V 2.0 – Last updated 16 November 2021
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
The data we collect about you
Personal data does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes full name, username or similar identifier.
- Contact Data includes residential address and email address.
- KYC Data includes personal data obtained from:
- Identity verification (ID document information and proof of address);
- Verification of ultimate beneficial ownership of corporate and other legal entities;
- Anti-money laundering, proceeds of crime and terrorist finance checks (AML/CFT checks); and
- Sanctions lists checks.
- Financial Data includes bank account details and other financial information, including but not limited to, source of funds and source of wealth information.
- Transaction data includes details about payments to or from you, including digital access wallet information.
- Technical Data includes IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Communications Data includes your preferences in receiving marketing from us.
We may also process Special Categories of Personal Data about you (this includes data concerning your health, personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data) and/or information about criminal convictions and offences (together “Special Category Data”) when undertaking KYC/AML checks as part of our client on-boarding process.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your information by filing a form, signing up to our services or newsletter, signing a contract with us, via email or social media communications, interacting directly with a member of our team, be it in person or electronically, or providing services to us; or
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Third parties of public available sources. We may receive personal data about you from third parties such as analytics providers (Technical Data), KYC and other service providers and public records.
How we use your personal data
We will only use your personal data where:
- we need to perform the contract we are about to enter into or have entered into with you.
- we have your permission to do so.
- it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- we need to comply with a legal obligation.Where we process Special Category Data, we only do so with your explicit consent.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Our use of ‘cookies’
Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the service or a third-party to recognize you and make your next visit easier and the service more useful to you.
We use both session and persistent cookies on our website including essential and third party cookies. Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.
In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the service, deliver advertisements on and through the service, and so on. You can learn more about cookies and the following third-party websites:
- AllAboutCookies: http://www.allaboutcookies.org/
- Network Advertising Initiative: http://www.networkadvertising.org/
If you share our content through social media, for example by liking us on Facebook, following or tweeting about us on Twitter, or giving us a ‘+1’ via Google Plus, those social networks will record that you have done so and may set a cookie for this purpose.
In some cases, where a page on our website includes content from a social network, such as a Twitter feed, or Facebook comments box, those services may set a cookie even when you do not click a button. As is the case for all cookies, we cannot access those set by social networks, just as those social networks cannot access cookies we set ourselves.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Internally within the Outlier Group;
- External Third Parties as set out in the Glossary below; and
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that we only use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see “Request erasure” in the section below for further information.
By law we have to keep basic information about our customers (including Contact, KYC information and Transaction Data) for 6 years after they cease being customers.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Outlier Ventures Operations Ltd (“Outlier Ventures”) is registered in England and Wales, company registration number 10722638. Outlier Ventures Operations Ltd is an appointed representative of Sapia Partners LLP which is authorised and regulated by the Financial Conduct Authority (Firm Reference Number 550103).
External Third Parties
Service providers acting as processors based in the United Kingdom or abroad who provide services to us.
Service providers acting as processors based in the UK who provide KYC services, regulatory and compliance services and client on-boarding services.
Third parties involved with the services we provide to clients such as counterparties and their solicitors, accountants, surveyors, family offices and other intermediaries and courts, tribunals, public registrars and stock exchanges.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, compliance banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.