 30 working days. If we require more time to respond fully to any request, we will notify you in writing within the 30-day period referred to. Any additional copies of any information we provide to you may be subject to a reasonable fee.

You also have other rights under Data Protection Laws in relation to your personal data. In particular, you may have (i) the right to request that we rectify or erase information we hold about you in certain circumstances, (ii) the right to ask us to limit our processing of your information, (iii) the right (if we are processing information based on your consent, such as for marketing purposes) to withdraw your consent, (iv) the right to object to certain processing of your information (including the right to object to processing of your personal data for direct marketing purposes at any time), (v) the right to ask us to move, copy or transfer your personal information to another organisation. If you wish to exercise any of these rights, please contact us at theteam@kelvincapital.com

Accuracy of personal data

Kelvin Capital tries to ensure that personal data we hold about you is accurate and kept up-to-date. If you believe that any information we are holding about you is inaccurate, out-of-date or incomplete, please notify us at theteam@kelvincapital.com as soon as possible. We will promptly correct or delete any information found to be incorrect.

Security

We have put in place what we consider to be appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.

Disclosure and sharing of your personal data

We may disclose personal data to third parties for the purposes of finance, IT, professional advice, portal development/support, or for any other purposes specifically permitted by the Data Protection Laws or for any other purpose which you may authorise.

We may also disclose personal data we hold to third parties:

  1. a) in the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets; and/or

  2. b) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

To the extent we transfer any personal data to any third party, we will only do so if that third party agrees to put in place appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, the personal data.

Transferring personal data outside the EEA

We may transfer personal data we hold about you to a country outside the European Economic Area (“EEA“) where we engage suppliers located in jurisdictions outside the EEA.

As at the date of this policy, we transfer personal data to some contacts located in the United States of America (“US“). We have taken steps to protect any of your personal data which we send to the US by putting in place a Non-Disclosure Agreement.

If we transfer any data to any other jurisdiction outside the EEA, we will provide you with details of the country to which data is being transferred, along with details of the measures we have put in place to protect it (which you may see a copy of, on request).

Retention of personal data

Kelvin Capital will destroy shareholder or member’s records 2 years after they cease to be a shareholder or member.

Kelvin Capital will retain records of potential members for 1 year after which they will be destroyed.

We will take all reasonable steps to destroy, or erase from our systems, all personal data which is no longer required.

Please note that you may contact us at any time at theteam@kelvincapital.com and ask for your details to be removed (please refer to the section headed “Access and other rights” above). We may not be able to continue to provide you with our services in the event you request that your details are removed.

Companies

If you are invited to participate in our Investment Showcase events, your showcase pitch will be recorded and distributed to Kelvin Capital Ltd members only as part of the fundraising process.  The videos will be uploaded to a third party site (YouTube) and listed under YouTube’s unlisted privacy setting. This allows us to issue the link to our members but it will not be shown in any search engine results.

Changes to this policy

We may make changes to this data protection policy at any time. Any changes we make will be notified to you in writing.

Contact

If you have any queries about this policy or your data, or you wish to submit an access request or raise a complaint about the way your personal information has been handled, please do so in writing and address this to Kelvin Capital, 163 Bath Street, Glasgow, G2 4SQ or by email to theteam@kelvincapital.com

If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data not in accordance with the Data Protection Laws you can complain to the Information Commissioner’s Office (https://ico.org.uk/).

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