Privacy

1. Introduction

This privacy policy (Policy) relates to your personal information in connection with your use of and access to the Clipway website (www.clipway.com) (the Clipway Platform) and any services provided by Clipway (the Clipway Platform and services together forming the Clipway Services).

We are committed to protecting your information and your right to privacy. If you have any questions or concerns about our Policy, or our practices with regards to your personal information, please contact us via privacy@clipway.com.

When you use the Clipway Services, you trust us with your information and we take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue your use of the Clipway Services.

2. Changes to this Policy or your personal information

We review this Policy regularly and it is your responsibility to check regularly and determine whether you still agree to comply with the Policy. If you do not agree to any changes to this Policy then you must immediately stop using the Clipway Services. In the event we make any significant changes to this Policy we will use our reasonable endeavours to inform you of such changes in advance in writing.

It is important that the personal information we hold about you is true, complete, accurate and current. Accordingly, you must notify us of any changes to your personal information (for example, if you change your email address).

3. About us

The Clipway Services are owned and operated by Clipway Limited (trading as “Clipway”), a company registered in England and Wales with company number 13459432 and whose registered office is situated at 5th And 6th Floors,152-156 Great Portland Street, London, England, W1W 6AJ (Clipway/we/us/our). Clipway is the controller (also known as a data controller) of, and is responsible for, your personal information. The term “you” refers to the user wishing to access and/or use the Clipway Services.

Clipway is a private equity firm combining experience and technology to invest in diversified portfolios of buyout and growth assets.

4. Information we may collect about you

4.1 Personal information you disclose to us

(a) Where and how we collect personal information

We collect personal information that you voluntarily provide to us when registering to use and actually using the Clipway Services, or otherwise contacting or interacting with Clipway.

If you apply or are put forward for a role with us, we also collect your personal information, which may include your contact details, details of your education, qualifications and skills, your nationality, your job title and your CV.

We use different methods to collect your personal information including through:

Direct interactions. You may give us your personal information by filling in forms, interacting with Clipway at events, or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you;
have contact with Clipway through introductions or meeting a Clipway representative or corresponding with Clipway in relation to a transaction that Clipway and/or the funds it manages or advises;
apply for and/or use the Clipway Services;
subscribe to our service or publications;
request marketing to be sent to you;
subscribe to our service or publications;
Deal with payment for the Clipway Services;
Resolve disputes or collect overdue payments;
give us feedback or contact us;
Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources – for example for anti-money laundering, background checks or similar purposes;
If we have a business relationship with the company that you represent, your colleagues or other business contacts, they may provide Clipway with personal information such as your contact data or other relevant information; or
Personal information may be collected from publicly available sources such as Companies House.

(b) The types of personal information we may collect

When you use the Clipway Services and/or when you otherwise deal with us, we may collect the following information about you:

Identity Data, which includes your first name and last name.
Contact Data, which means the data we use to contact you including [your billing address], email address and contact number.
Business Data, which includes job title, company, business affiliations and career highlights.
Transaction Data, which means details about transactions you have made in connection with the Clipway Services, including any funds you have invested in.
Usage Data, which includes information about how you use the Clipway Services. This includes your browsing patterns and information such as how long you might spend on one of our webpages on the Clipway Platform and what you look at and for, the page that referred you to the Clipway Platform and the click stream during your visit to the Clipway Platform, page response times, and page interaction information (for example, clicks you make on a page).
Marketing and Communications Data, which includes your preferences with regards to receiving marketing from us and your other communication preferences.
Other personal information relevant to services, customer surveys, questionnaires and/or offers.

4.2 Sensitive personal information

We will not usually ask you to provide sensitive personal information. We will only ask you to provide sensitive personal information if we need to for a specific reason, for example, if we believe you are having difficulty dealing with your account due to illness. If we request such information, we will explain why we are requesting it and how we will use it.

4.3 Personal information from third parties

Occasionally we may receive information about you from other sources, which we will add to the information we already hold about you in order to help us provide, improve and personalise the Clipway Services. If you apply for a job with us, we may also receive information from those who provide references relating to your prospective or actual engagement or employment.

4.4 Information automatically collected

We automatically collect certain personal information when you visit, use or navigate the Clipway Platform. This personal information does not reveal your specific identity (unless your device name is the same as your name) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Clipway Platform and other technical information. This personal information is primarily needed to maintain the security and operation of the Clipway Platform, and for our internal analytics and reporting purposes.

5. How do we use your personal information?

We use your personal information collected via the Clipway Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual Reasons), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons). We indicate the specific processing grounds we rely on next to each purpose listed below.

We may process your personal information for the following purposes:

To operate, manage, develop and promote Clipway and the Clipway Services and to identify you and verify your identity and/or eligibility in connection with any Clipway Services you wish to use;
To take steps towards entering into a contract with you to provide the Clipway Services and to claim any right to be paid under our terms (Contractual Reasons). This includes collecting and using your personal information to:
– Prepare an agreement with you;
– Manage any accounts you hold with us;
– Contact you for reasons related to the Clipway Services;
– Enable us to follow up on enquiries made by you in relation to the Clipway Services and/or to provide information you have requested;
– Contact your referee(s) or to obtain a reference for a job that you are applying for; and
– Notify you of any changes to the Clipway Services that may affect you.
To invite you to presentations and events and organise meetings between you and Clipway representatives and to contact you regarding enquiries you have made in relation to the Clipway Services (Business Purposes).
To provide you with analysis of the markets which Clipway operates in and assess any potential transactions and assess your suitability for involvement in a transaction, including verifying your identity and source of funds (Business Purposes).
To facilitate a recruitment process in which you are involved (Business Purposes).
To send administrative information to you for Business Purposes, Legal Reasons and/or possibly Contractual Reasons. We may use your personal information to send you service and new feature information and/or information about changes to our terms and policies, as may be in place from time to time.
To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our brand partners may use your personal information for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails (see below for further details).
To request feedback for our Business Purposes and/or with your Consent. For example, we may use your personal information to request feedback and to contact you about your use of the Clipway Platform.
To protect the Clipway Services for Business Purposes and/or Legal Reasons. We may use your personal information as part of our efforts to keep the Clipway Services safe and secure (for example, for the purposes of monitoring and/or preventing fraud).
To enforce our terms and policies for Business Purposes, Legal Reasons and/or possibly Contractual Reasons.
To respond to legal requests and prevent harm for Legal Reasons. For example, if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
We may use your personal information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Clipway Services, our services, our marketing and your experience.

6. Will your personal information be shared with anyone?

We only share and disclose your personal information in the following situations:

Contractual. We may share your personal information to enable us to provide you with the Clipway Services – for example with any service providers or subcontractors.
Business Purposes. We may share your personal information with:
– credit reporting agencies and other financial institutions including our own bankers, service providers; our professional advisers, such as our accountants, auditors and lawyers, insurers and industry groups having a legitimate reason to receive such information
– in connection with fund transactions, investor financial or other reports, or for other purposes related to raising, managing and operating private investment funds, or for providing related advice or other services, to our affiliates or third parties who have a legitimate reason to receive such information, including the following:
– – financial service providers, such as placement agents, other broker-dealers, custodians, banks and others used to facilitate transactions for private equity funds;
– – other service providers to private equity funds, their general partners or managers, or their respective affiliates, such as administrators, depositaries, custodians, or providers of legal, accounting or tax preparation services;
– – managers or administrators of, or advisors to, portfolio investments, as well as co-investors in portfolio investments and their advisors, if requested in connection with an investment; and
– – investors in private equity funds or alternative investment vehicles in connection with closing documentation, investor reports, financial statements or other investor communications.
Compliance with Legal Obligations. We may disclose your personal information where we are legally required to do so in order to comply with applicable laws, governmental requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to requests from public authorities in order to meet national security or law enforcement requirements).
Vital Interests. We may disclose your personal information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, illegal activities or situations involving potential threats to the safety of any person, or where we believe it is necessary for the purpose of providing evidence in connection with litigation proceedings in which we are involved.
Third Party Service Providers. We may share your personal information with third party vendors, service providers, credit reference agencies, trade associations of which we are a member, credit card associations, contractors or agents who perform services and require access to such personal information to carry out that work, for example third party software developers or email marketing services.
Business Transfers. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Business Partners. Provided you have given us Consent to do so we may share your personal information with our business partners to offer you certain products, services or promotions.
With your Consent. We may disclose your personal information for any other purpose with your Consent, including with any person who you have named as a person we can contact to discuss your account and any agent or representative of yours.

We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Clipway Services. In such circumstances we will not disclose any information which can identify you personally.

7. Is your personal information transferred internationally?

Whenever we transfer your personal information outside of the UK, we will take all reasonably practicable measures to protect your personal information in accordance with this Policy and applicable laws. To the extent that any transfer requires approved safeguards to be in place we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal information the same protection it has in the UK. Please contact us if you want further information on the specific mechanism(s) used by us when transferring your personal information out of the UK.

8. Third party websites

The Clipway Platform may feature links to third party websites or social media channels, or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy.

We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Clipway Platform. You should review the policies of such third parties and contact them directly if you have any related questions.

9. For how long do we keep your personal information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax law, accounting requirements or other legal or regulatory requirements).

When we have no ongoing Business Purpose to justify the processing of your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. How do we keep your personal information safe?

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. For example, we store your personal information on secure servers and company data is stored on separate secure encrypted disks when not in use.

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.

However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Although we will use our reasonable endeavours to protect your personal information, we cannot guarantee the security or integrity of personal information that is transferred from you or to you via the Internet. Transmission of personal information to and from the Clipway Platform is therefore at your own risk. You should only access our services within a secure environment.

11. Your Consent to processing

You will be required to give Consent to certain processing activities before we can process your personal information. Where applicable, we will seek Consent from you when you first submit your personal information to or through the Clipway Services.

If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing privacy@clipway.com or, where applicable, clicking the ‘Unsubscribe’ button that appears in mailing list communications.

If you withdraw your Consent, and if we do not have another legal basis for processing your personal information, then we will stop processing your personal information. If we do have another legal basis for processing your personal information, then we may continue to do so subject to your legal rights.

Please note that if we need to process your personal information in order for you to use the Clipway Services and you object or do not provide Consent to us processing your personal information, you accept that the Clipway Services will no longer be available to you.

12. Marketing and opting out

If you have given Consent to marketing we may contact you about our services, promotions and special offers. If you no longer wish to receive such information, you can withdraw your Consent at any time by sending an email to privacy@clipway.com or unsubscribing from the communications.

If you have given Consent, we may share your personal information with carefully selected third party organisations and business partners and they may contact you directly. If you would prefer to no longer receive direct marketing communications from third parties and partners after previously giving your Consent, please contact those third parties and partners directly to withdraw the Consent.

Where you opt out of receiving marketing messages, this will not apply to personal information provided to us in connection with your purchase service or your involvement in other related transactions.

13. What are your privacy rights?

You have certain rights in relation to the personal information that we hold about you. Details of these rights and how to exercise them are set out below. Please note that we will require evidence of your identity before we are able to respond to any requests. This is a security measure to ensure that your personal information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. To exercise or discuss any of your rights, please contact us via privacy@clipway.com.

Right of Access. You have the right at any time to ask us for a copy of the personal information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason(s) for doing so.
Right of Correction or Completion. If personal information we hold about you is not accurate or is out of date and requires amendment or correction, you have a right to have the data rectified or completed.
Right of Erasure. In certain circumstances, you have the right to request that the personal information we hold about you is erased (for example, if the personal information is no longer necessary for the purposes for which it was collected or processed or our processing of the personal information is based only on your Consent and there are no other legal grounds on which we may process the personal information).
Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information (for example, if we are processing your personal information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests).

You may also have the right to restrict our use of your personal information, for example during a period in which we are verifying the accuracy of your personal information in circumstances where you have challenged the accuracy of that information.

Right of Data Portability. In certain instances, you have a right to receive the personal information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format.

In such circumstances, you can ask us to transmit your personal information to you or directly to a third-party organisation on your behalf.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.

If we are relying on Consent to process your personal information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing that occurred before the withdrawal of such Consent.

14. Contact us

We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy or have any other questions, please email us via privacy@clipway.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns).

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.