Privacy & Cookies Policy

  1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://www.truestoneimpactinvestment.co.uk/ and/or use our services.

By providing us with your data, you warrant to us that you are over 13 years of age.

TRUESTONE IMPACT INVESTMENT MANAGEMENT LIMITED is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Full name of legal entity:   Truestone Impact Investment Management Limited

Email address:                      info@tiim.co.uk

Postal address:                     20 St Dunstan’s Hill, London EC3R 8HL

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at enquiries@tiim.co.uk.

  1. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information about an individual from which that person can be identified.  It does not include data where the identity has been removed (anonymous data).

We may process the following categories of personal data about you:

  • Communication Data: This includes any communication that you send to us whether through the contact form on our website, email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Investor Data:  When you register to use our services we may ask you to provide certain information such as your name, address, email address, contact number, and bank account details.  We process this data to manage the investments you have made, to keep records of the same and to send you investment reports. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • User Data: This includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
  • Technical Data: This includes data about your use of our website and online services such as your IP address, (your login data), details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
  • Marketing Data: This includes data about your preferences in receiving information about investment opportunities from us and our third parties and your communication preferences. We process this data to enable you to receive information about new investment opportunities, relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
  • We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and investment opportunities to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business.
  • Sensitive Data: We do not collect any sensitive data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver services to you). If you don’t provide us with the requested data, we may have to cancel a service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at enquiries@tiim.co.uk.  In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

  1. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this https://truestoneimpactinvestment.co.uk/privacy-cookies-policy/ 

We may receive data from third parties such as analytics providers based outside the EU (e.g. Google), advertising networks such as Facebook based outside the EU, search information providers based outside the EU (e.g. Google), providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

  1. MARKETING COMMUNICATIONS 

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you our marketing communications if (i) you have already made an investment or asked for information about our services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

We do not currently share your personal data with any third party for their marketing purposes nor will we do so in the future without first obtaining your express consent.

You can ask us or third parties to stop sending you marketing messages at any time unsubscribing or by emailing us at enquiries@tiim.co.uk at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of entering into investment opportunities.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers
  • Government bodies that require us to report processing activities.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

  1. INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.  We may share your personal data with companies in which you have invested which involves transferring your data outside the European Economic Area (EEA).  This will only apply where this is required to comply with statutory regulations of the country in which your investment sits.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

  • US-based providers (such as Google Analytics) are part of the EU-US Privacy Shield and have equivalent safeguards in place; or
  • We may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
  1. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

  1. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding the correct period for which to keep the data we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our investors (including Contact, Identity, Financial and Transaction Data) for six years after they stop being investors.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.  If you wish to exercise any of these rights, please email us at enquiries@tiim.co.uk.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request in order to speed up our response.

We aim to respond to all legitimate requests within one month.  Occasionally it may take longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

  1. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://truestoneimpactinvestment.co.uk/privacy-cookies-policy/

  1. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may need to update this Policy at any time and without notice and where we do this we will notify you by including pop up boxes on the website and/or emailing our customers. This Policy was last updated on 25 May 2018.

It is important that the personal data we hold about you is accurate and up to date.  Please keep us informed if your personal data changes during your relationship with us and periodically review your account settings on our website.

 

Private: Important Information

This website is not suitable for retail investors. It contains investment information for certified High Net Worth Individuals, Sophisticated and Professional Investors only.

Please read this page before proceeding as it explains certain restrictions imposed by law and regulation on the distribution of the information on this website.

This website is issued by Truestone Impact Investment Management Limited (“TIIM”) which is authorised and regulated by the Financial Conduct Authority (FCA Register number 522413) www.fca.org.uk. TIIM is a company registered in England & Wales. Registered Number: 0721774. Registered Office: 6th Floor, 60 Gracechurch Street, London, EC3V 0HR. Truestone Impact Investment is a trading name of TIIM.

This website is directed exclusively at UK authorised institutional investors, professional financial advisers and intermediaries (“professional investors”) only in connection with the investment business of eligible investors. If you are not a UK eligible investor then you should not access this website.

This website is not intended as and is not to be taken as an offer or solicitation with respect to the purchase or sale of any investment, nor does it constitute an offer or solicitation in any jurisdiction, including those in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such a solicitation or offer. It is your responsibility to be aware of and to observe all applicable laws and regulations of any relevant jurisdiction.

Any decision to purchase investments with respect to the Funds or direct investments described on this website must be based solely upon the information contained in the Prospectus for that investment, including any supplements thereto, which must be received and reviewed prior to any investment decision. Any person subscribing to the Funds and direct investments must be able to bear the risks involved and must meet the eligibility requirements (further details of which are set out below).

Please note that when you confirm you have read this important information we will place a cookie on your computer to recognise you and prevent this page reappearing should you access this site on future occasions. The cookie will expire after six months or sooner should there be a change to this important information.

A cookie is a small data file. Such cookies do not retrieve information about you stored on your hard drive and do not corrupt or damage your computer or computer files. You are not obliged to accept a cookie that we send to you, and you can in fact modify your browser so that it will not accept cookies. For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org.

By confirming that you have read this important information, you also:

(i) Agree that such information will apply to any subsequent access to the Individual investors Club (or Institutions / Intermediaries) section of this website by you, and that all such subsequent access will be subject to the disclaimers, risk warnings and other information set out herein; and
(ii) Warrant that no other person will access the Individual Investors Club section of this website from the same computer and logon as you are currently using.

This website contains information about the Truestone Impact Fund LP (an English Limited Partnership) and other similar funds and direct investment opprotunities. Prospective investors should be Professional Investors as defined by the Handbook of rules and guidance of the Financial Conduct Authority (“FCA”) which is available at www.fca.org.uk (“Eligible Investors”). Please note that Truestone Impact Investment Management Limited cannot advise whether these are suitable investments for you. For advice on suitability, please contact your financial adviser.

TIIM is the investment manager of the Truestone Impact Fund LP and other funds that may be described on this website. Trinity Fund Administration Limited is the Administrator of the Truestone Impact Fund LP and is authorised by the Central Bank of Ireland.

The information contained on this site is subject to copyright with all rights reserved. It must not be reproduced, copied or redistributed in whole or in part.

The information contained on this site is published in good faith, but no representation or warranty, express or implied, is made by TIIM or by any person as to its accuracy or completeness and it should not be relied on as such. TIIM shall have no liability, save for any liability that TIIM may have under the UK Financial Services and Markets Act 2000 (or the name of any replacement legislation if the legislation permits such a statement to be made), for any loss or damage arising out of the use or reliance on the information provided including without limitation, any loss of profit or any other damage, direct or consequential. No information on this site constitutes investment, tax, legal or any other advice.

Where a claim is brought against TIIM by a third party in relation to your use of this website, you hereby agree to fully reimburse TIIM for all losses, costs, actions, proceedings, claims, damages, expenses (including reasonable legal costs and expenses) and other liabilities, whatsoever suffered or incurred directly or indirectly by TIIM as a consequence of improper use of this website.

You acknowledge and agree that it is your responsibility to keep secure and confidential any passwords that we issue to you and your authorised employees and not to let such password(s) become public knowledge. If any password(s) become known by someone other than you and your authorised employees, you must change those particular password(s) immediately using the function available for this purpose on the website.

You may leave the TIIM website when you access certain links on this website. In so doing, you may be proceeding to the site of an organisation that is not regulated under the UK Financial Services and Markets Act 2000. TIIM has not examined any of these websites and does not assume any responsibility for the contents of such websites nor the services, products or items offered through such websites.

TIIM shall have no liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to, any direct, indirect or consequential damage, arising out of the use of this website.

Selected risk factors applicable to an investment in funds or direct investments that we wish to bring to your attention are as follows:

  • Past performance is no guarantee of future performance.
  • The value of investments and the income from them may go down as well as up and are not guaranteed.
  • You may not get back the amount you invested.
  • The favourable tax treatment of Enterprise Investment Schemes (EISs) is subject to government legislation and as such may not be maintained.
  • The levels and bases of, and reliefs from, taxation changed in the last Budget and may change in the future.
  • Rates of exchange may cause the value of investments to go up or down.
  • Fluctuation may be particularly marked in the case of a higher volatility investment and the value of an investment may fall suddenly and substantially.
  • Investments appearing on this site may offer limited or no liquidity and will not be suitable if you require ready access to your capital

Further risk factors are set out in the Offering Documents for investments appearing on this website, which should be considered in full in connection with a potential investment in them.

You can gain access to the FCA’s register and rules and guidance notes from the following link: www.fca.org.uk.

General enquiries about this website should be sent to enquiries@truestone.co.uk. This email address should not be used for any enquiries relating to investments.