We will ensure that your personal information is handled in accordance with any legislation applicable from time to time relating to the processing of personal information and/or privacy. By using our Website and by otherwise interacting with us, you acknowledge that we may collect, use and transfer your personal information as set out in this policy. This policy may be amended at any time without notice. If you are not happy with the terms of this policy or any amendments made, you should not access or use our Website and/or our services.
1. Personal Information You Provide To Us
When you engage with us (e.g. sending us emails, contacting us via telephone or visiting or making an enquiry through the Website), you may provide personal information about yourself. Personal information means any information relating to a living individual and from which that individual can be identified. We may collect, store and use different categories of personal information about you including your name and contact details (e.g. your address, email address and telephone number).
Certain personal information may be collected passively through the use of our Website, including your Internet protocol address, browser type, domain names, times, and operating system. We may also use session and persistent cookies and navigational data (such as URLs) to gather information regarding the date and time of your visit and the information and services for which you searched and which you viewed. We do not intentionally gather personal information about visitors who are minors.
Where you apply for a job with us through our Website, we may collect from you and third parties (where relevant) additional personal information such as your CV and any references.
Unless you agree that we can keep such information on file for future opportunities or we need to retain such information for compliance with our legal obligations, in the event that you are unsuccessful, we will only retain this personal information for as long as is reasonably necessary to process your application.
2. Information Received From Other Sources
We may receive information from third parties who collect personal information from you and pass it on to us. For example: (i) where we are conducting due diligence on prospective investee companies or deciding whether to invest in third parties we may also receive personal information concerning key personnel; (ii) our staff may also give us emergency contact information as part of our emergency scenario planning and may give us details of their dependents and of other people in relation to their employee benefits arrangements; (iii) where another individual makes an investment on your behalf, they may provide us with certain personal information to effect the transfer of the investment to you, such as your name and contact details; (iv) your employer may provide your personal information to us in connection with a service they provide to us or in connection with services that we provide to our clients; and (v) we may receive information from past employers and others concerning your employment history where you apply for a job with us. Where this is the case the third party is responsible for informing you that they have shared your personal information with us, directing you to this policy and obtaining any relevant consents from you to ensure you are happy with the ways in which your personal information will be used. However, once we are holding it, we will only handle any person’s personal information in accordance with this policy.
3. Sensitive Personal Information
You may provide us with “sensitive personal information” (i.e. personal information concerning an individual’s (i) racial or ethnic origin, (ii) political opinions, (iii) religious beliefs or other beliefs of a similar nature, (iv) membership of a trade union, (v) physical or mental health or condition, (vi) sexual life or orientation, (vii) commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed by him/her, the disposal of such proceedings or the sentence of any court in such proceedings) from time to time in connection with your application to invest with us, our provision of investment services to you, where you apply for a management role as a director of one of our portfolio companies or otherwise. In such cases, the provision of this information is entirely voluntary and subject to your express consent, however, we may be unable to carry out some activities necessary to process your application, instructions or other requests without the provision of such information. For example, we may be unable to process application forms or similar requests. We will use any sensitive personal information in accordance with the consent you have given and, where necessary, we may also process such information in the establishment, exercise or defence of legal claims.
Where we do receive sensitive personal information, we will only keep such information for as long as strictly necessary in order to comply with our obligations under the law.
4. Use of Information
Some of the personal information is collected and processed so we can perform a contract with you, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (namely to carry out and improve our business, analyse the use of our Website and services and support our staff and clients). In general, any information gathered is used either to respond to inquiries and requests that you make, to enable us to manage and administer investments or proposed investments on an ongoing basis, to aid us in providing better services to you, to improve our Website and services, to comply with our own legal and regulatory obligations, for our internal business processes and, where relevant, to process your application for employment.
Where you have explicitly consented at the time we collected your personal information or where we otherwise have a right to do so, we may also use your personal information to enable us to get in contact with you to let you know about any of our services that may be of interest to you and/or inform you about important changes or developments to our services by email.
Where you or your employer (or any other entity you work for) provides services to us, you and/or they may provide us with some of your personal information in connection with the provision of the services, such as your name, business contact details and other ID information. We will only process such personal information in connection with the provision of the services (such as using your contact details to discuss the services) and in accordance with this policy. In addition, where necessary, we may also share your personal information with our investors or other third parties in order to provide our services (e.g. if you or your business provides investor administration services, we may share your business contact details with our investors so that they can contact you).
If you change your mind about us using your personal information in the ways described in this Policy, please let us know by contacting us at [email protected]. You may also opt out of receiving marketing emails from us by following the instructions outlined in the email.
5. Disclosure of Personal Information
Any personal information provided to Bluewater will be transferred to and stored on Bluewater’s physical servers in the UK and also on cloud based servers within the UK. Backups of our data is held on cloud based servers within the EU. Any personal information provided to a fund will be transferred to and stored in Jersey. We take steps to protect your personal information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your personal information with certain third parties, such as our delegates, professional advisors, service providers, regulatory bodies, auditors, technology providers and any duly authorised agents or related, associated or affiliated companies of the foregoing for the same purposes.
In processing your personal information, it will sometimes be necessary for us to transfer your personal information outside the European Economic Area (“EEA”) to our staff and our third party service providers. It may also be accessed by staff operating outside the EEA who work for us or for one of our suppliers or group companies. This includes people engaged in, among other things, the provision of support services to us. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this policy and relevant data protection legislation when it is processed in, or otherwise accessed from, a location outside the EEA. This means that we will only transfer your personal information outside the EEA including to our group companies / funds if the receiving party (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to Personal Information, (b) has agreed (by way of written contract incorporating the “model clauses” as approved by the European Commission or by some other form of data transfer mechanism approved by the European Commission) to provide all protections to your personal information as required by applicable data protection legislation or (c) we have your explicit consent to do so (such as where you have requested a service from one of our funds situated outside the EEA). Where any transfer takes place under a written contract, you have the right to request a copy of that contract and may do so by contacting us at [email protected]. For the avoidance of doubt, in the event that the UK is no longer a part of the EEA, references in this paragraph to the EEA shall mean the EEA and the UK.
By submitting your personal information to us, you acknowledge this transfer, storing or processing of your personal information.
Bluewater is committed to protecting the security of your personal information. We use a variety of industry-standard security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. Even though Bluewater has taken significant steps to ensure that your personal information is not intercepted, accessed, used, or disclosed by unauthorized persons, you should know that Bluewater cannot fully eliminate security risks associated with personal information.
If you use our Website, you acknowledge that you will receive cookies from our Website but such cookies will not collect any personal data.
8. Data Storage
9. Your Rights
You have the right to ask us not to process your personal information for marketing or research purposes. If you have given us your express consent, or where we otherwise have the right to do so, we may use your personal information for marketing purposes. If we intend to disclose your personal information to any third party for marketing purposes, we will seek your explicit consent prior to any such transfer. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. You can also exercise the right at any time by contacting us at [email protected].
You are entitled to know some details about the personal information we hold about you and how that information is processed. If you would like to request this, please contact us at [email protected] and we will provide you with the information to which you are entitled.
You can also ask us to: (a) make any changes to ensure that any personal information we hold about you is accurate and up to date; (b) erase or stop processing any personal information we hold about you where there is no longer a legal ground for us to hold it; or (c) in some circumstances, transfer any information we hold about you to a specified third party. If you wish to exercise any of these rights, please contact us at [email protected].
10. Contact Information
If you have any questions or complaints regarding the use of or your rights regarding your personal information, please contact Bluewater at [email protected]. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues.
Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any personal information via these websites.