WIF AX, LLC
Our website address is: https://wifaxvc.com/
Privacy Notice
WIF AX, LLC (“WIF AX”) is committed to protecting your
privacy. At all times we aim to respect any personal information you share with
us or that we collect about you and keep it safe. This Privacy Notice
(“Notice”) sets out our data processing practices when you interact with us
including online through our website – www.wifaxvc.com
or www.wifax.vc – and your rights and options regarding the ways in which your
personal information is used.
Please note that we have additional privacy notices that
apply if you choose to enter into a formal relationship with us e.g. as an
Investor. You may access the privacy notice for investors here.
This Notice contains important information about your
personal rights to privacy. Please read it carefully to understand how we use
your personal information.
The provision of your personal information to us is
voluntary. However, without providing us with your personal information, your
use of our services may be impaired. For example, you will be unable to contact
us via this website.
We collect personal information about you
What personal information do we process?
How and why will we use your personal information?
Communications for marketing/ fundraising
How long do we keep your personal information?
Lawful bases
Will we share your personal information?
Security/ storage of and access to your personal information
Exercising your Rights
Changes to this Notice
Links and third parties
How to contact us
1. We collect
personal information about you
1.1 When you give it to us directly
For example, personal information that you give us by
signing up for our email newsletter, contacting us through our Contact Us page
or if you apply for a job with us, or personal information that you provide in
any way to any of our staff.
1.2 When you visit our website
When you visit our website, we automatically collect the
following types of personal information:
(a) Technical information, including the internet protocol
(IP) address used to connect your device to the internet, browser type and
version, time zone setting, browser plug-in types and versions and operating
systems and platforms.
(b) Information about your visit to the websites, including
the uniform resource locator (URL) clickstream to, through and from the site
(including date and time), services you viewed or searched for, page response
times, download errors, length of visits to certain pages, referral sources,
page interaction information (such as scrolling and clicks) and methods used to
browse away from the page.
We also collect and use your personal information by using
cookies on our website – please see our Cookie Notice.
1.3 When we obtain it from publicly available sources
Your personal information may be available to us from
external publicly available sources. This may include information available on
Companies House, the Charity Commission and other charity registers, reputable
media articles, publications and company websites and professional networking
sites such as LinkedIn. Depending on your privacy settings for social media
services, we may access information from those accounts or services, including
from Facebook, Instagram and Twitter.
1.4 When we obtain it from third parties
For instance, we may obtain personal information about you
from Independent Financial Advisers or other professional advisers.
In general, we may combine your personal information from
these different sources for the purposes set out in this Notice.
2. What personal
information do we process?
We may collect, store and otherwise process the following
kinds of personal information:
(a) your name and contact details, including postal address,
telephone number, email address and, where applicable, social media identity;
(b) information about your professional status and
background in the context of understanding your potential interest in our
services;
(c) information about your experience and education if you
apply for a job with us or you apply for a management position in one of our
portfolio companies;
(d) information about your computer/mobile device and your
visits to and use of this website, including, for example, your IP address and
geographical location;
(e) information about our services which you use/ which we
consider may be of interest to you;
(f) information you provide through our management
questionnaire in the context of a potential commercial acquisition or
investment, including about your health or criminal convictions.
2.2 Do we process special categories of personal
information?
The General Data Protection Regulation (“GDPR”) recognizes
certain categories of personal information as sensitive and therefore requiring
more protection, for example information about your health, ethnicity and
political opinions. We do not intentionally collect special categories of data
through our website.
When we process special category data (on health) we will
only do so where you have voluntarily provided this information to us and you
have confirmed your explicit consent for our use, unless processing is
necessary for compliance with our legal and regulatory obligations.
When we process data on criminal convictions we do so
because it is necessary for compliance with our legal or regulatory
obligations.
3. How and why will
we use your personal information?
Your personal information, provided to us through our
website, will be used for the purposes specified in this Notice. In particular,
we may use your personal information:
(a) to provide further information about our work, services,
activities or products (where necessary, only where you have provided your
consent to receive such information)
(b) to answer your questions/requests and communicate with
you in general;
(c) to analyze and improve our work, services, activities,
products or information (including our website) and to hold a list of contacts
(such as IFAs) that we work with or would wish to work with;
(d) to report on the impact and effectiveness of our work;
(e) to run/administer our website, keep the website safe and
secure and ensure that content is presented in the most effective manner for
you and for your device;
(f) to register and administer your participation in events;
(g) to satisfy legal obligations which are binding on us,
for example in relation to regulatory, government and/or law enforcement bodies
with whom we may work (for example requirements relating to the payment of tax
or anti-money laundering);
(h) to review your application for a job to work for us and
to contact you about the position and any interview process;
(i) to review any applications for a management position
where we are leading the recruitment process for one of our portfolio
companies;
(j) to carry out appropriate due diligence on shareholders
and management team members in the context of a commercial acquisition or
investment;
(k) to carry out our business activity as an investment fund
manager;
(l) for the prevention of fraud or misuse of our services;
and/or
(m) for the establishment, defense and/or enforcement of
legal claims.
4. Communications for
marketing/ fundraising
We may use your contact details to provide you with
information about our work, events, services and/ or products which we consider
may be of interest to you (for example, about services you previously used). We
will only contact you where we have informed you that we will and, where the
law requires us to, we will obtain your prior consent.
Where you do not wish to be contacted by us about our
projects and/ or services in the future, please let us know by email via fund@wifaxvc.com.
You can opt out of receiving emails from WIF AX, LLC. at any time by contacting
us at fund@wifaxvc.com.
5. How long do we
keep your personal information
In general, unless still required in connection with the
purpose(s) for which it was collected and/or processed, we remove your personal
information from our records six years after the date it was collected.
However, if before that date (i) your personal information is no longer
required in connection with such purpose(s), (ii) we are no longer lawfully
entitled to process it or (iii) you validly exercise your right of erasure
(please see section 9 below), we will remove it from our records at the
relevant time.
If you request to receive no further contact from us, we
will keep some basic information about you on our suppression list in order to
comply with your request and avoid sending you unwanted materials in the
future.
6. Lawful bases
The GDPR requires us to rely on one or more lawful basis to
process your personal information. We consider the grounds listed below to be
relevant:
(a) Where you have provided your consent for us to use your
personal information in a certain way (for example, we will ask for your
consent to use your personal information to send you promotional or fundraising
material by email, and we may ask for your explicit consent to collect special
categories of your personal information).
(b) Where necessary so that we can comply with a legal
obligation to which we are subject (for example, when we are required to carry
out a Know Your Client check in the context of a commercial acquisition or
where we are obliged to share your personal information with regulatory bodies
which govern our work and services).
(c) Where necessary for the performance of a contract to
which you are a party or to take steps at your request prior to entering a
contract (for example, if you apply to work for/ volunteer with us).
(d) Where there is a “legitimate interest” in us doing so.
6.2 Legitimate interests
The GDPR allows us to collect and process your personal
information if it is reasonably necessary to achieve our or others’ legitimate
interests (as long as that processing is fair, balanced and does not unduly
impact your rights).
In broad terms, our “legitimate interests” means the
interests of running WIF AX, LLC. as a specialist fund manager enabling
investors to invest in our funds; for example providing information about our
services, responding to queries, administering events and advertising our
services.
When we process your personal information to achieve such
legitimate interests, we consider and balance any potential impact on you (both
positive and negative), and your rights under data protection laws. We will not
use your personal information for activities where our interests are overridden
by the impact on you, for example where use would be excessively intrusive
(unless, for instance, we are otherwise required or permitted to by law).
7. Will we share your
personal information?
We may share your personal information with our third party
suppliers when they are processing personal information on our behalf.
Please note that if you are a shareholder in a company in
the context of a commercial acquisition or investment that we are involved in,
we are required to carry out Know Your Client checks. For this purpose, we use
a third. As part of using a third-party, your personal information may be
disclosed to a credit reference agency which may keep a record of your personal
information and may disclose the personal information, and the fact that a
search was made, to other customers for purposes of assessing credit risk and
occasionally to prevent fraud, for money laundering and debtor tracing.
We may need to disclose your personal information where
legally required or upon request to regulatory and government bodies (such as
HMRC) as well as law enforcement agencies. We may also merge or partner with
other organizations and, in so doing, acquire or transfer personal information
but your personal information would continue to be used for the purposes set
out above.
We may also share your personal data with our US subsidiary,
other affiliates of ours or financial institutions active in the field of
impact investing so that they can contact you about opportunities we think you
may be interested in.
8. Security/storage
of and access to your personal information
8.1 WIF AX, LLC. is committed to keeping your personal
information safe and secure and we have appropriate and proportionate security
policies and organizational and technical measures in place to help protect
your information. For example, your personal information is only accessible by
appropriately trained staff and contractors, and stored on secure servers with
features enacted to prevent unauthorized access.
8.2 In general, the personal information that we collect
from you will be stored at a destination within the United States. However,
your personal information may sometimes be transferred or stored outside the United
States. If we transfer your personal data to our Foreign subsidiary, we will do
so in reliance on standard contractual clauses to ensure adequate protection.
8.3 Please note that some countries outside of the United
States may have a lower standard of protection for personal information,
including lower security requirements and fewer rights for individuals. Where
your personal information is transferred, stored and/or otherwise processed
outside the United States in a country that does not offer an equivalent
standard of protection to the UNITED STATES, we will take all reasonable steps
necessary to ensure that the recipient implements appropriate safeguards (such
as by entering into standard contractual clauses approved by the European Commission)
designed to protect your personal information and to ensure that your personal
information is treated securely and in accordance with this Notice.
8.4 Unfortunately, no transmission of your personal
information over the internet can be guaranteed to be 100% secure – however,
once we have received your personal information, we will use strict procedures
and security features to try and prevent unauthorized access.
9. Exercising your
Rights
Where we rely on your consent to use your personal information,
you have the right to withdraw that consent at any time. This includes the
right to ask us to stop using your personal information for marketing purposes
via the contact details in section 12 below or to unsubscribe from our
newsletter at any time. You also have the following rights:
(a) Right of access – you can write to us to ask for
confirmation of what personal information we hold about you and to request a
copy of that information. Provided we are satisfied that you are entitled to
see the personal information requested and we have successfully confirmed your
identity, we will provide you with your personal information subject to any
exemptions that apply.
(b) Right of erasure – at your request and where you are
entitled to, we will delete your personal information from our records as far
as we are required to do so. In many cases we will need to hold onto limited
personal information about you in order to ensure we don’t send you further
communications.
(c) Right of rectification – if you believe our records of
your personal information are inaccurate, you have the right to ask for those
records to be updated. You can also ask us to check the personal information we
hold about you if you are unsure whether it is accurate/ up to date.
(d) Right to restrict processing – you have the right to ask
for processing of your personal information to be restricted if there is
disagreement about its accuracy or legitimate usage.
(e) Right to object – you have the right to object to
processing where we are (i) processing your personal information on the basis
of the legitimate interests’ ground, (ii) using your personal information for
direct marketing or (iii) using your information for research or statistical
purposes.
(f) Right to data portability – to the extent required by
the GDPR, where we are processing your personal information by automated means
and either (i) because we have obtained your consent, or (ii) because such
processing is necessary for the performance of a contract to which you are a
party or to take steps at your request prior to entering into a contact, you
may ask us to provide your personal information to you – or another service
provider – in a machine-readable format.
(g) Rights related to automated decision-making – you have
the right not to be subject to a decision based solely on automated processing
of your personal information which produces legal effects or similarly
significant affects you, unless such a decision (i) is necessary to enter into/
perform a contract between you and us/ another organization; (ii) is authorized
by EU, UNITED STATES or USA (as long as that law offers you sufficient
protection); or (iii) is based on your explicit consent.
We may ask you for additional information to confirm your
identity and for security purposes, before disclosing personal information
requested to you.
Please note that some of these rights only apply in limited
circumstances. For more information, we suggest that you contact us using the
details in section 12 below.
You are further entitled to make a complaint about us or the
way we have processed your personal information to the data protection
supervisory authority in your home country. In the UNITED STATES this is the
Information Commissioner’s Office (www.ico.org.United States). For further
information on how to exercise this right, please contact us using the details
below. In the US, this is the Federal Trade Commission’s Office (www.ftc.org).
10. Changes to this
Notice
We may update this Notice from time to time so please check
back periodically. We will notify you of significant changes by contacting you
directly where we can reasonably do so and by placing a notice on our website.
This Notice was last updated on 3rd of April 2019.
11. Links and third
parties
We link our website directly to other sites. This Notice
does not cover external websites and we are not responsible for the privacy
practices or content of those sites. We encourage you to read the privacy
notices of any external websites you visit via links on our website.
12. How to contact us
Please let us know if you have any questions or concerns
about this Notice or about the way in which WIF AX, LLC. processes your
personal information by contacting us through any of the following means:
Email: fund@wifaxvc.com
Telephone: + 1 520-222-7591
Post:
236 S. Scott Avenue, Suite 140
Tucson,
Census Tract ID: 04019000100
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