Who is this Notice for?

Accelerator Advisory Limited (“AAL”, “we”, “us” or “our”), trading as Deeptech Labs, is a global accelerator and venture capital fund.  We connect the Cambridge ecosystem of leading researchers, tech organisations and entrepreneurs to build world-changing Deeptech companies  (“our services”), as part of which we may use email, social networks, our website or video conferencing to communicate with you.  This notice applies to our contacts from Deeptech Labs community members and entrepreneurs and other interested parties (together referred to as “you” or “your”).

What is the purpose of this Notice?

This Privacy Notice tells you:

  • what personal information AAL may collect about you in the course of its business;
  • what AAL uses your personal information for; and
  • who (if anyone), AAL passes it onto and how they use it.

AAL will only use your personal information in accordance with this notice and any other notices we provide to you about your personal information (the “Notices”),and in accordance with Data Protection Legislation (as defined below).

In this notice the terms “controller” and “processor” each have a special meaning that is set by Data Protection Legislation.  In this notice “personal information” is a reference to “personal data” as defined under the Data Protection Legislation, and the term “special category data” has a special meaning as defined by the Data Protection Legislation. The meaning of each of these terms is briefly outlined later in this notice.  Any reference “use” of personal information is synonymous with “processing” as defined under the Data Protection Legislation, and it embraces all use of the information from its creation or collection to its destruction.

The Data Protection Legislation is: (i) the Data Protection Act 2018 or any successor legislation, (ii) the General Data Protection Regulation ((EU) 2016/679) as applied under English law (“GDPR”), and (iii) the Privacy and Electronic Communications (EC Directive) Regulations 2003 or any successor legislation.

This notice is intended to meet certain obligations that AAL has as a controller.  It does not establish or evidence any obligations that will bind AAL.  It does not constitute or contain any representation or warranty by AAL.

Who is the controller?

For the purposes of the Data Protection Legislation, AAL is a “controller” in relation to your personal information. This means that AAL is responsible for deciding how AAL hold and use personal information about you. AAL is required under Data Protection Legislation to provide you with the information contained in this notice.

It is important that you read this notice, together with any other Privacy Notice that AAL may provide (the “Notices”), so that you are aware of how and why your personal information is collected and used by AAL.

Our main address is Mills & Reeve LLP Botanic House, 100 Hills Road, Cambridge, United Kingdom, CB2 1PH. AAL is a private company limited by shares, and registered in England and Wales under company registration number 12144298.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, please contact Chris Anderson who can be contacted at hello@dtl.vc.

What types of personal information AAL collect and hold about you

Personal information is defined broadly as any information relating to an identifiable living individual. It does not include information where the identity has been removed (“anonymous data”).

AAL may collect, generate, store, share and otherwise use the following categories of personal information about you. Once AAL has collected the personal information it may be used for any of the purposes described in this notice. This personal information may be held in electronic or paper format.

Personal information collected directly

We will obtain the following personal information about you if you provide it to us, or if any of your colleagues (or someone else that you have authorized) provides it to us:

  • your name
  • your title
  • your gender
  • your employer and their address
  • your employment status and job title
  • your work contact details (postal address, email address, contact telephone numbers)
  • (if you make them available to us) your personal contact details (postal address, email address, contact telephone numbers)
  • recorded instructions you give to us under our agreement(s) with you or your organisation
  • personal information that you submit to us
  • our records relating to the performance of our services for you and your organisation, including records forming part of or made in connection with our contract with you or your organisation
  • our records of your correspondence with us or our service providers (including enquiries that you submit to us, and records of meetings and telephone calls, as well as written correspondence)
  • our records of our correspondence with third parties about you (including records of meetings and telephone calls, as well as written correspondence)
  • information that you have made publicly available (for example, on your organisation’s website or on a social network), and other information that you choose to provide to us.

If you are a co-investor, we will also process information relating to your investments, including financial information that you provide and that we obtain in the course of our business.

Personal information collected by our website

You can access most of the pages on our website without giving us your personal information. However, you may choose to provide us with your personal information on some pages of our website, for instance by completing an application form.

When we collect and store this personal information, except for user activity logs it is collected as part of logs which do not identify you. We are, however, generally able to link logs with identifiable individuals, and we reserve the right to do so for the purposes described in this notice.

From what sources will AAL obtain your personal information?

We obtain your personal information (including that of your staff) from the following sources:

From you, or someone else who you trust and authorise: People who you trust and authorise could include members of your family, other staff or clients of your organisation, or your advisors or representatives.

From third parties: We may obtain personal information about you from third party sources, other than your staff and colleagues. For example, if we use any sub-contractors to help us perform our services, or operate the infrastructure that we rely on to provide our services, they may collect personal information about you and provide it to us. We may be introduced or referred to you by third parties. We may also receive feedback or other information from any such sources.

From your clients and contacts: We may obtain personal information about you from your organisation’s clients and contacts who are introduced to us or who we work with, or who choose to contact us.

From our own observations and records: We keep records relating to the instructions you give, our correspondence with and about you, and our services.

Purposes for which your personal information is used, and our legal bases

For as long as we have access to your personal information, we will use it for any or all of the following purposes (and compatible purposes), unless otherwise required as a result of you exercising your rights under Data Protection Legislation.

Purpose

Basis of use

(If you are an individual or an unincorporated partnership) to provide you with our services.

Use is necessary for our performance of the contract we have with you, or to take steps at your request before we enter into a contract.

(If you are a corporate entity) to work with you in connection with providing our services.

Use is in our legitimate interests in working with staff of our customer in order to provide our services for our customer.

To undertake financial management, planning and reporting within our business.

Use is in our legitimate interest in corporate governance and management of our organisation, our staff, and our services.

 

To manage the security of our services.

Use is in our legitimate interests in managing the security of our products, our services and infrastructure.

To comply with any legal or regulatory requirements.

Use is in our legitimate interests to comply with such requirements, or to put you in the position of being able to comply.

In some cases use will be necessary for us to comply with our legal obligations, for example if we must notify a regulator about any security incident.

For us to take legal or administrative action, including to collect debts, resolve disputes with you or your organisation, and deal with regulators.

Use is in our legitimate interest in enforcing our contract with you or your organisation, in ensuring that our services and supporting infrastructure are used lawfully and in accordance with policies and terms and conditions imposed by us, in resolving any disputes with you or your organisation, in dealing with regulators and in us establishing, exercising or defending legal rights or claims.

 

To give us information about how you use our services.

Use is in our legitimate interests in seeking to develop and improve our engagement with our customers and users, and our business.

 

To build a profile using personal information about you that we acquire via our services or other sources (such as our website and social networks that we use).

 

 

Use is in our legitimate interest in understanding our communities and partners (and their staff) and what they require from our services and in conducting focused and effective marketing and advertising to grow our business. 

You can stop profiling by us and social networks and our other service providers by managing your device and browser settings, rejecting cookies on our website (when asked on the website) and third party websites, choosing not to receive direct marketing from us and our service providers, and not interacting with such material.  We will then still collect your personal information when we provide our services for or in relation to you, but will not use it for direct marketing purposes.

 

To prepare and send you direct email correspondence, containing information about AAL, our products or our services or our channels.

 

Use is based on us only contacting you about services that are similar to those that we have previously provided to you, provided that we have given you the chance to opt out before we start contacting you, and also each time we contact you.

 

Alternatively, use will be based on your explicit consent to us contacting you for direct marketing purposes.

 

If AAL is considering a corporate transaction such as changing its owners, merging or obtaining finance, in which cases (for example) your personal information may be provided confidentially to the potential new owner(s), merger candidate(s) or sources of finance as part of their due diligence on AAL.

Use is in our legitimate interest in evaluating, preparing for or undergoing a change of ownership, merger, acquisition of finance or other corporate transaction.

How long does AAL retain your personal information?

AAL will only retain your personal information for as long as is necessary to fulfil the purposes AAL collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. Retention periods for your personal information will be set in accordance with our Data Protection Policy.

Sharing your personal information

For as long as we have access to your personal information, we may share any of it with any of the following to the extent that they need to have access to your personal information in order to perform their role.

Third parties listed under the heading “Our service providers” are our processors, who use your personal information for our purposes and on our instruction (although there are circumstances where each of them can lawfully become a controller of your personal information).

Other third parties who are listed in this section are controllers, who decide the purposes for which they use your personal information. This Notice explains why we share your personal information with those third parties. You must refer to the similar notices that they provide to understand all their intended uses of your personal information.

Our service providers

  • Any employee within our organisation.
  • Our staff who are appointed as consultants, agency staff, contractors or on any other basis other than as employees, but who are subject to our day-to-day line management or supervision.
  • Our suppliers and service providers appointed by AAL and who are not subject to day-to-day line management and supervision by us.
  • External telecommunications and internet-based services that we use for storing or transferring your personal information, such as our telephone services mobile telephone services, broadband and email providers.

Third parties who use personal information for their own purposes

  • Our regulated service providers, such as banks, payment processing service providers, auditors, professional advisers, financial services providers, accountants and insurance brokers. (Although they each provide services for us, their regulatory compliance, monitoring and reporting responsibilities mean they must each act as a controller in relation to your personal information.)
  • Your and our insurers for the purposes of us taking out or renewing insurance, notifying the insurers, and dealing with actual or potential claims.
  • Public bodies, including courts and tribunals.
  • Law enforcers, including local authorities, the Police, the National Crime Agency, and international law enforcers.
  • Any third party who is considering entering into a corporate transaction with or in relation to AAL (and the third party’s advisers and sources of finance).

We reserve the right to disclose your personal information to other third parties if we have lawful grounds to do so, or are under a legal obligation or permission to disclose or share it with them, or in order to establish, exercise or defend our legal rights or to protect the rights, property, or safety of AAL or our personnel.

We do not give anyone else access to your personal information in return for payment, for marketing or any commercial purposes.

Our transfer of your personal information abroad

Our paper records and IT systems on which AAL store your personal information are all within the UK.

Some third parties that we work with, or that provide goods or services to us, are based outside the EU, so their use of your personal information will involve a transfer of information outside the EU. Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EU.

What if your personal information changes?

It is important that the information we hold about you is correct and accurate. Please tell us if your personal information changes during your relationship with us.

Your rights

Under the Data Protection Legislation and in certain circumstances, you have the right to:

  • Request Access: to personal information that AAL holds about you. This includes a right for you to receive a copy of the personal information AAL holds about you, and to check AAL are lawfully using it.
  • Request Rectification: of your personal information if you become aware of any inaccuracies in your personal information which AAL use.
  • Request Erasure: of your personal information where (a) there is no good reason for us continuing to use your personal information as described in our Notices, (b) AAL rely on your consent and you have withdrawn it, (c) you have exercised your right to object to our use of it (see below) and no exception permits us to keep using it, (d) it is established that AAL did not have a lawful right to use your personal information, or (e) the law requires us to erase your personal information.
  • Object: to the use of your personal information. You can exercise this right if AAL rely 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 the use of your personal information on this ground, if there is no exception which applies to permit us to keep using it.
  • Stop: us carrying our profiling for our direct marketing purposes, or stop us sending direct marketing to you.
  • Restriction of processing: of our use of your personal information. This enables you to ask us to suspend our use of your personal information, for example if you want us to establish its accuracy or the reason for us using it, or you consider AAL no longer needs to use your personal information for the purposes for which it was collected or used (but you want it to be preserved). You may also ask us to restrict use if you exercise your right to object to our use of your personal information and no exception applies to permit us to keep using it.
  • Withdraw your consent: if we rely on your consent as our legal basis for AAL using your personal information.
  • Complain to the ICO: the Information Commissioner’s Office is the personal information regulator in the UK. See www.ico.org.uk for details.

If you want to exercise any of your rights please contact us using the contact details set out at the beginning of this Notice.

No fee is usually required

You will not pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with your request in such cases.

Changes to Privacy Notice

AAL may update this notice at any time. AAL will place the latest version by a prominent notice placed on AAL’s website. AAL may notify you in other ways from time to time of how AAL uses your personal information. It is important that you read this notice, together with any other Notices, so that you are aware of how and why AAL are using such information.

Date of this Privacy Notice: 29 October 2021

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