Welcome to www.alicorn-vp.com. This policy explains how we handle and use your personal information and your rights in relation to that information. Under data protection law, Alicorn Global Limited is the controller of that information.
Alicorn Limited (“we”, “our” or “us”) are committed to protecting and respecting your privacy.
This Privacy Policy explains why and how we will use the personal information that we have obtained from you or others, with whom we share it and the rights you have in connection with the information we use. Please read the following carefully.
This policy describes the way we handle and use the personal information that we obtain from all the different interactions you may have with us as a business, including when you visit our social media pages or website currently located at www.alicorn-vp.com or when you contact us or take part in any of our competitions or promotions.
Alicorn Limited is the controllers in relation to the processing activities described below. This means that Alicorn Limited decides why and how your personal information is processed. Please see the section at the end of this policy for our contact and legal information.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We only collect personal information which we need and that is relevant for the purposes for which we intend to use it.
We may collect information if you are an investor or prospective investor, or connected with a portfolio company or prospective portfolio company or otherwise provide us with your personal information. The information that we may collect and process depend on the data subject, however, the most likely categories are the following:
We use your personal information to establish and administer your investment, comply with relevant laws and regulations such as the Anti-Money Laundering and Counter-Terrorism Financing Act and to communicate with you about your investment.
Most commonly we will use your personal data where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. For example:
Personal information may be used for secondary purposes such as the provision of promotional and marketing material. You can contact us at any time if you do not wish to receive such materials or information.
Where we collect your personal information for a specific purpose (not contemplated in this Privacy Policy), you will be provided with a collection notice which explains the primary purpose (and any related secondary purposes) for which your personal information is being collected.
We do not actively seek to collect sensitive information (for example health information or information about any criminal record), unless it is necessary for business purposes. If we do have to collect sensitive information, we will only collect, use and disclose it in accordance with privacy laws.
We process all data in accordance with the EU General Data Protection Regulation. We may disclose your personal information to:
Alicorn uses third party investment administrators and registries to support the administration of our financial products. We have contractual arrangements with these service providers to ensure they comply with privacy laws when dealing with your personal information.
Your personal information may be provided to external service providers in offshore locations such as Jersey.
You have certain rights by law including the right to access your information held by us (for which we may charge a small administrative fee) and to have any inaccurate information corrected.
The law on data protection sets out several different reasons for which a company may collect and process your personal data, including:
GDPR gives you (as an individual) a number of rights in respect of your data, including:
If you require access to, or wish to update your personal information, please contact our Data Protection Officer. A link may be found in the ‘Contact’ Section of the website.
We take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, interference, modification or disclosure.
We have physical, electronic and procedural safeguards to protect your information which is held by us. For example, your personal information is stored in secured office premises and/or in electronic databases requiring logins and passwords for access. Access to information stored electronically is restricted to staff whose job purpose requires access. We also require all staff to maintain the confidentiality of customer information.
We use secure methods to destroy or de-identify any personal information as soon as the law permits, provided the information is no longer required.
Our service providers are required to notify us of any unauthorised access, disclosure or loss of personal information.
In such a circumstance, Alicorn performs an assessment to determine if there has been an ‘eligible data breach’ which means a breach of security leading to the destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. The Firm will have to notify the Information Commissioner’s Office (ICO) of an eligible data breach where it is likely to result in a risk to the rights and freedoms of Data Subjects.
If this is the case, the individuals affected will also be notified as soon as practicable of the details of the breach and the recommended steps to take in response to it.
Alicorn Limited
Floor 1, 16 Albemarle Street, London, England, England, W1S 4HW
Email: [email protected]
We will endeavour to answer any questions, correct any error on our part or resolve any complaint you may have about our information handling practices.