InReach Data Privacy Notice

This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you relating to our analysis of the market and potential investment opportunities. We are required to provide you with certain information under data protection legislation.

What is the relationship between InReach Ventures LLP and InReach Data Limited?

InReach Ventures LLP is an investment firm which uses a software platform to identify and evaluate relevant investment opportunities. For details of how InReach Ventures LLP processes personal information, please click here.

InReach Data Limited is an associated company of InReach Ventures LLP, and owns the software platform that is used by InReach Ventures LLP (and other users of the platform who may be authorised from time to time) to identify potential investment or other corporate opportunities. The platform collects and processes company data (which may include limited personal information about the company’s founders and key employees) to help platform users identify the most relevant opportunities. Any personal information within the platform is processed in accordance with this privacy notice.

Who collects information about you?

InReach Data Limited (company number: 9601812), registered office: c/o Rees Pollock, 16 Great Queen Street, Covent Garden, London WC2B 5AH United Kingdom (us or we) is a ‘data controller’. This means that we are responsible for deciding how we hold and use certain information about you.

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

What information do we hold about you?

We may collect the following information about you:

Your name and contact details;
Details of the company you own or work for, including its location and any shareholding you may have in the company;
Public URLs for professional and social networking platforms;
Work contact details;
Your current role, professional skills, work and education history;
Any other information which you provide to us directly.

How is your information collected?

We may collect information about you from the following sources:

Directly from you. We may obtain information from you when you complete our online form (including where you partially complete the form), or where you provide us with requested information during a phone call or video call. You may also provide us with information when we correspond with you via e-mail or any other forms of communication.
From third parties within your company. Through our online form, or any of the methods of communication referred to above, we may collect information about co-founders and key employees within your company.
From third party sources. As part of our analysis of the market and potential investment opportunities, we may obtain information from other third party sources to supplement the information we already hold about you or to gather initial information about you and your company. We may obtain the data from various sources, including through APIs with other professional or social networking platforms, partner companies who in turn obtain personal information about individuals from business networking platforms, or through publicly available sources (for example, where you have made your work details available to the public on certain publicly available platforms or your company’s own website).

How we will use information about you

We may use the information we collect about you:

To communicate with you in relation to any funding application you submit;
To evaluate and store any information you provide to us about you, your colleagues or your business for potential investment evaluation purposes, ongoing development of our own technology and products and market analysis;
To maintain information about you, your colleagues, and your business as an ongoing reference tool or general resource for our business;
For us to comply with our legal and regulatory obligations;
To contact you in relation to potential investment opportunities;
To enable others to evaluate potential investment and/or corporate opportunities concerning your company, and to contact you in relation to these;
To consider whether or not to enter into a contract with your company for investment purposes;

We use and share your personal information based on our legitimate commercial interests and those of our trusted partners, in accordance with relevant data protection legislation. However, we take care to ensure that your interests and fundamental rights do not override those interests. You have the right to object to this processing and if you wish to do so, please contact us using the details provided in this Privacy Notice.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider a potential investment opportunity, we may not be able to process your online application for funding.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. Our internal proprietary software may perform automated processing based on company information (which may include your personal information) which we have obtained to identify and analyse potential investment opportunities. However, you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so.

Why might you share my personal information with third parties?

We may need to disclose your information in the following circumstances:

Where we need to share your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 or InReach Ventures LLP, our associated company, to perform the purposes set out in this Privacy Notice. We (and members of our group) may also need to share some of your information with our affiliates and professional advisers;
We may pass data to other companies that process personal data on our behalf to help us conduct our business. When we do so, we ensure that appropriate contractual safeguards are put in place;
Where we allow other persons or companies, such as our trusted partners or other authorised third party platform users, to access your information. For example, trusted investor partners who need to evaluate whether they are able to offer investment for your company.
Where we are required to comply with any legal obligation, to enforce or apply our Terms of Use and other agreements, or to protect the rights, property or of us, members of our group, our customers, or others, including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may also disclose your information to third parties if:

we sell or buy any business assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets and their professional advisers;
we, members of our group or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.

We will only share your information with third parties outside our group where disclosure is consistent with a legal basis for processing on which we rely and where this is lawful and fair to you. We may disclose your information if it is necessary for our legitimate interests or the interests of a third party but will not do this if these interests are overridden by your interests and rights in particular to privacy.

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.

Where and how we store your information

The data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers, trusted partners or other authorised third party platform users for the purposes set out above only. In order to ensure that any third party treats your personal data in a way which is consistent with the UK and EU’s laws on data protection, we will put in place agreements with those third parties which contain provisions approved by the EU for protecting personal data.

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 according to 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 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 rights in connection with your personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you would like to exercise any of those rights, please:

Contact us in writing at privacy@inreachventures.com;
let us have enough information to identify you;
let us have proof of your identity and address; and
let us know the information to which your request relates.

Who to contact with queries or if you have a complaint

If you have any questions about this privacy notice or how we handle your personal information, please contact us at privacy@inreachventures.com. We hope that any query or concern you raise about our use of your information can be resolved but if not, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. See https://ico.org.uk/concerns or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Changes to this Privacy Notice

This Privacy Notice may be reviewed and amended from time to time. If we make any substantial change to the way in which we use your personal information we will notify you, where possible. Please see our website at www.inreachventures.com for the latest version of this Privacy Notice.