This website and the Investor Portal are operated by Parkwalk Advisors Ltd (“Parkwalk“, “we“, or us“). In this Privacy Notice, we explain how we handle personal information about our investors, potential investors and where relevant, their independent financial advisers (“IFAs”) (together, “Investors“) and any users of this website (“Website Users“). It also provides details of the rights that you have under data protection law.

Parkwalk Advisors Ltd is the data controller in respect of Investors’ and Website Users’ personal information

This Privacy Notice should be read together with our Cookie Policy and Terms of Use.

If you have any questions in relation to this Privacy Notice or Parkwalk’s handling of your information please get in touch using the contact details outlined at the end of this Notice.

1. What personal information do we collect?

Investors

As an investment fund, Parkwalk will collect various categories of personal information about Investors so that we can operate our business and fulfil the obligations contained in the investment agreement with you. We collect some of this personal information directly from you. We may collect other personal information indirectly from an investor’s, or potential investor’s, IFA. We also collect personal information about the IFA themselves.

This personal information is stored primarily on the Investor Portal where Investors can access information about their investments and which is designed to cater for the regulatory and statutory requirements for recording and processing EIS investments and to assist Parkwalk in responding to your enquiries and applications. We also hold a limited amount of personal data about Investors on Parkwalk’s internal client record management system (the “CRM“). 

The types of information we may collect on the Investor Portal and the CRM are listed below. Depending on whether you are an investor, potential investor, or an IFA, we may collect all or just some of the following categories of personal information:

  • Contact details. Includes your name, address, email address and telephone number.
  • Citizenship information. Including your place of birth, nationality and national tax identification numbers.
  • Identification information. Including your date of birth and copies of your passport and driving licence.
  • Bank Account details.
  • Investments information. Including fees relating to each transaction and holding and valuations for each investment you have with us.
  • IFA information. The identity of the IFA that referred you to us, where applicable.
  • Details of personal circumstances. Including those relating to your health, life events, resilience and capability.
  • Other. Any other personal information that you voluntarily provide to Parkwalk.

Website Users

We collect personal information you provide to us directly as some sections of the website invite you to email us with enquiries, request fund information or enquire about opportunities for entrepreneurs. We also collect information related to your use of our website. For example, we use cookies and similar technologies to collect information automatically about your use of the website, see the paragraph on cookies below, for more information. The categories of information we may collect, therefore, include the following:

  • Contact details. Including your name, address, email address and telephone number.
  • Website use information. Including details of the web pages you have visited on our website and the content that you access.

We use cookies to collect website use information. This data is then aggregated before it is used. This aggregated information enables us to make certain parts of the website easier to use and to improve the functionality of the website. Please see our Cookie Policy for more information. When you enter the website, we may also collect information, where available, about your computer such as your IP address, operating system and browser type for system administration purposes.

2. What will we do with your personal information?

Investors

Depending on whether you are an investor, potential investor, or an IFA, we may process your personal information for all or just some of the following purposes:

  • to perform our obligations under your investment agreement, including:
    • to manage and administer your investments; 
    • to contact you about matters related to your investment with us;
    • to administer your account on the Investor Portal;
    • to transfer money owed to you that we receive during the life of your investment or upon your exit from the investment.
  • where you have registered an interest, to contact you about matters related to a potential investment with us;
  • depending on your permissions, for marketing purposes, including:
    • to send IFAs a monthly sales email;
    • to send investors a quarterly newsletter.
  • to comply with our legal and regulatory obligations (including our obligations as an FCA-regulated company), including:
    • to comply with the requirements of Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS);
    • to comply with anti-money laundering obligations;
    • to comply with obligations in relation to dealing with politically exposed persons; and
    • to ensure we are treating our investors fairly.

Parkwalk will only process Investors’ personal information where we have a legal basis for doing so, and this will be determined by the purpose for which your personal information is processed. In the majority of cases this will be because it is necessary for us to do so in connection with your investment agreement with us.

In certain situations, however, Parkwalk may handle your personal information because it is necessary for our legitimate interests as an investment fund. Our legitimate interests include, contacting you about your interest in investing with us provided that such processing does not result in a negative impact on your privacy and other rights.

Parkwalk may also have a legal basis for processing certain categories of Investor personal information because it is necessary for us to do so in order to comply with a legal obligation we are subject to. This includes the detection and prevention of money laundering or obligations in relation to dealing with politically exposed persons.

Where we collect characteristics about your health, we seek your explicit consent to process this personal information.

Website Users

Depending on how you use our website, your interactions with us and the reasons for which you provide your information, your personal information will be used for the following purposes:

  • to ensure that the website is presented to you in an effective manner;
  • to understand how visitors interact with our website;
  • to provide you with information that you have requested from us (for example, if you contact us using the contact details provided on our website).

Typically, we process your personal information on one of the following legal bases:

  • because you have provided your consent, for example to certain types of cookies; and
  • because it is in our legitimate interests to do so (and these are not overridden by the impact on your privacy or other rights). We have a legitimate interest in responding to enquiries you submit through the website.

3. Who is your personal information shared with?

Investors

We share Investors personal information with: Parkwalk employees that have a need to know this information and the custodian bank that we appoint from time to time and the depository. The custodian may share your personal information with any nominee used by the custodian from time to time. We also share Investors’ personal information with our third party service providers, including those providing the CRM and Investor Portal.

Your personal information may be shared with other third parties where one of the following circumstances applies: 

  • we are under a legal, regulatory or professional obligation to disclose your personal information, or in order to enforce, apply or comply with the terms of our investment agreement with you, or to protect the rights, property, or safety of our business, or others. For example, to HM Revenue & Customs in documents required for EIS relief applications or for the purposes of FATCA compliance and the company that we use to conduct anti-money laundering checks.
  • occasionally, and only where we have 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.
  • to seek legal advice from our external lawyers or in connection with a dispute with a third party.
  • our business, or substantially all our business’s assets are merged or acquired by a third party, in which case your personal information may form part of the transferred or merged assets;

Website Users

We generally do not share personal information collected via the website with third parties. However, personal information may be shared with third parties where one of the following circumstances applies:

  • you have consented to us doing so.
  • we are under a legal, regulatory or professional obligation to disclose your personal information, or in order to enforce or apply our Terms of Use, or to protect the rights, property, or safety of our business, or others.
  • our business, or substantially all our business’s assets are merged or acquired by a third party, in which case your personal information may form part of the transferred or merged assets.
  • we are using a third party service provider (for example, to host the website).

4. How long will we retain your personal information?

Investors

We will keep your personal information for no longer than is necessary for the purpose for which it was collected. The retention period for personal information will vary according to the type of record. 

We will retain our records in relation to Investors as follows:

  • Contact Details. While you remain invested in any fund managed by us or hold any beneficial interest in any investee company through any Parkwalk fund and for seven years afterwards at which point we will review the personal data we hold about you and determine if it is necessary to retain the information for longer.
  • Citizenship information. While you remain invested in any fund managed by Parkwalk or hold any beneficial interest in any investee company through any Parkwalk fund and for seven years afterwards at which point we will review the personal data we hold about you and determine if it is necessary to retain the information for longer.
  • Identification information. While you remain invested in any fund managed by Parkwalk or hold any beneficial interest in any investee company through any Parkwalk fund and for seven years afterwards at which point we will review the personal data we hold about you and determine if it is necessary to retain the information for longer.
  • Bank account details. While you remain invested in any fund managed by Parkwalk or hold 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.
  • Investments information. While you remain invested in any fund managed by Parkwalk or hold any beneficial interest in any investee company through any Parkwalk fund and for seven years afterwards at which point we will review the personal data we hold about you and determine if it is necessary to retain the information for longer.
  • IFA information. While you remain invested in any fund managed by Parkwalk or hold any beneficial interest in any investee company through any Parkwalk fund and for seven years afterwards at which point we will review the personal data we hold about you and determine if it is necessary to retain the information for longer.
  • Details of personal circumstances. While you remain invested in any fund managed by Parkwalk or hold any beneficial interest in any investee company through any Parkwalk fund and for seven years afterwards at which point we will review the personal data we hold about you and determine if it is necessary to retain the information for longer.
  • Other. While you remain invested in any fund managed by Parkwalk or hold any beneficial interest in any investee company through any Parkwalk fund and for a short period thereafter at which point we will review the personal data we hold about you and determine if it is necessary to retain the information for longer.

Where we determine that we no longer have a need to keep your information, we will delete or anonymise it. Please note that where you unsubscribe or opt out from a marketing communication, we need to keep a record of your email address to ensure we do not send you marketing emails in the future.

Website Users

We will keep your personal information for as long as we need it for the purposes set out in Section 4, above. This period will vary depending on the nature of your interactions with us. Where we no longer have a need to keep your information, we will delete or anonymise it.

5. Where do we store your personal information?

We store your personal information within the UK.

6. Exercising your rights

You have certain rights in relation to your personal information, including the right to object to, restrict and/or withdraw your consent to the processing of your personal information, the right to access or erase your personal information, and the ability to receive a machine readable copy of your personal information.

You also have the right to ensure that we correct or delete any inaccurate or out of date personal information which we have about you. If you believe that any personal information which we have about you is inaccurate or out of date and you would like us to correct or delete it, or you wish to exercise any other of your rights, please contact us at [email protected] or by writing to us at the details listed in section 7 below.

Any request to exercise one of these rights will be assessed by us on a case-by-case basis. There may be circumstances in which we are not legally required to comply with your request because of relevant legal exemptions provided for in applicable data protection legislation.

You may also have the right to contact the relevant data protection authority (the Information Commissioner’s Office) if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have any such concerns, we politely request that you contact us at the email address above in the first instance so that we can investigate, and hopefully resolve, your concerns.

7. Questions and more information

If you have any questions, need further information about our privacy practices, or would like to let us know that your details require updating, please contact us at [email protected] or write to us: 3 Pancras Square, Kings Cross London N1C 4AG.

8. Updates to this Notice

This Privacy Notice may be amended by us at any time. Please check this page periodically to inform yourself of any changes. It was last updated in February 2023.