The Fund Incubator Privacy & Cookie Policy
TFI Privacy Policy:
Privacy Notice:
The Fund Incubator Limited [“TFI”] respects the privacy of every individual whose personal information it handles. This Privacy Notice explains how TFI collects, stores and uses that personal information and sets out our approach to the General Data Protection Regulation and UK laws such as the Data Protection Act.
About us:
This site, is owned and operated by TFI. TFI is the data controller for the purpose of the Data Protection Act 1998 and the General Data Protection Regulation.
Please note that our website and other digital platforms may contain links to third party websites / digital platforms which are provided for your convenience. We are only responsible for the privacy practices and security of our own digital platforms. We recommend that you check the privacy and security policies and procedures of each and every other website / digital platform that you visit.
Business Contacts:
As a part of its day to day operations TFI meets large numbers of business contacts at meetings and receives emails about investment opportunities. It is likely to receive and store personal information on those it meets.
If you have had contact with TFI, for example through emailing us or meeting a colleague, it is likely that we will want to make a note of that email or meeting and may store limited amounts of personal information relating to you, such as your name, job title, employer organisation and contact details.
We will collect and store this personal information for the purposes of:
- maintaining a record of contacts;
- providing periodic business updates;
- drawing to your attention working opportunities which may be of mutual benefit to us as described below; and
- organizing meetings with you.
The personal information we hold about business contacts may be shared with:
- professional advisors;
- companies who hold or ‘process’ personal information on our behalf, or cloud-based products such as Microsoft 365.
The legal basis for collecting and storing such personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.
Personal Information Of Suppliers And Professional Advisors:
As a part of its day to day operations TFI is likely to receive and store personal information to enable it to buy office and other supplies or engage with professional advisors.
If you are a supplier or professional advisor to TFI, we will capture and use limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation and contact details. We will store this personal information for the purposes of administering and maintaining records of services or advice we have received and commissioning further services.
The personal information we hold about suppliers and professional advisors may be shared with:
- other professional advisors;
- companies who hold or ‘process’ personal information on our behalf, or cloud-based products such as Microsoft 365;
We store and process information in this way because it is necessary to:
- perform a contract to which you are likely to be a party;
- comply with a legal or regulatory obligation; and/or
- protect our legitimate interests in running and promoting our business.
Personal Information Collected During A Transaction
TFI is likely to receive and store personal information as part of its investment evaluation process including undertaking legally required ‘Know Your Customer’ checks to help prevent money laundering and other forms of financial crime.
If you are involved in a transaction that TFI and/or the funds that it manages or advises enters into, or a potential transaction that TFI considers, we may store personal information relating to you. This might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out.
We collect and store this information for the purposes of:
- evaluating a transaction and your role in it;
- executing transactions;
- managing an investment once made;
- maintaining records of investments;
- meeting regulatory and legal obligations eg KYC checks;
- safeguarding our legal rights and interests;
- seeking and receiving advice from our professional advisors, including accountant’s lawyers and other consultants; and
- providing periodic business updates, as described below
The personal information we hold about the members of a management team teams may be shared with:
- professional advisors, such as accountants, lawyers or other consultants;
- financial intermediaries;
- credit and other reference agencies;
- other persons who have an interest or involvement in, or who are considering an interest or involvement in, a TFI transaction, including co-investors, other providers of finance and investors in TFI’s funds;
- companies who hold or ‘process’ personal information on our behalf, or cloud-based products such as Microsoft 365.
We store and process information in this way because it is necessary to:
- perform a contract to which you are likely to be a party;
- comply with a legal or regulatory obligation; and/or
- protect our legitimate interests in running and promoting our business.
Personal Data Collected During Visits To Our Website:
When you interact with our digital platforms, we may also automatically collect the following information about your visit. This is primarily to help us better understand how people use our digital platforms to enable us to create better content and more relevant communications:
- how you have reached our digital platform and the internet protocol (IP) address you have used
- your browser type, versions and plug-ins, and your operating system
- your journey through our digital platform, including which links you click on and any
- searches you made, how long you stayed on a page, and other page interaction information
- what content you like or share
- information collected in any forms you complete
Mandatory Provision Of Information:
In some cases, we will not be able to deal with you further without receiving certain information – eg ‘Know Your Customer’ information. In such circumstances we will explain this to you including the possible consequences of not providing particular information. In any event TFI will only process the personal information you provide to TFI for the purposes listed above.
Sensitive Or Special Category Personal Data:
TFI avoids wherever possible receiving information on race, religion, political views and your mental or physical health.
International Transfers Of Personal Information:
TFI is based in Europe and does not anticipate transferring your personal data outside the EEA.
Where we transfer personal information to other third parties outside of the EEA, we will ensure that those transfers take place in accordance with the Data Protection Laws, including by entering into data transfer agreements with recipients. If you would like more information about how your personal information may be transferred, please contact us using the information below.
Keeping You Informed:
We wish to build a long-term relationship with you and would like to use personal information that we hold to send you updates about our business, activities and opportunities to work together. We would usually do this by email and/or post. You can opt out of receiving updates at any time by contacting us using the information below, or by clicking the “Unsubscribe” link in any email that you receive.
Retention Of Personal Information:
The period for which TFI will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation.
Your Rights to See and Correct Data:
As a ‘Data Subject’ you have a number of important rights:
- to access your personal information;
- to request that it is erased;
- that its processing is restricted to the purpose for which it was given and;
- that any inaccurate personal information is rectified.
In the first instance please contact us on Barry.lawson@thefundincubator.com. Please note that these rights are subject to some statutory qualifications.
Security:
We will take all reasonable steps to protect the confidentiality and security of your personal information but cannot guarantee the security of any that you disclose online for example when it is sent by email. You accept the inherent security risks of providing information online over the Internet and will not hold TFI responsible for any breach of security unless this is due to TFI’s negligence or wilful default.
When you submit your data to us, we use industry standard Secure Sockets Layer (SSL) encryption technology to guard your information. In addition, we have security procedures in place to protect our paper based systems and computerised databases from loss and misuse, and only allow access to them when it is absolutely necessary to do so, and then under strict guidelines as to what use may be made of the personal information contained within them.
Where a password is required to access certain areas of our digital platforms, you are responsible for keeping your password secure and confidential. Please do not share or disclose your password to any other person.
Questions And Further Information
If you have any questions about this Privacy Notice or about your personal data, please email us at Barry.lawson@thefundincubator.com or write to us at the following address:
The Fund Incubator Limited
C/o Mainspring Fund Services
27 Furnival Street
London
EC4A 1JQ
United Kingdom
Changes to TFI’s Privacy Notice:
We aim to meet high standards and so our policies and procedures are constantly under review. From time to time we may change this privacy notice. Accordingly, we recommend that you check this page periodically in order to review the latest version.
Where To Make A Complaint:
If you have a complaint regarding any aspect of your personal data or this privacy policy, please write to us at the above address. If you are still not satisfied with the outcome of your complaint, you may write to the Information Commissioner’s Office at the following address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
TFI Cookies Policy:
Introduction:
Our site uses cookies to distinguish you from other users of our site and to save and retain information about you and your usage of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. By continuing to browse the site, you are agreeing to our placing cookies on your computer, subject to the terms of this policy.
In this section we set out details of the cookies we use on our site.
| Cookie Name | Purpose | Controller | Further Info (including duration) |
| SERVERID | Functional – to provide load balancing functionality | Our Cookie | Persistent |
| Cookie_notice_accepted | To read if cookies can be placed | Our Cookie | Run for 30 days, reacceptance after each period requested |
Dated: August 2022