Apollo Informal Investments Ltd Privacy Notice December 2021

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Apollo Informal Investments respects your privacy and is committed to handling your personal data appropriately.

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This privacy policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and how we comply with our responsibilities under applicable data protection laws (including, when and to the extent in force, the Data Protection Act 1998, the General Data Protection Regulation (Regulation (EU) 2016/679), the Privacy and Electronic Communications Regulations 2003, the UK Data Protection Act 2018 (UK DPA) and relevant Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (“Data Protection Laws“)).

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Please read this policy carefully and if you have any questions or concerns, please contact us at board@apollo-informal-investment.com

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Our contact details

The Data Controller for the purposes of Data Protection Laws is Apollo Informal Investments Limited, incorporated in Scotland, company number SC460425 and having its Registered Office at 5th Floor, Quartermile Two, 2 Lister Square, Edinburgh, EH3 9GL. You can contact us by mail or by email at: board@apollo-informal-investment.com.

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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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us first.

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Data we collect and use of this data - members and potential members

We hold information about you which you provide to us in your membership application forms, FSMA Declarations, General Power of Attorney, via the Apollo investment platform (currently Gust) and in the course of your meetings or correspondence with us. On occasion, we may be provided with information by your or our solicitor (for example in relation to investments or anti-money laundering verifications) or by an existing member or board member (where, for example, you are introduced to Apollo and invited to attend a members’ meeting as a guest).

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We may collect the following personal data from you:

• name

• address

• contact details

• date of birth

• financial information (including details of your Apollo investments and investment appetite)

• CVs and details of your experience and directorships.

 

The personal data and other information we hold about you may be used to:

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• assess your membership application

• carry out checks and maintain records in relation to anti-money laundering verifications and your certification as a high net worth or sophisticated investor

• inform you of investment opportunities

• provide you with access to the Apollo deal room on our investment platform, currently Gust

• facilitate you entering into investment agreements

• ensure you receive copies of investment agreements, share certificates, EIS certificates and other shareholder communications and updates in relation to companies in which you have invested

• invite you to Apollo meetings and events

• update you on Apollo activities and the young company finance market

• inform you of opportunities to participate in Apollo activities, act as an Observer or Investor Director or otherwise become involved with companies that Apollo members have invested in

 

and otherwise in the normal course of carrying out Apollo’s core business, for any other purpose specifically permitted by the Data Protection Laws and/or which you may authorise.

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Data we collect and use of this data – investee companies

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We hold information about you and your primary contacts which you (or someone acting on your behalf) provide to us in your investment pitch, via the Apollo investment platform (currently Gust) and in the course of meetings or correspondence with us.

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We may collect the following personal data about you or your primary contacts:

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• name

• address

• contact details

• CVs and details of experience and directorships.

 

The personal data and other information we hold about you may be used to:

• carry out due diligence and communicate with you regarding your investment proposals and the management of

• your business

• distribute your investment proposals and management information to our members

• invite you to Apollo meetings and events

• update you on Apollo activities

and otherwise in the normal course of carrying out Apollo’s core business, for any other purpose specifically permitted by the Data Protection Laws and/or which you may authorise.

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Disclosure and sharing of your personal data

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To the extent reasonably required, we may disclose personal data (a) to third parties that provide finance, IT, professional advice and other services to Apollo (including the Apollo investment platform, currently provided by Gust); (b) to solicitors and other parties participating in or facilitating any investment opportunity you are involved in; (d) any company in which you have invested or wish to invest; (e) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation and (f) for any other purposes specifically permitted by the Data Protection Laws or for any other purpose which you may authorise.

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If you are a member, your name and contact details will be able to be viewed by other Apollo members on the Apollo investment platform, currently Gust.

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Personal data may be shared on a controller/controller basis with Scottish Enterprise in connection with any investment opportunity in which Scottish Enterprise provide or are being asked to provide investment monies.

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Scottish Enterprise processes personal data in accordance with data protection legislation and their privacy notice (https://www.scottish-enterprise.com/help/privacy-notice).

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We may use the third-party event management software Eventbrite to invite you to events. We may use third-part site Doodle to help us find suitable dates. We may send you regular updates via the Apollo investment platform, currently provided by Gust. We may use Docusign to facilitate electronic signature of documentation.

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Basis of processing

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We process your data in order to perform our obligations under our agreement with you or in order to take steps at your request prior to entering into a contract with you or you becoming a member of Apollo and in order to comply with Apollo’s legal obligations. We may also process your data for the legitimate interests of Apollo, including for the purposes of setting and collecting membership fees and monitoring Apollo investment activity and member investment appetite for reporting and strategy purposes and monitoring diversity.

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Accuracy of personal data

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Apollo tries to ensure that personal data we hold about you is accurate and kept up to date. If you believe that any information we are holding about you is inaccurate, out-of-date, or incomplete, please contact us as soon as possible. We will promptly correct or delete any information found to be incorrect.

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Security

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We have put in place what we consider to be appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.

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Transferring personal data outside the EEA

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We may transfer personal data we hold about you to a country outside the European Economic Area (“EEA“) where we engage suppliers located in jurisdictions outside the EEA. If we transfer any data to any other jurisdiction outside the EEA, we will provide you with details of the country to which data is being transferred, along with details of the measures we have put in place to protect it (which you may see a copy of, on request). Where information is shared with Docusign for the purposes of the electronic signature of documentation, full details of the security measures in place are available here: https://www.docusign.com/trust

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Retention of personal data

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Apollo will take all reasonable steps to destroy, or erase from our systems, all personal data which is no longer required.

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Access and other rights

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You may ask to view records held about you at any point by making a request in writing to us at our registered office address or by e-mail. This request will be responded to within 30 working days. If we require more time to respond fully to any request, we will notify you in writing within the 30-day period referred to. Additional copies of any information we are asked to provide to you may be subject to a reasonable fee.

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You also have other rights under Data Protection Laws in relation to your personal data:

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• the right to request that we rectify or erase information we hold about you in certain circumstances

• the right to ask us to limit our processing of your information

• the right (if we are processing information based on your consent, such as for marketing purposes) to withdraw your consent,

• the right to object to certain processing of your information (including the right to object to processing of your personal data for direct marketing purposes at any time)

• the right to ask us to move, copy or transfer your personal information to another organisation.

 

If you wish to exercise any of these rights, please contact us at our registered office address or by e-mail. We may not be able to continue to provide you with our services in the event you request that your details are removed.

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Changes to this policy

We may make changes to this Privacy Policy from time to time. Updated versions will be available on the Apollo website.