Privacy Policy
Investment Disclaimer & Privacy Policy
The information on this site is directed at persons resident in the UK and is not to be regarded as an offer to buy or sell, or the solicitation of any offer to buy or sell securities or investments in any jurisdiction other than the UK, including, but limited to, the United States of America.
A person resident in territories other than the UK should consult their professional advisers as to whether they require any governmental or other consents or need to observe any formalities to enable them to invest in the products described on this website.
We do not offer investment advice or make recommendations regarding investments, nor do we offer tax advice and nothing on this website should be construed as investment or tax advice. The information on this websiteis for informative purposes only. Under no circumstances is the information to be used or considered to as an offer to sell, or a solicitation of an offer to buy, any security. Additional information is available upon request. Where information has been obtained from outside sources, it is believed to be reliable but is not represented to be accurate or complete. Past performance is not necessarily a guide to the future. The value of an investment and any income from it can go down as well as up and you may not get back the amount originally invested.
We accept responsibility for the information on this website. To the best of our knowledge and belief (having taken all reasonable care to ensure that such is the case) the information on this website is in accordance with the facts and does not omit anything likely to affect the import of such information. This website may contain links to other websites provided by third parties. Such links are for your information only and we have no control over the content or resource of those sites and accept no responsibility for them, or any loss or damage that may arise from your use of them.
This website is subject to regular update and revision. While we attempt to ensure the correctness and timeliness of all material posted on the website, we take no responsibility for errors or omissions which are the result of technical causes, or otherwise. We maintain the right to delete or modify in part or in full any information on this website without prior notice.
Concentric Team LLP (“Concentric”) is authorised and regulated by the Financial Conduct Authority (“FCA”)
This privacy policy sets out how Concentric uses and protects any information that you give Concentric when you use this website. Concentric is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
Concentric may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 25th May 2018.
All your personal Information shall be held and used in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data. If you want to know what information we collect and hold about you, or to exercise any of your rights as set out below, please write to us at the below address or via email at: info@concentricteam.com
Website users
If you are just browsing our website we will not collect personal data other than your IP address collected through our cookies. Some interactive or dynamic applications on this website use session cookies (tokens that remain active only until a browser session is closed). These applications will not work as expected by the user without such cookies. No cookie information is collated or stored by Concentric.
Browsers can be set to reject cookies and still have access to all of the Concentric web pages, with the exception of those few interactive or dynamic applications that require cookies for proper operation. Refer to the Help information in your particular browser software for instructions on how to enable or disable cookies.
This website only collects data that you enter into the website for example to submit an enquiry or where you follow a link from our website to send us an email.
If you subscribe to any of our mailing lists or you otherwise ask to receive our mailings, we will use your contact details to send you the material you have requested. You can unsubscribe at any time by clicking the unsubscribe link in the emails you receive or by contacting us using the details below.
We do not collect any sensitive personal data about you.
We are allowed to process your personal data on the basis that it is in our legitimate interests to:
- monitor how our website is used in order to improve it;
- respond to enquiries, complaints and requests;
- send you the material you have requested or which we think will be of interest given our previous business dealings.
We use service providers to operate our website and some of these service providers may process your data as part of the services they offer to us. We take steps to ensure that our service providers treat your data in accordance with the law, only use it in accordance with our contract with them and keep it secure.
Job applicants and management positions
If you submit an application for a job with us or are interested in a potential management position or directorship with one of our portfolio companies we will store personal data relating to you. Depending on how far your application progresses, this might include your contact details, your relevant education and employment history, details of referees and information you provide in your CV. Further information may be generated by you and us later on such as notes of interviews and answers to written tests. We may gather further personal data before deciding whether to make you a final offer such as proof of your identity, proof of your qualifications, pre-employment health questionnaires and credit checks. If you apply for a role that must be approved by the Financial Conduct Authority we may obtain details of any relevant criminal or disciplinary history as part of that approval process.
Most of the personal data that we process about you when you apply for a job or a management position or directorship is information that you give us directly or is generated through the recruitment exercise, although we may gather information from recruitment agencies, your referees and credit reference agencies. If you are required to take psychometric tests, the test provider will send us your responses and any analysis they carry out based on your responses. We may in certain circumstances need to seek confirmation from the Home Office that you have the right to work in the UK.
Most of the personal data described above is processed by us pursuant to our legitimate interests as an employer or fund manager. We use your personal data to contact you about your application and to assess your experience and suitability for a job with us, to help us assess your training needs and understand your characteristics and working-style. We may process special categories of data to ensure that we can comply with our legal or regulatory obligations as an employer, such as details of your right to work in the UK, information about your health (in order to assess whether you are medically able to carry out the work offered and whether any adjustments would be needed to your work environment), information about a disability (in order to make reasonable adjustments to your application process or assess adjustments to your potential work environment), details of your relevant criminal or disciplinary history (to ensure full disclosure is made to the Financial Conduct Authority). We may process information about your health for the purposes of occupational medicine, in order to assess your medical capacity to perform the job you have applied for. We may also need to process personal data in order to exercise our legal rights and bring or defend claims.
Some of our service providers that act as our processors could have access to your personal data such as our IT consultants or psychometric testing providers. In addition, we share your personal data with recruitment and credit reference agencies and, in some circumstances, the Financial Conduct Authority, who act as separate controllers of your personal data. If you are interested in a management position or directorship with one of our portfolio companies will share your data with our portfolio companies, who act as separate controllers of your personal data.
If you are employed by us, our staff privacy notice will then apply to your personal data.
Shareholders and investors
If you are a shareholder or investor in one of the Funds we manage or another Concentric entity that we manage or advise (together “investment entities”), the investment entity will collect personal data about you including your name, address, email address, contact numbers and national insurance number in order to maintain the share register or equivalent of the investment entity. The relevant investment entity is the controller of your personal data.
The personal data of investors and shareholders is collected and processed on behalf of the investment entity so that it can comply with its legal and regulatory obligations to:
- maintain the shareholder register (or equivalent);
- communicate with shareholders and investors (including the mailing, in physical or electronic format, of annual reports, AGM or EGM notices and proxy card;
- facilitate the payment of dividends or other distributions from the investment entity.
The relevant investment entity will share your data with service providers who process personal data on their behalf, such as ourselves, Concentric (as manager or adviser or receiving agent) and entities who maintain the share register on their behalf, for example, Computershare plc.
The relevant investment entity may instruct Concentric to share data with your financial or other adviser, where you give us authority to do so. Your financial or other adviser act as separate controllers of your personal data. The relevant investment entity may instruct Concentric to share your data with professional advisers such as accountants, lawyers or consultants.
Business contacts
If you have had contact with us, for example through emailing us or meeting a Concentric representative, we may store limited amounts of personal data relating to you, such as your name, job title, employer organisation and contact details.
We will use this personal data in order to:
- maintain a record of contacts
- provide you will periodic business updates
- invite you to presentations and events
- organise meetings between you and our representatives.
We are allowed to process this personal data on the basis that it is in our legitimate interests to:
- maintain relationships with our business contacts
- send you material which will think will be of interest given our business dealings
- develop our business network
- promote and run our business.
We may share your personal data with companies who process personal data for us such as providers of contact management systems. We may also share your personal data with our professional advisers such as accountants, lawyers or other consultants. We may also share your personal data with other companies in our group.
Suppliers and professional advisers
If you are a supplier to us, or one of our professional advisers, we will store limited amounts of personal data relating to you, including your name, job title, qualifications, employer organisation and contact details. Will store this personal data for the purposes of administering and maintaining records of services or advice we have received and commissioning further services.
We are allowed to process your personal data on the basis that it is in our legitimate interests to run and promote our business.
Actual or potential management teams
If you are involved in a transaction that the funds we manage or advise enter into, or a potential transaction that Concentric considers, we may store personal data relating to you. This might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out.
We collect and store this data for the purposes of:
- assessing potential transactions
- maintaining records of investments
- administering any transactions that we enter into
- assessing your suitability for involvement in a transaction, including by verifying your identity
- complying with our legal and regulatory obligations, including assessing and managing risk
- safeguarding our legal rights and interests and those of the funds we manage or advise
- seeking and receiving advice from our professional advisers
- providing periodic business updates.
We may share your personal data with companies who process personal data for us such as providers of contact management systems. We may also share your personal data with third parties who act as separate controllers of your personal data such as credit reference agencies, our professional advisers and other persons who have a potential interest or involvement in one of our transactions such as co-investors or investors in our funds.
We are allowed to process your personal data on the basis that it is in our legitimate interests in running our business, in particular by considering potential investments and administering transactions that we enter into. If we enter into a transaction that you are involved in, we are allowed to process your personal data for the purpose of performing a contract and to comply with our regulatory and legal obligations.
Mandatory provision of personal data
We will explain to you when the provision of particular data is mandatory, including the possible consequences of not providing particular data, for example, preventing us from offering you employment or proceeding with a transaction involving you. We will only process personal data you provide to us for the purposes set out in this notice.
Retention of personal data
The period for which we will retain your personal data will vary depending on the purposes for which it was collected, as well as the requirements of any applicable law or regulation. For example, if you send us an enquiry, we will hold your data until the enquiry has been completed and no further response is received for a reasonable period. If you subscribe to our mailings we will keep your data until you tell us you no longer wish to receive them. If you make a complaint, we will retain your data for a period of us to six years after resolution of the complaint. If you apply for a job with us and your application does not result in us employing you, we will delete all the personal data gathered during the recruitment exercise six months after the recruitment exercise has ended. This is so that we can defend any legal claims arising from the recruitment process. If you provide us with personal data because you are involved in a transaction with us we will retain your personal data for up to 10 years from our exit of the investment.
International transfers of personal data
Concentric does not transfer your data outside of the EEA. However, we use suppliers who may process personal data and have operations or use IT services in countries outside of the EEA. We ensure that our suppliers only transfer personal data outside of the EEA in accordance with General Data Protection Regulation.
Your rights
If we hold your personal data you may be entitled to access your personal data, or to request that it is erased, that its processing is restricted, or that any inaccurate data is rectified. You may also have the right to object to the processing of your personal data or, in some circumstances, to obtain an electronic copy of your personal data which we hold electronically or request us to provide it directly to another party. Your rights depend upon the basis on which we process your personal data and whether any exceptions or exemptions apply to the circumstances. Any requests should be submitted in writing to the contact details specified below. We will respond within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.
If you do not think that we have processed your data in accordance with this privacy notice, you should let us know as soon as possible. You also have the right to complain to the Information Commissioner’s Office (see www.ico.org.uk).
Accuracy and security
We strive to 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.
How to contact us
If you need to contact us about this notice, please email info@concentricteam.com or call +44 7796 854647. You may also write to Head of Compliance, Concentric Team LLP, Huckletree Soho, Ingestre Court, Ingestre Place, London, WIF 0JL