Forbury Investment Network Ltd (“We”) are committed to protecting and respecting your privacy.  Please note that the Commonwealth Environmental Investment Platform (“CEIP”) is a trading name of Forbury Investment Network Ltd.

This policy (together with our website terms of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This Privacy Notice is non-contractual, regularly reviewed and may be amended by us from time to time. 

THE TYPE OF DATA WE HOLD, PURPOSE OF PROCESSING, LEGAL BASIS, DATA SHARING AND RETENTION PERIODS

We have provided this information in a layered format below to ensure it remains clear and concise.  Please click on the sub-heading below that best describes you and this information will be displayed.

The type of data we hold

We may process the following personal data:

  • Your name and contact details
  • In some instances, we may require documentation to verify identity including passport or driving licence details for individuals or details of shareholders and directors from Companies House for organisations; 
  • In some instances, we may also need to carry out credit checks or other financial checks with (and obtain personal data from) the HMRC or similar financial organisations;
  • Details contained within any correspondence you send us

You are obliged to provide this information to enable us to perform our contract or to take steps to enter into a contract with you and to enable us to comply with statutory obligations, such as verifying identity and source of funds for anti-money laundering purposes.   If you do not provide this information we may not be able to provide any services to you.

The purposes of processing

To enable us to:

  • Perform our contractual obligations or take steps to enter into a contract (e.g. to contact you with investment or other business opportunities);
  • Preparatory steps to deal with your enquiry to potentially engage you as an investor or a business seeking investment or trade opportunities;
  • Verify identity and source of funds where legally required to do so (for example, in accordance with anti-money laundering legislation);
  • Retain a record for the defence of legal claims or insurance purposes;
  • We also process this to send you details of events we are holding if we feel these are of interest to you.  You have the right to opt out of marketing communications at any time (see ‘Marketing Recipients’ below)

Legal basis for processing

  • To perform the contract that we have entered into with you or take steps to enter into a contract as above
  • It is also necessary for our legitimate interests (to provide the service efficiently, to maintain accurate records for the defence of legal claims, to grow our network and business);
  • To comply with our legal and regulatory requirements;
  • Where you have given us your consent to do so we also rely on consent  

Sharing your data

Your data will be shared internally with Directors, employees, consultants and secondees of Forbury Investment Network only to the extent necessary to carry out their roles.  Your data may also be shared with the IT and Marketing teams in Clarkslegal LLP (a connected company) as necessary.

We will also share your personal information with third parties where required by law (for example to comply with anti-money laundering legislation) and where it is necessary to administer our contract with you.   We may also need to share personal data with third parties such as investors or businesses where applicable (the recipient of this information may, where necessary, be bound by confidentiality restrictions).

The type of data we hold

We assist businesses in looking for investment.  As such we may hold personal data (such as names, job titles and contact details) of that businesses’ directors, key personnel, contractors and advisors where this is relevant to the investment and business transaction. 
Businesses are not obliged to give this information.  However, if we do not receive this information, this may mean we are unable to effectively provide our services. 

The purposes of processing

We process this data to enable us to perform our contracts with businesses seeking to secure investment and to retain a record of matters for the defence of legal claims and/or insurance purposes.

Legal basis for processing

We process this information on the basis that it is necessary for our legitimate interests, namely to provide our services efficiently and to maintain accurate records for the defence of legal claims.  Where individuals have provided this information to us voluntarily, we also rely on consent to process this data.

Sharing your data

Your data will be shared internally with Directors, employees, consultants and secondees of Forbury Investment Network only to the extent necessary to carry out their roles.  Your data may also be shared with the IT team in Clarkslegal LLP (a connected company) as necessary.

We will also share your personal information with third parties where required by law (for example to comply with anti-money laundering legislation).

The type of data we hold

We may process the following personal data:

Information that you provide by filling in forms on our site www.forburyinvest.com or www.theceip.com (our sites). This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our site.

  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details of transactions you carry out through our site and of the fulfilment of your orders.
  • Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

When you access our sites cookies will also be created.

Cookies are pieces of data created when you visit a site, and contain a unique, anonymous number. They are stored in the cookie directory of your hard drive, and do not expire at the end of your session. These help us to estimate our audience size, speed up searches, recognise when you return to our sites and help is to make improvements to our content.

Cookies do not contain any personal information about you and cannot be used to identify an individual user. If you choose not to accept the cookie, this will not affect your access to the majority of facilities available on our sites.

Although your browser may be set up to allow the creation of cookies, you can specify that you be prompted before a site puts a cookie on your hard disk, so that you can decide whether to allow or disallow the cookie. Alternatively, you can set your computer not to accept any cookie.

Log files are also created when persons visit our sites. They allow us to record visitors` use of our sites and include your IP address. We put together log file information from all our visitors, which we use to make improvements to the content and layout of our sites.

For information you are asked to provide (as part of signing up to a service), you are obliged to provide this to enable us to perform the contract with you and to ensure our IT systems remain secure and effective.  A failure to provide this may mean we are unable to provide you with the services you require.  You are not obliged to provide other information save where this is collected automatically on viewing our website such as location data.

The purposes of processing

  • To ensure that content from our site is presented in the most effective manner for you and for your computer.
  • To enable us to ensure security of our systems and make improvements where necessary, including for user experience of the website;
  • To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To carry out our obligations arising from any contracts entered into between you and us.
  • To allow you to participate in interactive features of our service, when you choose to do so.
  • To notify you about changes to our service.
  • To make business decisions about the provision of services and our website

Legal basis for processing

We process this data as it is necessary for our legitimate interests, namely to keep records of user experiences, provide the information you have requested, improve our services, ensure our services remain accurate and up to date, study how our sites are used and popular content, for marketing strategies/communications and to maintain and grow our business.

We also process data as required by law, including, to comply with legal obligations such as security obligations in data protection legislation.

We do not rely solely on consent to process your data, however, where you have signed up for services we may also process your data on the basis of your consent.

Sharing your data

Your data will be shared internally with Directors, employees, consultants and secondees of Forbury Investment Network only to the extent necessary to carry out their roles.  Your data may also be shared with the IT and Marketing teams in Clarkslegal LLP (a connected company) as necessary.

Our website contains links to third-party websites.  Clicking on those links may allow third parties to collect your personal data.  We do not have control over such websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

The type of data we hold

We have a network of representatives based outside of the UK who assist us with identifying and facilitating investment and business opportunities internationally.  We maintain a list of the names and contact details for these representatives. 

Representatives are not obliged to provide this data.  However, a failure to do so will mean that we are unable to work with the representative for the above purpose.

The purposes of processing

We process this data to enable us to liaise with you and facilitate business and investment opportunities outside of the UK.

Legal basis for processing

We process this information on the basis of consent and as it is necessary for our legitimate interests, namely to provide our services efficiently to our client. 

Sharing your data

This data will be shared internally with Directors, employees, consultants and secondees of Forbury Investment Network only to the extent necessary to carry out their roles.  Data may also be shared with the Marketing and IT teams in Clarkslegal LLP (a connected company) as necessary.  We will also share your personal information with third parties where required by law.

The type of data we hold

Other parties to a matter may include advisers to the transaction for other parties, not our client.

We may be informed by you or by a third party (including but not limited to our client) of your name and contact details if you are involved on a particular matter we are instructed on.

In these instances, the likely data we will hold on you will be your name, the organisation you work for and your contact details.  It may also include information that you have given us or the client and your opinion on matters.

Generally speaking, you are not obliged by us to provide your personal data.  Failure to provide us with your personal data may impact the effective management of the matter in question.

The purposes of processing

The personal data is processed to ensure we are able to contact relevant parties on a matter and obtain all necessary information.

Legal basis for processing

We process this on the basis of our legitimate interests (to be able to provide services to our client) and our clients’ legitimate interests (to be able to effectively carry out the matter).

We may also process this data on the basis of consent (if you have provided these details to us yourself).

Sharing your data

This data will be shared internally with Directors, employees, consultants and secondees of Forbury Investment Network only to the extent necessary to carry out their roles.  Data may also be shared with the IT team in Clarkslegal LLP (a connected company) as necessary.  We will also share your personal information with third parties where required by law.

Type of data we hold

We may process your personal data including your name, employer, job title and email address for marketing purposes.

We will have received this data from you directly when attending networking events and signing up for services.  You are not obliged to provide this data for marketing purposes.

You may opt out of marketing communications by emailing marketing@forburyinvest.com.  Alternatively, each of our marketing communications contain an ‘opt out’ hyperlink so that you can opt out easily at any time.

Purposes for processing

We process this personal data to send you details of events that we think may be of interest to you or that you have expressly requested.

If you have opted out of marketing updates, we may retain your personal data as a record of those who have opted out to ensure that we do not contact you further for these purposes.

Legal basis for processing

We process this data on the basis of consent and legitimate interests, namely to maintain and grow our business.

Sharing of data

This data will be shared internally with Directors, employees, consultants and secondees of Forbury Investment Network only to the extent necessary to carry out their roles.  Data may also be shared with the IT and Marketing teams at Clarkslegal LLP (a connected company) as necessary.  

Where you sign up to attend events ordinarily a badge stating your name, job title and organisation (and/or a sign in sheet stating the same) will be on display at the event which others attending the same event may have sight of.      

Type of data we hold

We may process your personal data including your name and contact details where you have contacted us (e.g. for information) or where we have obtained your information from a public source or third party and wish to request information.  If we receive any communication from you then we will also process any data contained within your request. 

An example may be where we contact you to see if you would be interested in hosting a joint event or where you market to us.

This covers a variety of requests and, in most cases, we do not envisage you being obliged to provide your personal data.  If you are requesting information from us, not providing this data may mean we are unable to respond.

Purposes for processing

The purpose of us processing your personal data is to allow us to respond to your request or to seek information.

Legal basis for processing

We process this data on the basis of our legitimate interests.  These are likely to include growing our business and network.

Sharing of data

Your data will be shared internally with those parties relevant to the information request.  If your request requires this, it may be shared with other external parties. 

Please note that if we intend to further process your personal data for a purpose other than that for which it was collected, we shall provide you with information on this other purpose and all other information as set out in this notice. 

We will not transfer your personal data to any country outside the European Economic Area without your consent or where this is necessary to perform arrangements that we have agreed with you, as some individuals and businesses may well be seeking investment or business globally.  Information about the transfer and any relevant safeguards will be provided to you in advance of any such transfer and/or you giving consent.

In terms of retention periods, we will not keep your data for longer than is necessary. When deciding how long to hold your data we have regard to the purposes for which this is processed, legal and regulatory requirements (including any contractually agreed periods) and statutory limitation periods (under which it is prudent for us to retain records for longer periods).

CONSENT

Where we rely on consent to process your personal data, you have a right to withdraw your consent at any time.  This will not affect the lawfulness of processing based on consent before its withdrawal.

You can withdraw your consent to our processing at any time by contacting data@forburyinvest.com.  Please specify the type of processing that you are withdrawing your consent to in your email. 

YOUR RIGHTS

You have a number of rights in relation to the personal information that we process about you.  You:

Have the right to be informed about your data (as set out in this Privacy Notice);

Can request access to your personal data;

Can request that your personal data be rectified if it is inaccurate or incomplete;

Can request that the processing of your personal data be restricted or erased in certain circumstances, for example, where the data is no longer necessary to meet its purpose;

Can object to processing in certain circumstances, for example where this is based on legitimate interests or involves direct marketing;

Can request to receive personal data that you have provided in a structured, commonly used and machine-readable format and can have this transmitted without hindrance where the data is processed on the basis of consent or performance of a contract;

Can lodge a complaint with the Information Commissioner’s Office.

AUTOMATED DECISION MAKING (“ADM”)

ADM occurs when decisions are made about you by a computer or some other information analysing machine. Examples of this include the machine scanning of CVs, computer processed aptitude or personality tests and website profiling.  We do not use ADM.

CONTACT DETAILS FOR DATA CONTROLLER AND ENQUIRIES

For the purpose of the General Data Protection Regulation and UK data protection legislation, the data controller is Forbury Investment Network Ltd (Registered in England and Wales with Company No. 07307015) of 5th Floor, Thames Tower, Station Road, Reading, RG1 1LX, Tel: 0118 958 5321, Fax: 0118 907 4070.

If you have any enquiries re data protection or wish to exercise any of your rights please do contact data@forburyinvest.com .