Privacy notice

Introduction

The Collington Capital group is committed to protecting your personal information (that is, any information from which a person can be identified) and being transparent about what personal information we hold and process.

This Privacy Notice sets out how the entities which make up the Collington Capital group will use and protect the personal information of donors, grantors, investors and other participants in the impact investment chain (or employees and/or representatives of institutional donors, grantors, investors and other participants in the impact investment chain) and is written in accordance with applicable data protection and privacy laws, including the Data Protection Act 2018, the UK GDPR (as defined in the Data Protection Act 2018), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and all similar or related laws relating to the processing of personal information and/or privacy applicable to us from time to time or as re-enacted, applied, amended, superseded, repealed or consolidated (together the “Data Protection Laws“).

The following entities constitute the “Collington Capital” group:

• The Harriet Collington Foundation, a private limited company incorporated in England and Wales with registered company number 14446797 and registered address at 55 Ludgate Hill, London, United Kingdom, EC4M 7JW (“HCF“);
• Collington Capital Partners LLP, a limited liability partnership incorporated in England and Wales with registered company number OC427820 and registered address at 55 Ludgate Hill, London, United Kingdom, EC4M 7JW (“CC LLP“); and
• Collington Capital Limited, a private limited company incorporated in England and Wales with registered company number 14018133 and registered address at 55 Ludgate Hill, London, United Kingdom, EC4M 7JW (“CC LTD“),

each of which is a separate data controller in respect of personal information.

Unless otherwise specified in this Privacy Notice, the statements made within this Privacy Notice are made by each of HCF, CC LLP and CC LTD separately and references to “we”, “us” or “our” in this Privacy Notice should be considered references to each of HCF, CC LLP and CC LTD separately.

What personal information do we process about you?

HCF	HCF may process the following types of personal information about all types of donors, grantors, investors and other participants in the impact investment chain (or employees and/or representatives of institutional donors, grantors, investors and other participants in the impact investment chain): name contact details (including postal address, telephone number, and e-mail addresses) professional qualifications, historic or current occupation, historic or current affiliation with an organisation (job titles or roles) professional or personal connections with other individuals or organisations interest in impact themes and appetite to participate in or support the development of generic or specific impact investing vehicles history of donations, funding and investments associated with impact themes and generic or specific impact investments sources of funds for donations, grants or investments interactions with HCF (both online (e.g. from communications via websites or email) and offline (e.g. from communictions via letter or telephone or in person)) any other personal information which you provide to HCF or which is publicly available.
CC LLP	CC LLP may process the following types of personal information about all types of donors, grantors, investors and other participants in the impact investment chain (or employees and/or representatives of institutional donors, grantors, investors, enterprises, intermediaries and other participants in the impact investment chain): name contact details (including postal address, telephone number, and e-mail addresses) professional qualifications, historic or current occupation, historic or current affiliation with an organisation (job titles or roles) professional or personal connections with other individuals or organisations interest in impact themes and appetite to participate in or support the development of generic or specific impact investing vehicles history of donations, grants and investments associated with impact themes and generic or specific impact investments interactions with CC LLP (both online (e.g. from communications via websites or email) and offline (e.g. from communictions via letter or telephone or in person)) any other personal information which you provide to HCF or which is publicly available.
CC LTD	CC LLP may process the following types of personal information about all types of donors, grantors, investors and other participants in the impact investment chain (or employees and/or representatives of institutional donors, grantors, investors, enterprises, intermediaries and other participants in the impact investment chain): name contact details (including postal address, telephone number, and e-mail addresses) professional qualifications, historic or current occupation, historic or current affiliation with an organisation (job titles or roles) professional or personal connections with other individuals or organisations interest in impact themes and appetite to participate in or support the development of generic or specific impact investing vehicles history of donations, grants and investments associated with impact themes and generic or specific impact investments sources of funds for donations, grants or investments professional background, education and / or work / deals experience and track record in investing interactions with CC LTD (both online (e.g. from communications via websites or email) and offline (e.g. from communictions via letter or telephone or in person)) any other personal information which you provide to CC LTD or which is publicly available.

Credit/debit card details are NOT collected to process any financial transaction and are not stored on our electronic systems.

How do we use your personal information?

HCF	HCF may use your personal information to: further our purpose of enabling access to impact capital by impact-led enteprises provide you with information about the vision, purpose, mission, goals, plans and development of HCF provide you with opportunities to support the development and funding of impact investment vehicles develop and improve the opportunities we provide to support the development and funding of impact investment vehicles conduct due diligence before accepting any donations or funds or in-kind support administer or arrange your donation or grant as may be applicable run our business affairs, including keeping a record of your relationship with us ensure we know how you would like to be contacted by us contact you about opportunities to support the development and funding of impact investment vehicles.
CC LLP	CC LLP may use your personal information to: further our purpose of enabling access to impact capital by impact-led enteprises provide you with information about the vision, purpose, mission, goals, plans and development of CC LLP provide you with opportunities, services or information which support your participation in the impact investment chain develop and improve the opportunities, services or information we provide run our business affairs, including keeping a record of your relationship with us ensure we know how you would like to be contacted by us contact you about our opportunities, services or information which support your participation in the impact investment chain.
CC LTD	CC LTD may use your personal information to: further our purpose of enabling access to impact capital by impact-led enteprises provide you with information about the vision, purpose, mission, goals, plans and development of CC LTD meet our regulatory requirements to ensure that you are a professional investor provide you with opportunities and information which may enable you to make impact investments develop and improve the opportunities and information we provide to enable you to make impact investments administer or arrange your impact investment as may be applicable run our business affairs, including keeping a record of your relationship with us ensure we know how you would like to be contacted by us contact you about opportunities to enable you to make impact investments.

You may opt out of receiving marketing communications from us by following the instructions outlined in any marketing communication or by otherwise contacting us using the contact information set out at the bottom of this Privacy Notice.

How we collect and/or receive personal information about you?

We are committed to being transparent about how we collect and/or receive personal information and to meeting our obligations pursuant to the Data Protection Laws. We collect and/or receive personal information in the following ways:

Information you provide to us directly

You may give us your information when you:

• conduct a transaction (e.g. make a donation, grant or investment);
• attend one of our events; or
• otherwise communicate with us (both online (e.g. via websites or email) and offline (e.g. via letter or telephone or in person).

Information you provide to us indirectly

We may receive personal information from other entities within the Collington Capital group, our suppliers (for example, our professional advisers) and from our business partners (for example, our funders, investors, clients and fellow intermediaries ). 

Information from other sources

We may supplement information with personal information obtained from publicly available sources such as charity websites and annual reviews, corporate websites, public social media accounts, sanctions lists, political party lists, national and local press, the electoral register and Companies House, etc.

Legal basis for processing

The Data Protection Laws specify several different bases on which organisations may lawfully process personal information. We may rely on one or more of the following lawful bases from time to time:

Legitimate interests

We primarily process your personal information on the basis that it is necessary for our legitimate interests in fulfilling the purposes described above and does not unduly impact your rights. Our primary legitimate interest is furthering our objective of enabling impact-led enterprises to access impact capital. We only rely on legitimate interests where we consider that our legitimate interests are not overridden by your interests or fundamental rights or freedoms (for example, we consider any potential impact on you, how intrusive the processing might be from a privacy perspective and your other rights under the Data Protection Laws).

Legal obligation

In some circumstances we may process your personal information on the basis that it is necessary for compliance with our legal obligations. For example, in some cases we may need to share your personal information with regulators (such as the Financial Conduct Authority or Information Commissioner).

Perform or enter into a contract with you

In some circumstances we may process your personal information on the basis that it is necessary for the performance of a contract or arrangement to which you are a party or in order to take steps at your request prior to entering into a contract or arrangement.

Consent

In limited circumstances and for particular processing activities we may rely on your consent to process your personal information, but we will only do this where you have expressly provided your consent to those specific processing activities.

If you have provided your consent to us processing your personal information in a particular way but you later change your mind, you have the right to withdraw such consent at any time by contacting us using the contact information set out at the bottom of this Privacy Notice.

Sharing your personal information

In order to conduct our business, we may share your personal information with our employees, officers, agents, suppliers (for example, our professional advisers) or business partners (for example, our funders, investors, clients and fellow intermediaries). Disclosure to such recipients will occur only where we have a lawful basis to do so.

We may also disclose your personal information to third parties if we are under a legal or regulatory duty to do so (and/or where we believe we are under a legal or regulatory duty to do so).

If one or more of the legal entities in the Collington Capital group enters into a joint venture with, purchases or is sold to or merges with another business entity, your personal information may also be disclosed or transferred to the target company, our new business partners or owners or their advisors.

We require recipients to treat your personal information securely and in accordance with the Data Protection Legislation.

Personal information security and retention

We have put in place and maintain appropriate technical and organisational security and safeguarding measures (for example, through the use of data encryption, password protection and anti-virus / anti-malware programs) to protect your personal information. We have put in place policies and procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your personal information will be stored and processed in the United Kingdom, but may also be transferred to, stored at and/or processed in territories outside the United Kingdom. We will only transfer your personal information:

• to recipients in territories that are the subject of an adequacy decision under the Data Protection Legislation; or
• to recipients in other countries if we have provided adequate safeguards for your personal information in accordance with the Data Protection Legislation (such as through the use of contractual safeguards specified in the Data Protection Legislation).

We will only hold your data for as long as we reasonably require and, in any event, only for as long as the Data Protection Laws allow.

Your rights

In certain circumstances and subject to certain exemptions, you have the following rights in relation to the personal information that we hold about you:

• Your right to be informed – you have the right to ask us for information regarding how we use your personal information.
• Your right of access – you have the right to ask us to provide copies of your personal information.
• Your right to rectification – you have the right to ask us to rectify personal information that you think is inaccurate, or to complete personal information that you think is incomplete.
• Your right to erasure – you have the right to ask us to erase your personal information.
• Your right to restriction of processing – you have the right to ask us to restrict the processing of your personal information.
• Your right to data portability – you have the right to ask us to transfer personal information to another data controller.
• Your right to object to processing – you have the the right to object to the processing of your personal information.

You also have rights in relation to any automated decision-making and/or profiling and the right to withdraw consent to any consent-based processing at any time.

If you wish to exercise any of these rights, or if you have any queries or complaints in relation to how we use your personal information, please contact us using the contact information set out at the bottom of this Privacy Notice. If you wish to take any queries or complaints further, you have the right to contact the appropriate regulator (being the ICO in the UK) regarding such issues.

Please ensure that any personal information you provide us with is accurate and complete and you notify us of any changes to your personal information as soon as possible so that we can update our records.

Updating this Privacy Notice

We may update this Privacy Notice from time-to-time, at our sole discretion, effective immediately upon the posting of a new version on our website. Please check this page regularly to ensure you are familiar with the current version.

Contacting us

Please contact us if you wish to exercise any of your rights, or if you have any queries or complaints in relation to how we use your personal information, via email at info@collingtoncapital.com.

Alternatively, you can write to Olivia Dickson, Founder Member and Director, The Harriet Collington Foundation, 55 Ludgate Hill, London, United Kingdom, EC4M 7JW.

Last updated: 19 October 2023