Apiary Capital LLP
91 Wimpole Street
London W1G 0EF

Nikola Sutherland
Partner

Mark Salter
Managing Partner

Nicki Boyd
Partner

Rob Simpson
Partner

Jeniv Shah
Investment Director

APIARY CAPITAL LLP PRIVACY NOTICE

Apiary Capital LLP (“Apiary”, “we” or “us”) is committed to protecting the privacy and security of your personal information in accordance with applicable UK data protection laws, including the General Data Protection Regulation (the “GDPR”). Apiary is authorised and regulated by the Financial Conduct Authority.

This Privacy Notice sets out the basis on which we may process your personal data during the course of our business relationship, including through your use of our website, when you contact or request information from us, when you engage with us professionally or as a result of your relationship with one or more of our staff.

Purpose of this Privacy Notice

This Privacy Notice describes how Apiary collects and uses your personal data.

Apiary is a "Data Controller". This means that we are responsible for deciding how we collect and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.

We have appointed a person responsible for Apiary’s compliance with the applicable data protection legislation. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact:
Nikola Sutherland
nsutherland@apiarycapital.com +44 (0)203 908 5947
Apiary Capital LLP, 91 Wimpole Street, London W1G 0EF

The data we collect about you

Personal data 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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Generally, we do not rely on consent as a lawful basis for processing your personal data.

Purposes for which we will use your personal data

We have set out below a description of 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 under more than one lawful ground, depending on the specific purpose for which we are using your data.

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.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of our business relationship.

Disclosures of your personal data

We may have to share your personal data with third parties such as our agents and service providers; our regulators, including the Financial Conduct Authority; and law enforcement agencies in connection with any investigation to help prevent unlawful activity.

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.

International transfers

We may need to transfer your personal data outside the European Economic Area. We will ensure that any transfer of your data will be subject to appropriate safeguards, and we will ensure you have appropriate remedies in the unlikely event of a security breach.

Data security

Apiary has 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 the Information Commissioner’s Officer (the “ICO”), the UK supervisory authority for data protection issues, of a breach where we are legally required to do so.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred via the internet. If you have any particular concerns about your information, please contact us at info@apiarycapital.com

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Your legal rights

Under certain circumstances, by law you have the right to request access to your personal information; request correction of the personal information that we hold about you; request erasure of your personal information; object to processing of your personal information; and request the restriction of processing of your personal information.

No fees usually required

You will not have to 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 the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to complain

If we have not dealt with your concerns appropriately, you have the right to make a complaint at any time to the ICO (www.ico.org.uk).

May 2018