ProVen VCTs Privacy Notice & LEGAL INFORMATION
ProVen VCTs Privacy Notice
Scope and purpose
This Privacy Notice applies to ProVen VCT plc and ProVen Growth and Income VCT plc, and www.provenvcts.co.uk and related websites (the “Website”) (together the “ProVen VCTs”, “we”, “us”, “our”). It explains how the ProVen VCTs collect, use, share and otherwise process your Personal Data in connection with your relationship with us.
ProVen VCT plc is a public limited company registered in England and Wales with company number 3911323 and whose registered office is 39 Earlham Street, London WC2H 9LT. ProVen Growth and Income VCT plc is a public limited company registered in England and Wales with company number 4125326 and whose registered office is 39 Earlham Street, London WC2H 9LT. The Website is owned by Beringea LLP (“Beringea”), a limited liability partnership registered in England and Wales with company number OC342919 and whose registered office is 39 Earlham Street, London WC2H 9LT. Beringea is authorised and regulated by the Financial Conduct Authority (reference number 496358). Beringea provides investment management or other services to a number of companies and funds and to the extent that Personal Data is provided to companies and entities other than the ProVen VCTs, separate privacy notices will apply.
Should you have any questions about this Privacy Notice you can contact us at the address above, by telephone on +44 (0)20 7845 7820 or by email at email@example.com.
We may provide supplemental privacy notices on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. Those supplemental notices should be read together with this Privacy Notice.
The term “Personal Data” as used in this Privacy Notice means any information which relates to a living individual who can be identified from that data such as name, contact details, bank account details etc. Personal Data does not include data from which you can no longer be identified such as anonymised aggregate data.
What information do we collect about you, how do we collect it and what do we use it for?
We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:
a) if you have consented to us doing so;
b) if we need it to perform the contract we have entered into with you;
c) if we need it to comply with a legal obligation; or
d) if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests will be the provision of services by us, or Beringea or other third parties carrying out services on our behalf.
Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
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 Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
Accuracy of information
It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.
Security of information
We implement appropriate technical and organisational measures in order to protect your Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and measures adopted to protect your Personal Data are appropriate for the risks presented by the nature and use of your Personal Data. We follow recognised industry practices for protecting our IT environment and physical facilities.
What if you do not provide the personal data we request?
It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to provide all or some of our services, to enter into a contract with you or to send other information to you.
Change of purpose, anonymisation
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. 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.
In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
With whom will we share your information?
When using your Personal Data for the purposes and on the legal basis described above we may share your Personal Data with services providers we work with. We may also have to share your Personal Data with regulators, public institutions, courts or other third parties.
For the purposes described above we may have to transfer your Personal Data from the European Economic Area (EEA) outside of the EEA and in a jurisdiction not being subject to an adequacy decision of the European Commission. We will always ensure that there is a legal basis and a relevant safeguard method for such data transfer so that your Personal Data is treated in a manner that is consistent with, and respects the EU laws and other applicable laws and regulations on data protection.
Your rights in relation to your information
You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:
a) request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
b) request rectification of your Personal Data;
c) request the erasure of your Personal Data;
d) request the restriction of processing of your Personal Data;
e) object to the processing of your Personal Data.
If you want to exercise one of these rights please contact us at firstname.lastname@example.org.
You also 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, or, as the case may be, any other competent supervisory authority of an EU member state.
Right to withdraw consent
In case you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. To withdraw your consent, please contact email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
How long will we retain your information?
We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
To determine the appropriate retention period for your Personal Data, we will 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.
In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.
You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Notice. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Changes to this Privacy Notice
We reserve the right to update this Privacy Notice at any time, and we will make an updated copy of such privacy notice available on the Website.
If you have any concerns or require any further information, you can contact us at the address above, by telephone on +44 (0)20 7845 7820 or by email at firstname.lastname@example.org.
The information in this website does not constitute an invitation, inducement or offer to engage in investment activity, or to subscribe for or purchase shares or other securities. It is intended for general information purposes only and not as investment, or other advice, and is not to be relied upon in connection with any investment decision.
A VCT investment is therefore not suitable for all individuals.Any potential investor should seek independent, professional financial advice and read the relevant prospectus or offering memorandum prior to making an investment decision.
This site is aimed at persons for whom VCTs may be an appropriate investment. Whilst all retail investors may potentially invest in VCTs, they carry a higher risk than many other forms of investment and they may only be suitable for certain retail investors. They are unlikely to be suitable for investors who may need access to funds in the short term and the underlying nature of the investment into smaller companies may increase the risk of financial loss. Therefore, VCT shares are appropriate for more sophisticated investors with significant investment portfolios, who are able to take a longer term view and understand the risk-return of investing in smaller companies and the tax advantages of the VCTs.
The FCA has confirmed that VCT shares are to be treated as “Excluded Securities” in terms that they are not subject to the investment restrictions applied to Non-Mainstream investment Products.
The ProVen VCTs are managed by Beringea LLP, a specialist private equity fund manager based in the UK which is authorised and regulated by the Financial Conduct Authority (FCA). Beringea LLP's FCA Firm Reference Number is 496358.
The value of shares in a VCT and the income from them may fluctuate and investors may not get back the amount they invested. The market price of VCT shares is unlikely fully to reflect their underlying net asset value. It is possible that there may not be a liquid market in the shares of VCTs and shareholders may have difficulty in selling their shares. Any sale is likely to be at a discount to net asset value.
VCTs invest in a portfolio of small companies, which by their nature carry greater risk than larger, quoted companies.
Due to a number of the features and risk factors associated with VCTs, it is an investment that is not suitable for all investors. Potential investors who are in any doubt about what action to take should consult an authorised financial advisor.
To comply with the requirements of the Data Protection Act 1998, we adhere to strict security procedures and have taken all measures to ensure that no unauthorised disclosures of your details are made to a third party without your permission and unauthorised access to it is prevented.
Any information you provide to us will be used to administer your requirements for information from us. Occasionally, we may also use your details to inform you of other features, services and products which we think you may be interested in and we may contact you by post, fax, email or telephone. We will keep your personal information confidential except to the extent that we are compelled to disclose it by law or to comply with an instruction of a regulatory body of competent jurisdiction. To comply with the requirements of the Data Protection Act 1998, we adhere to strict security procedures and have taken all appropriate measures to ensure that no unauthorised disclosures of your details are made to a third party without your permission and unauthorised access to it is prevented.
Reasonable care has been taken to ensure that the information available on this site is correct and up-to-date. However, since some of the information has been sourced from third parties and certain data may not have been updated, we make no representation or warranty of any kind regarding the information on this site.
You should therefore be aware that certain information may be out of date, incomplete or incorrect and therefore should be independently verified or verified directly with us before taking any action in reliance on it.
Exclusion of Liability
- Where the site contains links to another website and other data, these links are provided for your information only. We accept no liability for any information or content in them and may have not control over them.
- No recommendation, commentary or other information contained on this site should be considered to be advice on which you should place reliance.
- In using this website, it is a condition that you accept, as reasonable terms, that we have no liability and this includes all costs, losses, damages and expenses of any kind, including any loss of profit or economic loss and any consequential loss of any kind.
- Furthermore, we are not liable as a result of any loss or damage sustained through our website being subject to third party cyber/computer attack or hacking which may affect your equipment and/or data or other assets or proprietary material due to your use of our site or downloading any material from our site.
Issued by Beringea LLP which is authorised and regulated by the Financial Conduct Authority registered number: 496358
What are ‘Cookies’?
A cookie is a text file saved to your computer's hard disk by a website so it can remember who you are. Cookies only record pages of a website that have been visited by your computer and the duration of the visit to those pages. These remain on your computer until you leave the website and allow you to carry information across pages of the website without having to re-enter information, for example when putting items into a shopping basket, or logging in to a site. Some cookies will stay on your computer after leaving the website. For a more detailed explanation, see the types of cookies below.
Also called a transient cookie, a cookie that is erased when you close the web browser. The session cookie is stored in temporary memory and is not retained after the browser is closed. Session cookies do not collect information from your computer. They typically will store information in the form of a session identification that does not personally identify the user.
Also called a permanent cookie, or a stored cookie, a cookie that is stored on your hard drive until it expires (persistent cookies are set with expiration dates) or until you delete the cookie. Persistent cookies are used to collect identifying information about the user, such as web surfing behavior or user preferences for a specific website.
What is the new directive?
Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.
What does it relate to?
This directive relates to website users’ consent of Cookies created by a website.
For more detailed information about cookies, how they work on your computer and how to delete them or allow them to remain on your computer, please visit www.ico.gov.uk/cookiesadvice