Diversity VC’s Privacy Policy
Welcome to Diversity VC’s Privacy Policy.
What does this Privacy Policy Cover?
Diversity.VC respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our website (“Site”), our industry reports (“Reports”) and our marketing communications (“Communications”) and tell you about your privacy rights and how the law protects you.
With that in mind, this Privacy Policy is designed to describe:
- Who we are and how to contact us.
- Your rights relating to your Personal Data.
- Marketing communications preferences.
- What Personal Data we collect.
- How we use your Personal Data and why.
- What happens when you do not provide necessary Personal Data?
- Personal Data from Third Party Sources.
- Who we share your Personal Data with.
- How we keep your Personal Data secure.
- How long we store your Personal Data.
- Our policy on children.
- Third party links.
This Privacy Policy aims to give you information on how Diversity.VC collects and processes your Personal Data through our Site, 3rd party data sources and any data you may provide directly to Diversity.VC by email.
The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.
We will post any modifications or changes to this Privacy Policy on this page.
Who we are and how to contact us.
Who we are.
Diversity.VC Limited is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either Diversity.VC, “we”, “us” or “our” in this Privacy Policy).
Our address is: 84a Victoria Road, Horley, Surrey, England, RH6 7AB
How to contact us.
You can contact us by emailing: [email protected]
Your rights relating to your Personal Data.
By law you have the right to:
- Request access to your Personal Data. 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 information we hold about you corrected.
- Request erasure of your Personal Data. 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 exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. 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. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown here “Who We Are and How to Contact Us”.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may 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 to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Complaints
If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: [email protected]
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Marketing communications preferences.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing messages sent to you or by contacting us at any time over email at [email protected]
When you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result via direct email to Diversity.VC
What Personal Data we may collect.
All the Personal Data we may collect, both from you and from third parties about you, is outlined in the table below.
| Category of Personal Data collected | What this means |
|---|---|
| Identity Data | First name, surname, maiden name, last name, username or similar identifier, marital status, nationality, ethnicity, citizenship, sexual orientation, title, date of birth, gender, employment, education history |
| Contact Data | Home address, work address, email address, telephone numbers, Linkedin profile link and any other contact details you supply |
| Marketing and Communications Data | Your preferences in receiving marketing from us and our third parties, your communication preferences and records of all communications including electronic communications with our staff and meeting notes |
| Technical Data | 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 and other technology on the devices you use to access this website or use our services. |
Aggregated Data
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
Special Categories of Personal Data
We do collect some “Special Categories of Personal Data” about you (such as your race and ethnic origin). For information regarding our legal basis for collecting and holding this data is set out below (see How we use your Personal Data and why).
How we use your Personal Data and why.
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
| Purpose | Category(ies) of Personal Data involved | Why do we do this | Our legal basis for this use of data |
|---|---|---|---|
| Troubleshooting | Technical Data | To track issues that might be occurring on our systems. | Legitimate Interests.It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services. |
| Marketing | Identity DataContact Data Marketing and Communications DataTechnical Data | To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. | Legitimate Interests.We have a legitimate interest in providing you with updates on our Sites and related offers where you have purchased or shown interest in similar services from us. |
| Statistical analysis | Identity Data (some of this will fall into special category data)Contact Data | To create industry wide reports casting light on the diversity of gender, ethnicity and other identity features across the venture capital industry and how this changes over time in order to raise awareness of the issue and push for change. | Legitimate Interests. We have a legitimate interest in increasing awareness of diversity issues within the venture capital industry. |
| Statistical analysis (special category data) | Race and ethnic origin | To create industry wide reports casting light on the diversity of gender, ethnicity and other identity features across the venture capital industry and how this changes over time in order to raise awareness of the issue and push for change. | We will obtain your explicit consent. |
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).
In this case, we may have to stop you using our Site have with us but we will notify you if this is the case at the time.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
| Third party data source | Publicly available? | Category(ies) or other types of personal data received. |
|---|---|---|
| Yes | Identity DataContact Data | |
| Employer websites | Yes | Identity DataContact Data |
| Industry databases (for example Crunchbase, Beauhurst, Pitchbook etc) | Yes | Identity DataContact Data |
Who we share your Personal Data with.
The table below describes who we share your Personal Data with, what we share and why we share it.
We do not transfer your Personal Data to any parties located outside the European Economic Area. This includes our staff, representatives and advisors.
| Recipients | Category(ies) of Personal Data we share. | Why we share it | Location(s) |
|---|---|---|---|
| Service Providers (for example Airtable and Mailchimp) | Identity DataContact Data Technical Data | Our service providers provide us with IT and system administration services. | Within Europe |
| Contractor volunteers | Identity DataContact Data | Our contractor volunteers are used to analyse the data and product the Reports | Within Europe |
How we keep your Personal Data secure.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data.
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above “How we use your Personal Data and why.”, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
| Category of Personal Data | Retention period |
|---|---|
| Marketing and Communications Data | For so long as you have actively opted in to receive our marketing and communications messages. If you wish to stop such marketing messages please email [email protected]. |
| Contact Data | For as long as necessary depending on the purpose for which it was collected, unless .you have actively opted out of remaining in our dataset. |
| Identity Data | For as long as necessary depending on the purpose for which it was collected, unless .you have actively opted out of remaining in our dataset. |
| Technical Data | For as long as necessary depending on the purpose for which it was collected, unless .you have actively opted out of remaining in our dataset. |
Our policy on children.
This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.
Third party links.
This Site 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 your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.