NEO Privacy Terms
NEO Investment Partners LLP (“NEO”) is committed to respecting and protecting the privacy of anyone and the confidentiality of any personal information that you provide us with. In all our dealings with your personal data we comply with EU General Data Protection Regulation and, as amended and supplemented from time to time and other relevant applicable laws binding upon us (“Privacy Laws”).
The purpose of this statement is to set out how we use any personal information that we may obtain from you and explain:
· who is collecting data
· what information we collect about you
· how we will use this information (and on which basis we will use it)
· how data is stored and who it could be shared with
· website and cookies
· your rights and how to exercise them
If you are our business contact or a candidate and have met us, telephoned us or e-mailed us for business-related purposes, we will store limited personal information about you, such as your name, title, firm you represent (if applicable) , your résumé (if applicable) and your contact details. We will use this information for the purpose of maintaining a record of contact, organising meetings and providing potential business updates. This personal information is recorded on paper and in our IT systems in accordance with our data retention policy. We may share this information with our data processors such as IT service providers and professional advisors (such as lawyers, accountants, auditors, tax advisors) and consultants. Our legal basis for processing this information about you is our legitimate interest relating to managing and promoting our business.
If you are our supplier or advisor to NEO we will store limited personal information about you, such as your name, title, firm you represent and your contact details for the purpose of maintaining and managing the record of your services or advice, maintaining contact with you, organising meetings and providing potential business updates. This personal information is recorded on paper and in our IT systems in accordance with our data retention policy. We may share this information with our data processors such as IT service providers and professional advisors (such as lawyers, accountants, auditors, tax advisors) and consultants. Our legal basis for processing this information about you is (i) exercising our rights and obligations under a contract we may have with you (ii) our legitimate interest relating to managing and promoting our business.
If you are a member of a team of our current or potential investments we may store personal information relating to you, if you are involved in a transaction that NEO (or any of the funds or entities it manages) considers or enters into. This information nay include your name, contact details, your résumé, previous professional experience, nationality and identity information (including copies of identity documents, such as a passport), financial status, references provided by third parties, and results due diligence and anti-money laundering procedures we may need to carry out. We will collect and store this information for the purposes of:
assessing potential transactions;
maintaining records of our investment process;
managing any transactions that we enter into and projects our funds invest in;
assessing your suitability for involvement in a transaction;
complying with our regulatory and legal obligations, including assessing and managing risk;
safeguarding our legal rights and interests;
seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
maintaining business contact.
This personal information is recorded on paper and in our IT systems in accordance with our data retention policy. It may be shared with our data processors such as IT service providers and professional advisors (such as lawyers, accountants, auditors, tax advisors) and consultants, credit reference agencies, due diligence advisors, financial intermediaries, our investors, co-investors and other providers of financing.
Our legal basis for collecting and storing personal information about you is that such processing is necessary for (i) complying with our regulatory and legal obligations, (ii) our legitimate interests in running our business, and, if we enter into a transaction involving you, (iii) exercising any contractual rights and obligations we may have relating to such transaction.
If you are an investor in any funds or entities we manage and hold your interests directly or through the nominee accounts, we store personal information about you such as your name, title, your contact details and such identity, financial and other details about you that you provided to us in your subscription documents and during the due diligence process. We will store, maintain and process your data for the purposes of communicating with you, complying with our regulatory and legal obligations relating to our relationship with you as well as facilitating the transactions relating to your investment.
This personal information is recorded on paper and in our IT systems in accordance with our data retention policy. It may be shared with our data processors such as IT service providers and professional advisors (such as lawyers, accountants, auditors, tax advisors) and consultants.
Our legal basis for collecting and storing personal information about you is that such processing is necessary for (i) complying with our regulatory and legal obligations, (ii) exercising contractual rights and obligations we may have under an agreement with you (iii) our legitimate interests in managing our business and communicating with the investors.
Without prejudice to any communications made to comply with legal or contractual obligations, any personal data NEO processes may also be disclosed to external parties as required by laws or regulations (e.g. court, tribunal, Regulatory Authority or Governmental Entity).
NEO will retain personal information for such period as may be necessary (i) for the purpose it was collected for and (ii) to comply with the requirements of the applicable laws and regulations, in line with our Data Retention Policy.
NEO and its operations are based in the United Kingdom. In limited circumstances we may transfer certain personal information outside of the EEA. Where we do so, we ensure that these transfers take place in accordance with the applicable Privacy Laws, including entering into data transfer agreements.
NEO Website
You can visit our Website without telling us who you are and without revealing any information about yourself. We do not collect any personal data about our visitors through NEO website. We may, however, collect some anonymous information through our use of ‘cookies’.
NEO website may contain hypertext links to external websites. NEO is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.
Cookies
Most websites use cookies in order to make them work, or to work more efficiently, as well as to provide statistical information to the owners of the website. They help us to understand how our visitors use our website so we can develop and improve the design, layout, content and function of the site. Cookies are small text files that are placed on your computer’s hard drive by websites that you visit. They save and retrieve pieces of information about your visit to the website – for example, how you entered the site, how you navigated through the site and what information and documentation was of interest to you. This means that when you go back to a website, it can give you tailored options based on the information it has stored about you on your last visit. Our website uses cookies to help improve your experience on our website and also allows us to improve our site.
We use the following cookies:
· Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
· Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
· Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
NEO website currently uses the following cookies:
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
If you are uncomfortable with the use of cookies, you can disable cookies on your computer by changing the settings in the preferences or options menu in your browser. You can set your browser to reject or block cookies or to tell you when a website tries to put a cookie on your computer. You can also delete any cookies that are already stored on your computer’s hard drive. However, please be aware that if you do delete and block all cookies from our website, parts of the site will not then work. This is because some of the cookies we use are essential for parts of our website to operate. Likewise, you may not be able to use some products and services on other websites without cookies.
To find out more about cookies, including seeing what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org or www.aboutcookies.org
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
By using NEO website without adjusting your web browser to block them, you are consenting to these types of cookies being stored on your device.
Your rights and how to exercise them
You have the right to determine how we use your data, including your right to access it, rectify it and obtain a copy of it in a machine-readable format.
You may be able to oppose the purposes of processing it and ask that your personal information is erased or that its processing is restricted.
You also have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller without hindrance from us. In exercising your right to data portability, you have the right to have your personal data transmitted directly from a controller to another, where technically feasible.
You can contact us to exercise your rights at the address below or sending an email to privacy@neoinvestmentpartners.com
NEO Investment Partners LLP
4th Floor, 33 Cavendish Square
London, W1G 0PW, United Kingdom
If you consider that the processing of your personal data infringes applicable data protection laws, as data subject you have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority (in the UK it is the Information Commissioner’s Office www.ico.org.uk).
We endeavour to take all reasonable steps to protect your personal information and keep it up to date However, we cannot guarantee the security of any data that you disclose online and we will not be responsible for any breach of security unless this is due to our negligence or wilful default.