Privacy Policy
Last Updated: 13 November 2024
At Propela Ventures Ltd (“we,” “our,” or “us”), we are committed to protecting your privacy and ensuring that your personal data is handled in a safe and responsible manner. This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website www.propelaventures.com (“Website”) and engage with our services. It applies to all users of the Website, including investors, potential investors, operators, potential operators and others who interact with our business in the UK, EU, or US.
By accessing our Website or providing your personal data to us, you consent to the collection, use and transfer of your data as described in this Privacy Policy.
1. Data Controller
The data controller responsible for your personal data is:
Propela Ventures Ltd
24 Church Street, Rickmansworth, Hertfordshire, United Kingdon, WD3 !DD
15829884
If you have any questions or concerns about how we handle your personal data, please contact us at:
Data Protection Officer (DPO):
Admin Team
admin@propelaventures.com
2. Types of Data We Collect
We may collect and process the following personal data about you:
- Contact Information: Name, address, email address, phone number.
- Investment Information: Financial details, investment preferences and investment history.
- Identification Information: Passport, identity card, or other identification details required for regulatory compliance.
- Device and Usage Data: IP address, browser type, operating system and website usage data (e.g., cookies).
- Investor Due Diligence Information: Information necessary for compliance with Anti-Money Laundering (AML), Know Your Customer (KYC) and other regulatory requirements.
3. How We Use Your Data
We use your personal data for the following purposes:
- To Provide Services: To manage your investment and provide related services (e.g., portfolio management, updates on fund performance).
- Regulatory Compliance: To comply with regulatory requirements, including KYC, AML and tax reporting obligations in the UK, EU and the US.
- Communication: To communicate with you about our investment opportunities, news, updates and other related services.
- Website Functionality: To improve and personalize the Website experience, track user activity and ensure the security of the Website.
- Legal Obligations: To comply with legal obligations, enforce our terms and conditions and resolve disputes.
4. Legal Basis for Processing (GDPR Compliance)
Under the General Data Protection Regulation (GDPR) and other applicable data protection laws, we rely on the following legal bases for processing your personal data:
- Consent: For communications and marketing purposes, where you have given your explicit consent.
- Contractual Necessity: For the performance of a contract with you or to take steps at your request prior to entering into a contract (e.g., managing your investment).
- Legal Obligation: To comply with laws and regulations, including KYC, AML and tax obligations.
- Legitimate Interests: To improve our services, protect our business and ensure the security and functionality of our Website.
5. How We Share Your Data
We may share your personal data with the following third parties, as necessary:
- Service Providers: Third-party providers who assist us with IT, legal, accounting, marketing, and other administrative services.
- Regulatory Authorities: If required by law, we may share your data with regulatory bodies in the UK, Luxembourg or other relevant jurisdictions for compliance with legal and regulatory requirements.
- Investee Companies: If you are an investor, your data may be shared with investee companies to facilitate investment activities or reporting purposes.
- Other Third Parties: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred as part of the transaction.
We do not sell or rent your personal data to third parties.
6. Data Transfers
As we operate across multiple jurisdictions (UK, Luxembourg, and other EU countries), your personal data may be transferred to or processed by entities outside the UK or EU, including the United States. In such cases, we ensure that appropriate safeguards are in place, such as:
- The use of Standard Contractual Clauses (SCCs) or other legally recognized mechanisms for transfers outside the European Economic Area (EEA).
- Adherence to relevant data protection laws and regulations to ensure your data is processed securely.
7. Data Retention
We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including any legal, accounting, or reporting obligations. This means we will retain your data for the duration of our contractual relationship with you and for any periods required by applicable law or regulation.
8. Your Rights
Under data protection laws, you have certain rights regarding your personal data. These include:
- Access: You have the right to request a copy of the personal data we hold about you.
- Rectification: You have the right to request corrections to any inaccurate or incomplete personal data we hold about you.
- Erasure: You have the right to request the deletion of your personal data, subject to certain conditions.
- Objection: You have the right to object to the processing of your personal data in certain circumstances, including for direct marketing.
- Portability: You may request to receive your personal data in a structured, commonly used and machine-readable format.
- Withdrawal of Consent: If we process your data based on consent, you have the right to withdraw that consent at any time.
- Complaint: You have the right to lodge a complaint with a supervisory authority, such as the UK Information Commissioner’s Office (ICO) or the relevant EU data protection authority.
9. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to improve your experience on our Website, analyze trends, and collect information about the use of the Website. You can choose to switch off cookies when using the Website.
10. Security of Your Data
We take the security of your personal data seriously and employ appropriate technical and organizational measures to protect it against unauthorized access, alteration, disclosure, or destruction. However, please be aware that no data transmission over the internet can be guaranteed to be 100% secure.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology or legal requirements. Any changes will be posted on this page with the updated date. We encourage you to review this Privacy Policy periodically.
12. Contact Us
If you have any questions or concerns about our Privacy Policy or how we handle your personal data, please contact us at:
Propela Ventures Ltd
24 Church Street
Rickmansworth
Hertfordshire
WD3 1DD
admin@propelaventures.com
