About us

We are ALSA Management Services Ltd of 78 Pall Mall, LondonSW1Y 5ES, United Kingdom at https://www.alsaventures.com/, (“we” or “the Firm”) and we are subject to the laws of England and Wales. We use your information as further explained in this Privacy Notice. We will be the “controller” of the information you provide to us.

What information do we need?

We collect basic personal data about potential and existing clients, investors and partners from time-to-time, such as names, email addresses and addresses.

We may, in addition to the above, collect your date and place of birth, telephone number, job title, tax identification number, photocopy of identification and sometimes proof of address.

We will not ask you to provide any sensitive information(such as health data) or use your information to build profiles about you.

Why do we need it?

Personal information and/or data may be used to:

• stay in touch with investors, investees and partners by post, telephone, electronic mail, etc., in connection with your relationship;
• facilitate and manage our business relationships. This may include sharing information internally as well as disclosing it to our professional advisers;
• facilitate business operations, including conducting due diligence, making investment recommendations, assessing and managing risk; and
• comply with our legal and regulatory requirements and obligations, including in relation to performing money laundering and ‘know your customer’ checks, in compliance with (among other things) the U.S. Foreign Account Tax Compliance Act and the OECD CommonReporting Standard.

What do we do with it?

All the personal data we process is processed by our staff in the United Kingdom to:

• communicate with you by telephone, mail, email or other electronic means;
• provide you with the information, products and services that you request from us, as well as access to the data room; and
• perform our obligations under any contract we have with you.

We may share your information with our service providers such as our IT service providers for the purposes of providing services to us, including data storage.

In addition to the uses outlined above, our staff in the UnitedKingdom may, if required, process your personal data to:

• carry out risk assessments; and
• verify your identity as part of our ‘know your customer’ checks (and to prevent, detect and prosecute fraud and crime and comply with legal or regulatory requirements).

We may share your information with:

• our professional advisers, such as (but not limited to) our legal advisers or administrators, where they require that information in order to provide advice to the Firm in relation to our services, activities and operations;
• the Financial Conduct Authority of the United Kingdom, and any other regulatory authority we may be subject to for the purpose of demonstrating compliance with applicable law and regulations;
• Her Majesty's UK Revenue and Customs and any other relevant government authority as required by law; and
• such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police.

This information is located on servers within the United States of America for the purposes of IT hosting and maintenance.  

No other third parties have access to your information unless we specifically say so in this Privacy Notice, or the law requires this.

Marketing

If you have provided consent or we otherwise have the right to do so, we may, to the extent permissible by law, send to you direct marketing and promotional materials relating to our services or related products, for example sending you communications (including by email) for these purposes.

Where we rely on legitimate interest as a basis for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests. You can find out more information about these balancing tests by contacting us at investor.relations@alsaventures.com.

How long will we keep it?

We will hold your personal information only for as long as necessary to carry out the data processing purposes stated above, following which we will securely destroy your personal information. Your personal information will be kept securely to prevent unauthorised access by other people. You must inform us of any changes to your personal information so that we can keep it up to date. Should you notify us of such changes, we will notify any of the above-mentioned third parties (if we have disclosed your personal information to them) of these changes, to ensure your records are rectified and remain accurate.

Your rights

Right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Notice.

Right of access

You have the right to access the information we hold about you. We usually act on requests and provide information free of charge but may charge a reasonable fee to cover our administrative costs of providing the information for requests which are manifestly unfounded or excessive.

Correcting or erasing your information

You have the right to ask us (and third parties to whom we transfer your personal information) to rectify your personal information if it becomes inaccurate.

We need to notify any third parties with whom we have shared your information that you have made a rectification request (see “What do we do with it?” above) We will take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.

You have the right to ask us to erase your personal information if:

• you withdraw your consent to our processing of your personal information;
• your personal information has been processed unlawfully by us; or
• your personal information is no longer necessary for the purposes for which it was collected by us.

Restricting processing of your information

You have the right to restrict our processing of your personal information in certain circumstances. When processing is restricted, we may store your personal information, but may not use it further.

Data portability

You have rights to obtain and reuse your personal data for your own purposes across different services in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred to another party.

If the personal information concerns more than one individual, we may not be able to transfer this to you if doing so would prejudice that person’s rights.

Objecting to processing

You have the right to object to certain types of the processing of your personal data, in certain circumstances. In particular, you have the right to object to the processing of your personal data based on our legitimate interest or on public interest grounds, and the right to object to processing for direct marketing purposes (including profiling).

Right to withdraw consent

If you have provided your consent to the collection, processing and transfer of your personal information 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 investor.relations@alsaventures.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 required to retain your information for a legal or regulatory purpose.

Contact Details

If you have any questions, would like to talk to someone about this Privacy Notice, access your personal information or make a complaint about how we have handled your information, please contact investor.relations@alsaventures.com.

If you believe our processing of your personal information does not comply with data protection law, you can make a compliant to theInformation Commissioner’s Office using the following details:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom
Tel: 0303 123 1113
www.ico.org.uk