1. ABOUT US
FSVL is a data controller for all data processing carried out in respect of FSVL investments, which means that it is responsible for compliance with data protection laws.
If you would like to contact FSVL about any use of your personal data, please email email@example.com. You also have the right to complain to your national data protection authority (which, for the UK is Information Commissioner’s Office whose helpline number is: 0303 123 1113).
2. WHO DO WE COLLECT INFORMATION ABOUT?
We do not provide products or services, or promote our business, to consumers. We do collect information about individuals who invest in or are concerned with the investments we manage, and much of our work is the evaluation of existing and potential investments. We therefore collect information about individuals who are or may become directors, officers, shareholders or persons with management or control responsibility in:
- existing or potential investments
- other co-investors with us in our investments (or potential investments)
We also collect:
- information about individuals representing businesses that we work with
- certain information from users of our website, as described in Section 6 of this policy.
3. WHAT INFORMATION WE COLLECT
- contact information, for example, personal and work email addresses and phone numbers
- identifying information, for example, passport, ID or driving licence number, date of birth and gender
- professional information, for example, employment history, educational and professional - qualifications and accreditations, directorships
- information about relationships with the FIL Limited group and our investments or potential investments
- financial information about you and your business interests, your creditworthiness and your financial history
- information from anti-fraud, due diligence, political exposure and sanctions databases, which may include public domain information about your medical history, your family, criminal convictions, political opinions or affiliations
- from users of our website, information about the website that users came from or are going to. We also collect information on which pages of our website users visit, IP addresses, the type of browser used and the times our website is accessed. However, this information is aggregated and is not used to identify individuals. We do not require personal data to be submitted in order to use our website.
4. SOURCES AND HOW WE COLLECT INFORMATION
We collect information:
- through contact with you, your advisers and with businesses you are associated with
- from the evaluation and completion of investment transactions including information provided during the due diligence process
- from public domain sources, such as social media and newspaper reports
- from third party sources, such as the providers of databases like Worldcheck and C6 Intelligence which we use to assist us in undertaking investment due diligence and background checking.
5. HOW WE USE INFORMATION
We use personal information for a number of purposes relating to our interest in operating and promoting our business. In doing so, we balance our appropriate business needs with your right to have your information handled in a way which does not unreasonably prejudice your interests.
- to evaluate and execute potential investment opportunities
- to operate and manage our investments
- to carry out market research, business and statistical analysis
- to comply with best practice and standards in making investment decisions
- to comply with applicable law, regulation and internal compliance relating to the prevention of fraud, tax evasion, bribery and corruption, money laundering and terrorist offences or relating to cyber or data security.
The most common use of personal information is as an input to our opinion on whether to pursue, or complete, an investment transaction and if so, on what terms. We may decide not to pursue an investment transaction (or be unable to do so for legal or regulatory reasons) as a result of due diligence and background check enquiries (and the information revealed by those enquiries).
We are required to use certain personal information in order to comply with legal obligations to which we are subject. If we contract with you directly, we will use personal information in order to perform our contractual obligations.
We only collect and process "special categories" of information (such as information regarding political affiliations) when we have been provided with it by third party providers of due diligence and background checking data services, from information which is in the public domain. You can complain to us about our use of information about you received from third party providers of data services, or to the providers themselves (Worldcheck and C6).
6. LINKS TO OTHER WEBSITES
Our website contains links to other websites. Any such links are provided for your convenience only. We are not responsible for privacy policies or practices of other websites to which users choose to link from our website. We encourage users to review the privacy policies of those other websites to understand how they collect, use and share personal information. Furthermore, we have no control over third party websites and accept no legal responsibility for any content, material or information contained in them. Your use of a third party site may be governed by the terms and conditions of that third party site.
7. MARKETING COMMUNICATIONS
We may use your information to send you emails, for example, with newsletters and invitations to events, and if you do not wish to receive these kinds of communications, you can opt out of our mailing list.
8. SHARING INFORMATION
We may share information with other companies in the Fidelity International group and with our sister firms, Eight Roads and FMR LLC (and members of their groups) and with associated entities.
We may share information collected as detailed under Section 3 of this policy in order to comply with legal and regulatory obligations and best practice in relation to investment due diligence and decisions. We may share information with third party suppliers or service providers, for example, legal advisers, but this will be limited to the amount of information needed for that third party to carry out the relevant function. We may also share information with third parties where you have authorised us to do so, such as providing information for the purposes of completing tax returns.
If you would like more details about our sharing of personal information, please contact us as set out in Section 1 of this policy.
9. OUR RETENTION OF INFORMATION
We retain information we collect for as long as is reasonably necessary to comply with the purposes set out in Section 5 of this policy.
We have implemented reasonable technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure. These include the anonymization of information where appropriate and the encryption of all personal information stored in our systems.
In accessing our website, because the internet is an open system, we cannot guarantee that unauthorised third parties will never be able to defeat those measures or use our website users' personal information for improper purposes.
11. TRANSFERS OF INFORMATION
As part of our investment process, it is necessary to transfer your personal data across national borders. These transfers may involve at least one of Fidelity’s Group entities operating in the UK and EEA and as such will apply the European standard of protections to the personal data we process. In practice, this means that all the entities in the Fidelity Group agree to process your personal data in line with high global standards. Where your personal data is transferred within the Fidelity Group but outside of the UK and EEA, that data subsequently receives the same degree of protection as it would in the UK and EEA.
Where it is necessary to transfer personal data to a third party, stringent reviews of those with whom we share the data are carried out and that data will only be transferred in line with the purpose for which it was collected.
12. YOUR RIGHTS
You have a right to:
- access information we hold about you, and know for what purpose we use that information
- correct inaccuracies in information we hold about you
- withdraw any consent you have given to use of your information
- complain to the relevant supervisory authority in any jurisdiction about our use of your information
- in some circumstances:
- request that we erase information we hold about you
- receive a copy of any personal information provided by you and require us to provide this information to a third party
- restrict the use of information we hold about you
- object to the use of information we hold about you, including where that information is used for direct marketing purposes.
You can exercise these rights by contacting us as detailed under Section 1 of this policy.