Privacy Policy

ICF Trustees (“We”) are committed to protecting and safeguarding your personal data. As part of this commitment, we have updated our privacy policy to meet the high standards of the new European data protection law, known as the General Data Protection Regulation (GDPR).

Our updated policy explains your rights under this new law and will become effective on May 25th 2018.

To review the updates, or if you have any questions or would like to contact us, please refer to our updated Privacy Policy below.

Privacy Notice

Introduction

ICF Trustees respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, whether obtained directly from you or from third party controllers and tell you about your privacy rights and how the law protects you.

Please use the Glossary below to understand the meaning of some of the terms used in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT AND / OR PROCESS
HOW IS YOUR PERSONAL DATA COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how ICF Trustees collects and/or processes your personal data.

Controller/Processor

ICF Trustees d acts as both controller and processor and where applicable to you, we are responsible for your personal data (referred to as “ICF Trustees ”, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are

ICF Trustees

C/O Innovation Capital Finance Limited

63/66 Hatton Garden

Fifth Floor

Suite 23

London

EC1N 8LE

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We ensure that we are compliant with data protection legislation. As such our privacy notice may be updated accordingly.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect and/or process

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username, marital status, title, date of birth, nationality and gender.
Contact Data includes residential address, billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from individuals.
Technical Data includes internet protocol (IP) address when data is requested from our server. This is using the standard IIS logs. No other data is collected by us. We have a payment portal hosted by a third party who uses cookies to keep track of the user’s payment progress, which is then deleted after the session ends.
Profile Data includes your username and password, transactions made by individuals.
Usage Data includes resources downloaded by website users (pictures, pages, etc).

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We may collect any Special Categories of Personal Data about you (this may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We may also collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you or a contract you have with a third-party controller for whom we process your data and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, website or otherwise.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from marketers/sales agents who collect your data on behalf of a third-party controller.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you or you have entered into with a third-party controller.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest To register you as a new customer(a) Identity
(b) Contact Performance of a contract with youTo process your data in respect of your shared leisure purchase:
(a) Register your ownership, identify and distribute funds,raise invoices and collect funds(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Profile(a) Performance of a contract with a third-party controller who collected your data where we are acting as processor.To manage our relationship with you as a customer which will include:
(a) Updating our terms or privacy policy
(b) Collect and recover money owed to us(a) Identity
(b) Contact
(c) Financial
(d) Transaction(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(b) Contact
(c) Technical(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing and Promotional offers from us

We do not currently market or provide promotional offers to individuals that we hold personal data on.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside ICF Trustees for marketing purposes.

Opting out

Where you have provided your express opt-in consent, you can ask us or third parties to stop sending you marketing messages at any time. Please contact us in this regard.

Cookies

Our website does not use cookies. However, our online payment portal is run by a third-party which does use session cookies to keep track of your transaction. These session cookies are deleted when you close your browser.

Change of purpose

We will only use your personal data for the purposes for which we collected it or processed it on behalf of third party controllers, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

The processing of your personal data by external third parties may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

The processing personal data occurs in a territory which is subject to a current finding by the European Commission under the data protection legislation that the territory provides adequate protection for the privacy rights of individuals; For further details see European Commission; Adequacy of the protection of personal data in non-EU countries; or
A valid cross-border transfer mechanism under the data protection legislation is in place, so that appropriate safeguards ensure an adequate level of protection with respect to the privacy rights of individuals; or
There are binding corporate rules in place in accordance with applicable data protection legislation; or
The European Commission’s Standard Contractual Clauses have been used which give personal data the same protection it has in Europe; or
The transfer otherwise complies with the data protection legislation.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for audit purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we may securely archive all or any personal data in our possession or control for twelve years, after which it shall be securely deleted or destroyed or, if directed in writing by the Customer, returned to them.In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

Request access to your personal data.This is commonly known as a “data subject access request”.

It enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of your personal data.

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data.

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data.

You are able to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data.

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data to you or to a third party.

If requested,we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent.

You are able to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

This is not currently applicable.

External Third Parties

Professional services including lawyers, bankers, auditors, IT providers and insurers who provide consultancy, banking, legal, insurance, IT and accounting services.
HM Revenue & Customs, regulators, fraud prevention agencies and other authorities based in the United Kingdom or in other worldwide locations who require reporting of processing activities in certain circumstances.

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Privacy Policy

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