Date: March 2022
1 Introduction
1.1 Vitruvian Partners LLP (“Vitruvian, “us”, “our”, “we”) takes the protection of your privacy and personal data seriously and we are committed to respecting the privacy of all visitors to the website www.vitruvianpartners.com website (the “Website”). Vitruvian is authorised and regulated by the UK Financial Conduct Authority (the “FCA“) with registration number 454063. This policy sets out what personal data we might collect, how we process and protect that data, the lawful grounds for that processing, and your related rights. This Privacy Policy applies to any personal data we collect about you, for example by accessing this Website or by investing in funds managed by Vitruvian or enquiring about any funds managed by Vitruvian or our services. ‘Personal data’ means any information relating to an identified or identifiable natural person, namely one who can be identified, directly or indirectly from that information alone or in conjunction with other information. By visiting and/or contacting us through the Website, you consent to this Privacy Policy, and you acknowledge that we may collect, use and transfer your Personal Information pursuant to the terms of this Privacy Policy. If you do not accept the terms of this Privacy Policy, do not use the Website.
1.2 Please note that, unless specified herein, the definitions used in this Privacy Policy are defined in the Terms and Conditions.
1.3 Vitruvian Partners LLP of 105 Wigmore Street, London W1U 1QY, England, is registered as a data controller with the Information Commissioner’s Officer, registration number Z3534459. Vitruvian Partners Limited of 105 Wigmore Street, London W1U 1QY, England, is also registered as a data controller with the Information Commissioner’s Officer, registration number Z3534232.
1.4 We do not market to or enter into contracts with children nor do we collect personal data from any person under 18 years of age. Please do not access of use the Website or services if you are under 18 years of age.
2 Information we may collect from you
Vitruvian may collect and process the following data in the normal course of business:
• technical information: this will include information such as the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit: this will including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
• personal information if voluntarily provided by you, including name and email addresses as may be provided by you through discussions or by email or telephone when contacting us or creating user profiles; and
• statistical information about your visit to the Website including the pages you visited and which browsers are used to visit the Website.
3 Use of information
3.1 Vitruvian may use information held about you in the following ways:
• to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve the Website to ensure that content is presented in the most effective manner for you and for your computer;
• as part of our efforts to keep the Website safe and secure;
• to correspond with you and to respond to queries about the investment funds we manage, to investigate investment opportunities, and to market our funds in accordance with applicable rules and regulations where we have a right to do so.
3.2 We will only use your personal data if and to the extent that applicable law allows. In most cases we will process your personal information to the extent:
• it is necessary for the performance of a contract with you or the organisation you work for;
• it is necessary in connection with a legal obligation;
• you have given your consent (where necessary) to such use or the organisation you work for has obtained your consent (where necessary) to share your information with us; or
• if we (or a third party) have a legitimate interest which is not overridden by your interests or your rights and freedoms. Such legitimate interests include the provision of services, running Vitruvian’s business and marketing relevant services directly to you.
4 Recruitment
If you apply for a job with us, you may need to provide personal information including special categories of personal information (for example, details of extenuating circumstances). Your application directly to us, or via a recruitment agency, will constitute your express consent to our use of this information. We will use this information to consider your application for a position with us. We may also use the information to carry out checks to verify the information provided by you (including reference, background, identity, suitability and criminal record checks). We may disclose it to recruiters, screening check providers, providers of occupational personality tests, health service providers, professional associations, government and law enforcement agencies, referees and your current and previous employers.
5 Disclosure
5.1 We will not give, sell or rent your personal data to third parties so they can market their services to you. Nor do we accept advertising from third parties on the Website. We may share personal data in the following limited circumstances (in each case, as necessary to fulfil the purposes set out in this Privacy Notice):
• any member or affiliate of the Vitruvian group;
• members and employees of the Vitruvian group;
• our fund administrator and our advisers; and
• analytics, platform and search engine providers that assist us in the improvement and optimisation of the Website, including Lead Forensics and Google Analytics.
5.2 Vitruvian may also disclose your personal information to third parties:
• in the event that it sells or buys any business or assets, in which case it may disclose your personal data to the prospective seller or buyer of such business or assets or their advisors;
• if Vitruvian or substantially all of its assets are acquired by a third party, in which case personal data held by it, including about its investors will be one of the transferred assets; and
• if it is under a duty to disclose or share your personal data by law or in order to comply with any legal obligation, regulation or court order, or in order to enforce or apply the Terms and Conditions, or to protect the rights, property, or safety of Vitruvian.
5.3 In each case, we shall take steps as reasonably necessary to share the minimum personal data necessary and have written contracts in place incorporating relevant wording to safeguard that personal data and comply with applicable laws, and we will only share such data as is necessary for the purpose in question. The personally identifiable information that you provide to us may be accessed by (or given to) our staff working outside the UK and the third parties referred to above, some of whom may be located outside the European Economic Area. Countries outside the European Economic Area may not necessarily have adequate data protection laws. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.
5.4 As a default position, we will only keep your personal data for as long as we reasonably require and, in any event, only for as long as applicable data protection legislation and our own internal rules and policies allow. This is subject, for example, to any valid opt-out or withdrawal of consent where processing is based on consent, or other valid exercise of your data subject rights which is affected.
6 Third Parties
The Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Vitruvian does not accept any responsibility or liability for these policies. We suggest that you carefully review the terms and conditions of use, and privacy policies, of each website that you visit before you submit any personal data to these websites. This Privacy Policy does not cover the information practices of those websites linked to from our Website. Other websites may send their own cookies to users, collect data, or solicit personal information.
7 Protection
The security of data is very important to our business. In accordance with our legal obligations, we take appropriate technical and organisational measures to protect your personal data and keep those measures under review. However, we can only be responsible for systems that we control and we would note that the internet itself is not inherently a secure environment.
8 Your Rights
Individuals whose personal data is processed by Vitruvian have certain legal rights regarding their personal data where relevant data protection laws apply. These rights include without limitation those listed below.
You have the right to: (i) know if we process any personal data about you and, if we are, with certain limitations, to a copy of that personal data; (ii) ask us to remove or correct any of that personal data that is inaccurate, to object to certain processing and to withdraw any consent you may have given us for any processing of your personal data; (iii)ask us to restrict processing certain of your personal data, to erase your personal data, and to ‘port’ certain of your personal data to you or another provider, provided in each case that we have such data and certain conditions are met; and (iv) at any time, object to the processing of your personal data for direct marketing.
9 Changes to our Privacy Policy
As data protection law and practice are constantly developing, we’ll need to update this policy from time to time, which we’ll do by posting a new policy on the Website that takes effect from the date stated. It is your responsibility to return to the Website from time to time and check for changes.
10 Cookies
10.1 By using the Website with your browser settings adjusted to accept cookies you consent to our use of cookies on the Website, which include Google Analytics cookies. We will be using Google Analytics cookies to collect information about how visitors use our Website, and we will use this information to improve the Website. These cookies collect information in an anonymous form, and such information includes the number of visitors to the Website, where visitors have come from before visiting the Website and the pages they visit. To learn more about what cookies are set on your computer as you browse the Internet and how to manage or delete them, visit www.allaboutcookies.org.
10.2 A cookie is a small piece of data that a website stores on your computer. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. We do not use cookies to store any personal information that could be read or understood by others.
10.3 We use cookies primarily for administrative purposes, to improve your experience with our Website. We only use cookies to capture anonymous analytics to improve your experience of the Website and its performance. This includes compiling statistical information concerning, among other things, the frequency of use of our Website, the pages visited, and the length of each visit, as well as information about your computer, operating system, browser, language, and country.
11 Terms and Conditions
Use of the Website is subject to our Terms and Conditions.
12 Contact
If you have any questions or requests in relation to this Privacy Policy, please address these to compliance@vitruvianpartners.com. We hope that we will be able to resolve any query or concern you raise about our use of your personal data. If you feel we have not handled your query or concern to your satisfaction you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at www.ico.org.uk/concerns or telephone 0303 123 1113.
13 Governing Law and Jurisdiction
This Privacy Policy is governed by and is to be construed in accordance with English law. The courts of England and Wales shall have exclusive jurisdiction to settle any dispute arising out of or in connection with this Privacy Policy.