Episode 1 - UK Privacy Policy
1. Welcome
This policy sets out how we at Episode 1 collect, use andprotect personal information you share with us. We update this privacy policy from time to time and changes areeffective when they are posted on this page. This policy was last updated on 1February 2024.
Note that our website at www.episode1.com containslinks to websites of our various portfolio companies but this policy does not applyto them (they will typically have their own privacy policies).
2. Who is responsible for your personal information
Episode 1 Ventures LLP is the entity within our groupwhich acts as controller of personal information you provide to us. It is registered with the InformationCommissioner’s Office under registration number ZB639722. A controller determines how your personalinformation is used and is responsible for ensuring your privacy rights arerespected.
If you have any questions about how your personalinformation is being used please email us here: email.
3. What information we collect and how we use it
The information we collect is determined by what we needit for.
When you visit and browse our website
We automatically collect certain personal informationabout you and how you access our website:
Information collected
How you access our website and associated technical information, such as your IP address, device, browser type and operating system.
Approximate location of your device (such as the city or region you are in) based on your IP address and device time zone setting.
Your journey through our website including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information and information collected in any forms you complete
How we use it
To present our website to you in the correct format for your device and browser and to analyse performance in order to identify ways in which it might be improved.
To help us better understand how people use our website to enable us create better content and more relevant communications.
Legal basis
Our legitimate interests in developing and improving our services.
Use of cookies
Cookies are small text files placed on your device by websites you visit. We use the following types of cookies on our website:
- analytics and performance cookies – allow us to see how visitors move around our website and monitor performance of certain features;
- functionality cookies – enhance our website's performance by enabling us to recognise you and remember your preferences so we may provide personalised features or content such as facilitating log in to secure areas ofthe website and using billing functionality;
Other than cookies required to operate our website, we only place cookies on your device or use these technologies to collect information with your consent. If you would like to withdraw your consent to non-essential cookies, you can do this by updating the cookie settings on our website.
Most browsers will also allow you to disable all cookies through your browser or mobile settings. These settings will typically be found in the "options" or "preferences" menu of your browser.Please note that if you choose to refuse cookies you may not be able to use the full functionality of our website.
When you meet or contact us
We meet large numbers of business contacts at meetings and conferences and receive emails about investment opportunities:
Information collected
Your name, job title, employer organisation and contact details such as email address and phone number.
Your communications with us.
How we use it
To maintain a record of contacts, provide information about our services or periodic business updates, draw your attention opportunities which may be of mutual benefit and to organise meetings with you.
Legal basis
Our legitimate interests in running and promoting our business.
Where you invest with us
As a part of our day to day operations we are likely to receive and store personal information on our investors and prospective investors.
Information collected
Your name, address, contact details, information relating to your financial status and dealings and your nationality (including copies of identity documents, such as a passport).
How we use it
To evaluate the make-up of our funds, execute investments, manage your relationship with us as an investor, maintain records of our investors, meet regulatory and legal obligations e.g. KYC checks, safeguard our legal rights and interests and seek and receive advice from our professional advisers.
Legal basis
Performing a contract to which you are likely to be a party.
Complying with a legal or regulatory obligation.
Our legitimate interests in running and promoting our business.
Where you pitch to us for investment
We receive and store personal information as part of theinvestment evaluation process.
Information collected
Where you send or otherwise present to us an overview of your company, we may store personal information relating to you in our Client Relationship Management or other such system. This may include your name, email address and gender.
How we use it
To evaluate a transaction and your role in it, meet regulatory and legal obligations e.g. KYC checks, safeguard our legal rights and interests, seek and receive advice from our professional advisers and/or to provide periodic business updates.
Legal basis
Performing a contract to which you are likely to be a party.
Complying with a legal or regulatory obligation.
Our legitimate interests in running and promoting our business.
When we make an investment
We receive and store personal information as part of theinvestment evaluation process.
Information collected
If we decide to offer a term sheet and make an investment further information collected 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.
How we use it
To execute investments and related transactions, manage an investment once made, maintain records of investments, meet regulatory and legal obligations e.g. KYC checks, safeguard our legal rights and interests, seek and receive advice from our professional advisers and/or to provide periodic business updates.
Legal basis
Performing a contract to which you are likely to be a party.
Complying with a legal or regulatory obligation.
Our legitimate interests in running and promoting our business.
We may process your personal data without your knowledge or consent in compliance withthe above but if we need to use your personal data for an unrelated purpose, wewill notify you and we will explain the legal basis which allows us to do so.
4. Who we share your information with and why
We may share the information we collect with the following recipients for the reasons specified:
Recipients
Other parts of our group or affiliates.
Why we share it
To provide or coordinate services on a group level, or perform certain business functions within our group.
Lawful basis
Our legitimate interests in coordinating intra-group services.
Recipients
Third party service providers who hold or process information on our behalf and in accordance with our instructions.
Why we share it
To receive certain services required for our business to operate such as hosting our IT infrastructure or other technical services like analytics or communications, professional advice from lawyers, accountants or consultants and payment processing, credit checking or services provided by other financial intermediaries.
Lawful basis
Performing a contract to which you are likely to be a party.
Complying with a legal or regulatory obligation.
Our legitimate interests in running and promoting our business.
Recipients
Persons who have an interest or involvement in, or who are considering an interest or involvement in, a transaction, including co-investors, other providers of finance and investors in our funds.
Why we share it
To execute investments and related transactions, manage an investment once made and maintain records of investments.
Lawful basis
Our legitimate interests in running and promoting our business.
Recipients
Law enforcement, regulators and other such parties
Why we share it
To comply with the law and the reasonable requests of law enforcement, detect and investigate illegal activities and breaches of agreements and/or exercise or protect the rights, property, or personal safety of ourselves, our users or others.
These recipients will use your personal information in the performance of their regulatory or law enforcement role.
Lawful basis
To comply with a legal obligation to which we are subject.
Our legitimate interests, namely enforcing our rights or complying with requests from regulatory authorities.
5. International transfers of your information
When information is shared as set out above it may be transferred to a country outside the United Kingdom or European Economic Area where the recipients have operations. Where that is required we will ensure such transfers are made in accordance with applicable law including being made subject to standard contractual clauses approved by the UK Information Commissioner for the transfer of personal information.
6. How we store your information and how long we keep it for
All personal information we collect is stored on secure servers and we implement appropriate technical and organisational measures to protect your information against accidental or unlawful destruction, loss, change or damage.
We keep your information on our systems for the duration of our relationship with you or as required by law and no longer (third parties we engage to provide services on our behalf do the same).
7. Your rights in relation to your information
You have certain rights in respect of personal information held by us – namely to:
- request access to confirm whether or not we have your personaldata and obtain a copy;
- request correction where it is incomplete or inaccurate;
- request erasure where there is no good reason for us continuing to process it;
- object to its processing where we are relying on a legitimate interest;
- restrict its use by having us temporarily suspend processing, subject to us establishing overriding legitimate grounds to use it;
- request transfer of information which you provided consent for us to use or where we used the information to perform a contract with you; and
- withdraw consent where we process your data on the basis of your consent.
Please keep in mind that there are exceptions to therights above and, though we will always try to respond to your satisfaction,there may be situations where we are unable to do so (for example, because theinformation no longer exists or there is an exception which applies to yourrequest).
Please contact us should you wish to exercise any ofthese rights or have a complaint regarding any aspect of your personal data orthis privacy policy. If you are still not satisfied with the outcome of yourcomplaint, you may contact the UK Information Commissioner’s Office at www.ico.org.uk.
