Privacy Policy

This privacy policy sets out how LP Grid Limited (we, us, our) uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1. Important information and who we are

Privacy policy

This privacy policy gives you information about how LP Grid Limited collects and uses your personal data through your use of this Website, including any data you may provide when you use our Website or purchase a licence to use our open source intelligence platform to help you find investors (Platform) and associated services (Services). This privacy policy also explains how we use investors' personal information within our Platform.

In this privacy policy:

• "LP Grid", "we", "us" or "our" means LP Grid Limited, a company registered in England and Wales (company number 17124805);

• "you", "your" or "customer" means any individual who visits our Website or uses our Platform and Services;

• "investor" means any individual who has committed to a General Partner and/or Limited Partner structure;

• "personal data" means any information about an individual from which that person can be identified; and

• references to our "Website" means the website at https://lpgrid.com/app, other websites which are operated by us and our branded mobile applications made available via third-party platforms.

LP Grid is the controller and responsible for the personal data collected in connection with your use of the Website, Platform and Services. We are also the controller and responsible for any personal data displayed on our Platform, including personal data relating to investors.

Our Directors are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (Paragraph 9), please contact the us using the information set out in the contact details section (Paragraph 10).

This Website is not intended for children and we do not knowingly collect data relating to children.

2. The types of personal data we collect about you

We may collect, use, store and transfer different kinds of personal data about you when you use our Website, Platform and Services and which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, title, gender and details of the organisation you work for.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this Website.

• Profile Data includes your username, purchases or orders made by you.

• Usage Data includes information about how you interact with and use our Website, Platform and Services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also process the following personal data about investors within our underlying Platform:

• Investors' name, relevant company profile information, role numbers, join/leave dates, liability amounts, historical changes and other information that is publicly available, including information available via Companies House and other registers such as Luxembourg Business Registers (RCS), German Handelsregister, Danish CVR/Virk, GLEIF, France AMF/GECO, Irish CRO Open Services, INSEE Sirene, Australian ABN Lookup and NewsAPI.ai / Event Registry.

• LinkedIn, including a link to investor's LinkedIn profile (where available).
  
  

1. We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific Website feature in order to analyse general trends in how users are interacting with our Website to help improve the Website and our service offering.
   
   

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • visit and use our Website;

  • create an account to use our Platform;

  • subscribe to our Platform and Services;

  • request marketing to be sent to you; and/or

  • give us feedback or contact us.

• Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and also obtain personal data from public sources including Companies House.

• Technical Data is collected from the following parties:

  • analytics providers such as Auth0 and jsDelivr;

  • other providers included in our cookies policy.

• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.

• Identity and Contact Data is collected about investors from publicly available sources including Companies House and the Electoral Register based inside the UK and other registers such as Luxembourg Business Registers (RCS), German Handelsregister, Danish CVR/Virk, GLEIF, France AMF/GECO, Irish CRO Open Services, INSEE Sirene, Australian ABN Lookup and NewsAPI.ai / Event Registry.
  
  

3. How we use your personal data
   
   

1. Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where our contract is with you directly (rather than the organisation you work with or for), we may rely on the performance of a contract lawful basis, including for the performance of the contract we are about to enter into or have entered into with you for providing you with access to our Platform or Services.

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
  
  

  2. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

3. Direct marketing

During the onboarding process on our Website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email used in the details provided in our contract.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

4. Opting out of marketing

You can ask to stop sending you marketing communications at any time by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a licence to use the Platform and Services or for issues with availability of the Platform or Services.

5. Cookies

For more information about the cookies we use and how to change your cookie preferences, please see www.lpgrid.com/legal/cookie-policy

6. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• third parties such as our business partners, service providers and sub-contractors for the performance of any contract we enter into with you or to help us improve our Website, Platform or Services (for example, our IT providers, marketing service providers, security service providers, insurance providers and document storage providers); and

• our professional advisors (including accountants, lawyers and auditors) that assist us in carrying out our business activities.

Where we have collected investor data from publicly available sources, we will make this available on our Platform, which is accessible by customers who have subscribed to use our Platform and Services.

We will also share your personal information with other third parties, for example:

• in the event that we sell or buy any business or assets, we will disclose your personal information to the prospective seller or buyer of such business or assets;

• if we or substantially all of our assets are acquired by a third party, personal information held by us will be one of the transferred assets; and

• if we are under a duty to disclose or share your personal information in order to comply with any legal obligation.

For a full list of the third parties with whom your particular personal information may be shared, please contact us using the details at paragraph 10 below.

7. International transfers

If we need to share your personal data with any recipient outside the UK, e.g. with any of those third parties listed above, we will ensure we do so in compliance with data protection laws. This will include:

1. for international data transfers subject to UK law, we primarily use European Commission's standard contractual clauses and the UK's Addendum; and

2. where appropriate, we carry out an assessment of the level of protection in light of the circumstances relating to the transfer, including the relevant risks presented by the transfer.

3. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

8. Data retention

   1. How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers for seven (7) years after they cease being customers for tax purposes. We will keep basic information about investors for the duration of the Platform being available and thereafter for a period of seven (7) years.

In some circumstances you can ask us to delete your data: see Paragraph 9 below for further information.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in Paragraph 4 for details of how to object to receiving direct marketing communications).

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

  • If you want us to establish the data's accuracy;

  • Where our use of the data is unlawful but you do not want us to erase it;

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details (Paragraph 10)).

10. What we may need from you

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 to speed up our response.

11. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: contact@lpgrid.com

• Postal address: FAO: LP Grid Limited, Pens Close, Stamfordham, Newcastle Upon Tyne, United Kingdom, NE18 0NE
  
  

13. Complaints

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can find our complaints form here.

14. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

15. 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 policy of every Website you visit.