During the course of its activities, Parkwalk Advisors Ltd (the “Company”) will collect and process personal data (which may be held on paper, electronically or otherwise) about its investors (the “Data Subjects”). The Company is the ‘controller’ of the personal data and recognises the need to treat any data in an appropriate and lawful manner in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (“GDPR”) and, in particular, to protect the security and privacy of data relating to the Data Subjects. The purpose of this fair processing notice is to set out, for the benefit of the Data Subjects, how the Company will handle the personal data collected.

Information the Company collects from Data Subjects and how it uses it

The Company has implemented a client record management system with Exact (the “CRM System”), which also has a Portal.

The CRM System is an internal central database of the Company’s investments and investors along with a record of the IFA that introduced each investor (if relevant) and relevant fees relating to each transaction and holding. The CRM System will assist the Company with the processing of applications and client enquiries and is designed to cater for the regulatory and statutory requirements for recording and processing EIS investments. Following the implementation of the CRM System, the personal data held by the Company will be stored on Exact’s servers located within the UK.

The Portal is an external portal system that will allow the Company’s clients (and their IFAs, if relevant) to access information about their investments, including fees relating to each transaction and holding, and valuations for each investment. The Portal will assist the Company with client enquiries and the accessibility of investment data for clients. Following the implementation of the Portal, the personal data held by the Company will be hosted on Microsoft servers located within the UK.

What data does the Company hold about its investors?What are the purposes of the processing?What is the legal basis for the processing?Does the Company share the data with anyone else within the UK or to a third country?
Personal contact details including name, personal email address, address and phone numberTo ensure the Company
has contact details for
investors on its records. 		Processing is necessary
for the purposes of the
legitimate interests
pursued by the Company.		The Company may
share personal
details with any
custodian that it
appoints from time
to time (the
“Custodian”).
In addition, certain
personal details may
be shared with HM
Revenue & Customs
in documents
required for EIS
relief applications.
Occasionally, and
only where the
Company has
received advance
written
confirmation from
investors that
personal
information can be
so shared,
information is
shared with an
investor’s IFA,
accountant and/or
lawyer upon
request.
Nationality and
citizenship
information
including national
tax identification
numbers 		To ensure the Company
has details for investors
on its records that must
be supplied to the
Custodian for the
purposes of MiFID II. 		Processing is necessary
for the purposes of the
legitimate interests
pursued by the Company.		The Company may
share personal
details with the
Custodian and with
an investor’s IFA (if
applicable).
Identification
information
including passport
and driving licence		To ensure the Company
is able to comply with its
anti-money laundering
obligations. 		Processing is necessary
for the purposes of the
legitimate interests
pursued by the Company.		The Company may
share personal
details with the
Custodian and with
an investor’s IFA (if
applicable).
Bank account details To enable the Company
to transfer any monies
received during the life of
an investment or upon an
exit. 		Processing is necessary
for the performance of
the investment
agreement between the
Company and the
investor.		The Company may
share personal
details with any
custodian that it
appoints from time
to time.
Any other
processing of
sensitive personal
data		To be confirmed in
advance of processing.		Explicit consent will be
required from investors.		To be confirmed to
investors in advance
of processing.

How long will the Company keep my personal data for?

The Company will not keep your personal data for longer than is necessary for the purpose. This means that the Company will use reasonable endeavours to ensure that your data will be destroyed or erased from the Company’s systems when it is no longer required. The retention period for personal data will vary according to the type of record.

The Company will retain its records in relation to investors as follows:

Personal Contact Details
While the investor remains invested in any fund managed by the Company or holds any beneficial interest in any investee company through any Parkwalk fund and for seven years afterwards.

Nationality and citizenship information including national tax identification numbers
While the investor remains invested in any fund managed by the Company or holds any beneficial interest in any investee company through any Parkwalk fund and for seven years afterwards.

Bank account details
While the investor remains invested in any fund managed by the Company or holds any beneficial interest in any investee company through any Parkwalk fund and for a short period thereafter to deal with any final payments which may be due.

What are Data Subjects’ rights in relation to their personal data?

It is important that the personal data which we hold about Data Subjects is accurate and up to date. Data Subjects should notify the Company of any changes. If at any point a Data Subject wishes to see what personal data the Company holds relating about them, he/she can request that this is disclosed to them. If a Data Subject believes that the information the Company holds relating to him/her is incorrect, he/she can in certain circumstances have it corrected or deleted: more details are provided below. If a Data Subject wish to raise a complaint on how the Company has handled his/her personal data, he/she should contact the Company’s Chief Compliance Officer.

If a Data Subject is not satisfied with the Company’s response to any complaint or belief that the Company is not processing his/her personal data in accordance with the law, a Data Subject can raise a complaint with the Information Commissioner’s Office.

A detailed summary of Data Subjects’ rights under the GDPR is available on request.

Questions

If you have any queries on this notice, please contact the Company’s Chief Compliance Officer.