Last updated: 22 March 2023
1. Introduction and who this Privacy Policy covers
This Privacy Policy sets out how FundAdminChain collects, stores, uses, discloses or otherwise processes information about you in the course of our business including providing services to our clients, through our website and when using our Platform, as well as sales and marketing activities.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
We own and operate a digital platform (Platform) which can be accessed via a web-based application and which facilitates digital services supporting fund management and administration. Within the Platform, there are distinct environments hosted by FAC (Portals), through which the Portal owner (the Landlord) will invite various parties to access dedicated areas within the relevant Portal.
We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our Platform and each Portal; where we provide you with services related to the Platform (the Services); or when you have other interactions with us.
It does not cover any use of personal data by the Landlord and any related party in respect of the offering of or investment in any funds product or administration services which will be covered by separate terms and privacy policies.
This privacy policy covers how we collect personal data from the following categories of individuals:
- Business Contact: Any individual employee of the Landlord or any fund manager, fund administrator or associate invited to be a user on the Portal.
- Investor: Any individual investor or employee of an investment entity we engage with in relation to our Platform.
- User: Any person accessing our Platform, whether as a Business Contact or an Investor.
2. Who we are
FundAdminChain Limited, a company incorporated in England with company number 11845957, having a place of business at 6th Floor, 140 London Wall, London, EC2Y 5DN, is the controller and responsible for your personal data (collectively referred to as “FundAdminChain”, “we”, “us” or “our”).
We are a majority-owned affiliate of Apex Group Limited and part of the international Apex Group, which operates in multiple jurisdictions.
3. 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 data about you. 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 website you visit.
4. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified.
- Basic Personal Data: Name, address, date of birth, gender, marital status, Tax Identification Number, National Insurance number.
- Identity Data: Passport, driving licence, utility bill, birth certificate, marriage certificate.
- Contact Data: Address, email address and telephone numbers.
- Technical Data: IP address, login data, browser type and version, time zone setting, operating system, platform and related device data.
- Profile Data: Username and password, purchases or orders, interests, preferences, feedback and survey responses.
- Usage Data: Information about how you use our Platform, products and services.
- Service Recipient: Contact information, employer and job title.
- Marketing and Communications Data: Marketing preferences and communication preferences.
Special Category Data
We may process limited special category data, including biometric data for identification purposes.
Criminal Background Data
We may collect information relating to criminal convictions where legally permitted and required for identity verification, financial crime prevention and platform access validation.
Keeping data up to date
It is important that the personal data we hold about you is accurate and current.
If you fail to provide personal data
Where we need to collect personal data by law or under a contract and you fail to provide it, we may not be able to provide services to you.
5. How is your personal data collected?
We collect personal data directly from you, from third parties, and automatically when you interact with our Platform.
6. How we use your personal data
We will only use personal data where the law permits us to do so.
- Where you have provided explicit consent.
- Where necessary to perform a contract.
- Where necessary for legitimate interests.
- Where necessary to comply with a legal obligation.
Purposes for which we use your personal data
| Purpose | Data Type | Lawful Basis |
|---|---|---|
| Providing access to the Platform and Services | Basic, Identity, Contact, Profile | Contract performance, legal obligation, legitimate interests, consent where required |
| Fraud prevention and identity verification | Basic, Identity, Contact | Legal obligation, legitimate interests, consent where required |
| Business administration and platform protection | Basic, Contact, Technical | Legitimate interests and contract performance |
| Analytics and service improvement | Technical, Usage | Legitimate interests |
| Anonymous statistical reporting | Technical, Usage | Legitimate interests |
| Managing relationships with Investors and Business Contacts | Identity, Contact | Legitimate interests |
| Service updates, surveys and support requests | Identity, Contact, Account, Usage, Marketing Data | Contract, legal obligation, legitimate interests |
7. Marketing
We may use information you provide to inform you about services that may be of interest to you. You can opt out of marketing communications at any time by contacting us.
8. Disclosures of your personal data
| Third Party | Details |
|---|---|
| Platform Users | Sharing within relevant Portals under strict access controls. |
| Service Providers | IT providers, cloud providers, marketing providers, identity verification providers. |
| Professional Advisers | Lawyers, auditors, insurers and bankers. |
| Authorities | FCA, ICO, HMRC, law enforcement and regulatory bodies. |
| Corporate Partners | Business transfers, mergers, restructuring and acquisitions. |
9. International transfers and Data Security
Where personal data is transferred outside the UK or EEA, we implement appropriate safeguards, including adequacy decisions and approved international data transfer agreements.
10. Data Security
We implement appropriate security measures to prevent accidental loss, unauthorised access, disclosure, alteration or misuse of personal data.
11. Data retention
We generally retain personal data for six years following the end of the relationship unless longer retention is required by legal, regulatory or litigation requirements.
12. Your legal rights
| Right | Description |
|---|---|
| Right of Access | Request details and copies of personal data held. |
| Right to Rectification | Correct inaccurate or incomplete personal data. |
| Right to Erasure | Request deletion of personal data where applicable. |
| Right to Restrict Processing | Limit the use of personal data in certain situations. |
| Right to Object | Object to processing based on legitimate interests or direct marketing. |
| Right to Data Portability | Request transfer of personal data where applicable. |
No fee usually required
You will not normally have to pay a fee to exercise your rights unless requests are unfounded, repetitive or excessive.
Time limit to respond
We aim to respond within one month of receiving a valid request.
13. Complaints
You may lodge a complaint with the Information Commissioner’s Office (ICO) or another applicable supervisory authority.
14. How to contact us
If you have any concerns, questions, or wish to exercise your rights:
Email: privacy@fundadminchain.com
Post:
FundAdminChain Limited
6th Floor, 140 London Wall
London, EC2Y 5DN
15. Updates
We keep this Privacy Policy under regular review and may update it from time to time. Where changes are material, we will notify you and update the revision date shown above.