Revcap Advisors Limited and Real Estate Venture Capital Management LLP ("Revcap", "we", "us", "our" and "ours") are committed to maintaining the accuracy, confidentiality and security of all personal information entrusted to us.
We collect personal information in the normal course of business to better serve and manage the needs of our clients, business partners and employees, and to fulfil our regulatory obligations. We do not sell personal information to anyone.
This statement describes how we collect and use personal data about you, in accordance with the Data Protection Act 1998 ("DPA") and, from 25th May 2018, the General Data Protection Regulation ("GDPR"), and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK ("Data Protection Legislation").
In this privacy statement the terms "consent", "controller", "personal data", "personal data breach", "processor", "processing" and any other term expressly defined in Article 4 of the GDPR, have the meanings given to them in Article 4 of the GDPR.
Personal data can be defined as any information relating to a living person who can be identified directly or indirectly from that information; for example, their name, address, date of birth, or online identifier such as an email address.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
For the purposes of the Data Protection Legislation and this statement, we are the data controller. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy statement.
Should you wish to contact us in relation to this privacy statement or our treatment of your personal data, you can do so using the details noted in section 12 of this document, below.
We may obtain personal data about you, for example:
The information we hold about you may include the following:
We may process your personal data for purposes necessary for the performance of our contracts with you or your employer or our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contracts with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our clients.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this statement, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
Why we might share your personal data with third parties
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process your personal data
"Third parties" includes third-party service providers and other entities within our group. The following activities are carried out by third-party service providers: IT services, professional advisory services, administration services, and insurance brokerage services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
Other third parties
We may share your personal data with other third parties, for example we may also need to share your personal data with a regulator or to otherwise comply with the law.
In certain circumstances, we may transfer the personal data we collect about you to the following countries outside of the EEA:
in order to perform our contracts with you.
There is an adequacy decision by the European Commission in relation to these countries, therefore they will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
We have put in place commercially reasonable and 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Please inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware, using the details noted in section 12 of this document, below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
If you want to exercise any of the above rights, please let us know using the contact details noted in section 12 of this document, below.
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using the details noted in section 12 of this document, below.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
This privacy statement was last updated on 22nd May 2018. We may update this privacy statement at any time by publishing an updated version on our website at https://www.revcap.co.uk/.
If you have any questions regarding this statement or if you would like to speak to us about the manner in which we process your personal data, please contact us by either:
You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO's contact details are as follows:
Information Commissioner's Office
Telephone - +44 (0) 303 123 1113 (local rate) or +44 (0) 1625 545 745 (national rate)
Website - https://ico.org.uk/concerns
Revcap Advisors Limited
105 Wigmore Street
London W1U 1QY
Tel: +44 (0) 20 7495 6335