Literacy Capital Privacy Policy

This Website Privacy Policy applies only to online information-gathering on the website for Literacy Capital plc, www.literacycapital.com (“Our Site”). Literacy Capital plc (the “Fund”) understands that your online privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Website Privacy Policy carefully and ensure that you understand it. Your acceptance of our Website Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Website Privacy Policy, you must stop using Our Site immediately.

This Website Privacy Policy may change so please remember to check back from time to time. This version was last updated on 30 May 2018.

 

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings: 

 

“personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our”

means Literacy Capital plc, a company limited by guarantee in England and Wales with registered number 10976145, whose registered address is Suite 1, 3rd Floor, 11-12 St. James’s Square, London, United Kingdom, SW1Y 4LB

2. Information About Us

2.1 Our Site, www.literacycapital.com, is operated by Literacy Capital plc.

2.2 We are a “data controller” for the purposes of the EU General Data Protection Regulation 2016/679 (“Data Protection Law”). This means that we are responsible for, and control the processing of, your personal information.

3. What Does This Policy Cover?

3.1 This Website Privacy Policy applies only to your use of Our Site. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

 

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;

4.1.2 The right of access to the personal data We hold about you (see section 12);

4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);

4.1.4 The right to be forgotten i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to Us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

 

5. What Data Do We Collect?​

5.1 We collect information through your use of Our Site, largely when you contact us for more information about the Fund.

 

5.2 The information retained by us, as provided by you on Our Site, will include some or all of the following personal and non-personal data:

5.2.1 full name;

5.2.2 email address; and

5.2.3 purpose for contacting the Fund.

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of an agreement with you, because you have consented to Our use of your personal data, or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

 

6.2.1 Supplying Our services to you (please note that We require your personal data in order to enter into an agreement with you);

6.2.2 Personalising, safeguarding and tailoring Our services for you;

6.2.3 Replying to emails from you;

6.2.4 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing lcpteam@literacycapital.com with a subject line of REMOVE FROM MAIL LIST);

6.2.5 Market research.

 

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR post with information and news on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

 

6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected on Our Site.

 

7. How and Where Do We Store Your Data?

 

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

7.2 The data about You collected form our website will only be stored in the UK.

7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

 

8. Do We Share Your Data?

 

8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.

 

8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

 

9. What Happens If Our Business Changes Hands?​

9.1 We may, from time to time, expand or reduce Our operations and this may involve the sale and/or the transfer of control of all or part of Our operations. Any personal data that you have provided will, where it is relevant to any part of Our operations that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Website Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller. 

10. How Can You Control Your Data?

10.1 When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).

 

11. Your Right to Withhold Information​​

11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

 

12. How Can You Access Your Data?

12.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at lcpteam@literacycapital.com with a Subject line of GDPR INFO REQUEST or using the contact details below in section 13.

 

13 Contacting Us

13.1 If you have any questions about Our Site or this Website Privacy Policy, please contact Us by email at lcpteam@literacycapital.com. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

 

14 Changes to Our Website Privacy Policy

14.1 We may change this Website Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Website Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

Literacy Capital Cookie Policy

1. Background

Cookie is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or tablet when you visit our website. They let our website recognise your device, so that our website can work more effectively, and gather information about how you use our site. A cookie, by itself, can't be used to identify you.

2. How do we use Cookies?

We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you come to our website and as such allows us to improve the user experience.  

 

3. The Cookies we use

We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide. We use all four categories of cookies:

  • Strictly necessary cookies are essential for you to move around our website and to use its features.

  • Performance cookies collect anonymous information about how you use our site, like which pages are visited most.

  • Functionality cookies collect anonymous information that remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.

 

4. No Cookies, please

You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser. But, if you choose to refuse all cookies, our website may not function for you as we would like it to. 

 

If you have any questions about how we use cookies, please contact us on lcpteam@literacycapital.com.

© 2019 by Literacy Capital