Privacy and cookies policy

International Public Partnerships Limited ("INPP") is committed to protecting and respecting your privacy.

Data protection privacy notice

This policy (together with our Terms of Use and any other documents referred to on it) sets out how your personal data is collected, processed and disclosed in connection with INPP pursuant to the EU General Data Protection Regulation 2016/679 and the Data Protection (Bailiwick of Guernsey) Laws 2017, together with all other applicable legislation relating to privacy or data protection.

We take privacy and security of your information seriously and will only use such personal information as set out in this Privacy Notice.

INPP collects personal data from (prospective) clients and investors, business partners and intermediaries (each a "Relevant Person") for the purposes of entering into or performing services pursuant to a contract or a service agreement and/or to meet certain legal requirements.  We may collect or obtain such information because you give it to us (for example by filling in a form on our website or by corresponding with us by phone, e-mail or otherwise), or because other people give that information to us on your behalf. It includes personal data you provide when you register on the website for us to contact you, and when you report a problem with our website.  Your personal information may be provided to INPP, which will act as a data controller in respect of such personal data, or certain other service providers to INPP or other third parties INPP authorises to process data for lawful purposes (the "Processors"). The Processors may process your personal information or such data in respect of your directors, officers, employees or beneficial owners.  If you are a director, employee or consultant of an entity that provides us with personal data on individuals connected to you for any reason in relation to your involvement with us, this will affect those individuals and you should transmit this document to those individuals or otherwise advise them of its content.

Your personal data may also be collected and processed by us as a result of your professional or family connection with a Relevant Person. If any information which you provide to us relates to a third party (such as a spouse or other family member), by providing us with their personal data you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their personal data in accordance with the above provisions, or are otherwise permitted to give us this information.

As INPP is incorporated in Guernsey, INPP is obliged to comply with the provisions of the Guernsey data protection laws. 

This Privacy Notice should be read in conjunction with INPP's website terms and conditions.

Where we obtain your personal data

Your personal data comprises the following categories:

• information related to identification (including full name, signature, nationality, place and full date of birth, passport number, residential/registered address, and other contact details such as telephone number, e-mail address);
• information required for payroll, benefits and expenses purposes;
• bank account details;
• national insurance number, passport number and overseas identification card numbers;
• shareholdings in a company/ies;
• correspondence records, communication method preference and any data that is mirrored from the CREST system;
• professional qualifications, employment history, references and other details regarding your career history such as training records;
• tax status and tax identification numbers;
• where necessary, information regarding your investment activity or health;
• any other information about you that you disclose to us when registering your interest via our website;
• your IP address, your browser type and language and other information about your visit to our website;
• where this is provided to the registrar, copies of documents such as death certificates and grants of probate;
• in relation to the online portal (https://www.signalshares.com/) mother's maiden name, user names combined with passwords, cookies and online identifiers, security questions together with responses;
• in relation to due diligence and anti-money laundering checks, scanned or photocopied images of passports, driving licences or utility bills; and
• in relation to some of the above categories, details of the countries where tax resident.

We primarily collect your personal data from the following sources:

• from information which you or your authorised representative gives to us or our Processors, including but not limited to:
  • information set out in any application to act or by virtue of you acting as a Relevant Person;
  • such other forms and documents as we may request that are completed in relation to you acting as a Relevant Person;
  • any documentation that we may obtain as part of our regulatory requirements; and
  • any personal data provided by you by way of correspondence with us by phone, e-mail or otherwise;
• personal data we receive from you or any third party sources which may include:
  • entities in which you or someone connected to you has an interest;
  • your legal and/or financial advisors;
  • your relatives, trustees, personal representatives or shareholders;
  • other financial institutions who hold and process your personal data to satisfy their own regulatory requirements;
  • credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements; and
  • information collected via our website (including cookies and IP addresses) and emails.
• If you fail to provide us with your personal data, or you object to us processing such information, we may not be able to fulfil our agreement with you (such as to send you the information you requested). Non-personal data regarding the use of our website, such as the number of hits per page, is captured automatically. This information enables us to analyse the use of the website and customer traffic, and is used to develop and improve our website. Like most websites, we also use "cookies" to help us improve our website’s use and speed. Cookies are small text files that websites transfer to your electronic device, and mean that a website will remember you. There are more details in our Cookie Policy.
• We may also collect and process your personal data in the course of dealing with advisors, our service providers, regulators and official authorities.

Why we collect your personal data

Lawful grounds for processing:

We are entitled to hold and process your personal data on the following lawful grounds:

• the processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override those interests;
• the processing is necessary for us to comply with our contractual duties to you under the terms of any contract which we have with you;
• to comply with our legal and regulatory obligations;
• (on exceptional occasions) where we have obtained your consent; and
• (on rare occasions) where it is needed in the public interest.

Some of the grounds for processing described above will overlap and there may be several grounds which justify our use of your personal data.

• To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will generally do so because you have given us your explicit  consent to process that data.
• Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

Inaccurate or Amended Information

Please let us know if any of your personal data (including correspondence details) changes as soon as possible. Failure to provide accurate information or to update changed information may have a detrimental impact upon your directorship, employment or consultancy, or your investment, including the processing of any payment due to you.  Failure to provide information where the same is required for anti-money laundering, pursuant to automatic exchange of information agreements, or other legal requirements may mean that any payment due to you cannot be processed.

Purposes of processing

Pursuant to our lawful grounds for processing, we may process, store and use your personal data for the purposes set out below ("Purposes"):

• to reflect your investment, directorship, employment or consultancy relationship with INPP or with one of its service providers;
• to communicate with you as necessary in connection with your affairs and generally in connection with your investment, directorship, employment or consultancy relationship with INPP or with one of its service providers;
• to operate INPP's IT systems, software and business applications;
• to support our IT and business applications support teams, accounting, legal, reporting, internal audit and risk management, administrative, transfer, document storage, record keeping and other related functions, including but not limited to processing personal data in connection with INPP;
• for providing you with services, training and related purposes;
• to monitor and record telephone and electronic communications and transactions:
  • for quality, business analysis, training and related purposes in order to improve service delivery;
  • for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act); and
  • to enforce or defend INPP's rights, or through third parties to whom we may delegate such responsibilities or rights in order to comply with a legal or regulatory obligations imposed on us;
• detecting and preventing crime such as fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions on an ongoing basis ("Regulatory Assessments");
• facilitating the internal administration of each of the Processors and retaining your personal data as part of our Regulatory Assessments or future services entered into by you;
• liaising with or reporting to any regulatory authority (including tax authorities) with whom INPP is either required to cooperate or report to, or with whom it decides or deems appropriate to cooperate, in relation to an investment, and which has jurisdiction over INPP or its investments in a third country without the same or similar data protection laws as Guernsey or any EU member state (a "Third Country without Adequacy");
• disclosing your personal data to any bank, financial institution or other third party lender providing any form of facility, loan, finance or other form of credit or guarantee to INPP;
• to carry out our obligations to you in connection with your investment, directorship, employment or consultancy with INPP or with one of its service providers;
• to discharge our anti-money laundering obligations to verify the identity of our directors, employees or consultants (or those of our service providers) or for prevention of fraud or for legal, regulatory or tax reporting purposes or in response to legal requests or requests from regulatory authorities (i.e. where it is necessary for compliance with a legal obligation to which we are subject). In discharging our anti-money laundering obligations we may, in certain circumstances, collect, store and process special categories of data such as information regarding criminal convictions;
• facilitating the internal administration of INPP;
• communicating with our professional advisers for the purposes of obtaining professional advice;
• conducting business analytics and diagnostics;
• to manage and respond to any request you submit through our website;
• to provide you with the information, products and services that you request from us (for example to send you our press releases);
• to contact you by telephone or email about products, developments or services that may be relevant to you, unless you indicate at any time that you do not wish us to do so;
• for research purposes;
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• where you have explicitly agreed to us processing your information for a specific reason or purpose (for example when you register your details on our website); and
• conducting credit reference checks.

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where these are required or permitted by law. 

• To the extent that such personal data contains special category data such as, for example: data relating to racial or ethnic origin, political opinion, religious or philosophical belief, trade union membership or criminal data then the processing of such data shall solely be for the purpose of complying with any duty imposed on INPP by an enactment including, but not limited to, legislation and regulatory obligations relating to anti-money laundering and combatting the financing of terrorism and all other related legislation.
• INPP does not make decisions about you based on automated processing of your personal data and will procure none of the Processors make such decisions unless duly authorised under the DP Law.

Sharing personal data

INPP may share your personal data with group companies and third parties (including banks, financial institutions or other third party lenders, IT service providers, auditors and legal professionals) under the terms of any appropriate delegation or contractual arrangement. Those authorised third parties may, in turn, process your personal data abroad and may have to disclose it to foreign authorities to help them in their fight against crime and terrorism.

• Where you submit personal information on this website, that information is disclosed to and used by INPP, the Amber Infrastructure Group Limited group of companies (the "Amber Group") and third parties authorised to act on our behalf or to provide services to INPP or the Amber Group to provide the information that you have requested and for the other purposes outlined in the Privacy Policy. All our employees and data processors, who have access to and are associated with the processing of personal data, are obliged to respect the confidentiality of your personal data.
• We work with third parties to research certain usage and activities on our website on our behalf. No personal information about you is shared, however in the course of conducting this research these third parties may place a unique ‘cookie’ on your browser.
• Data processing (as described above) may be undertaken by any entity in the Bailiwick of Guernsey or the European Economic Area (the "EEA"), an entity which is located outside the Bailiwick of Guernsey or the EEA in a Third Country without Adequacy.

Any Third Country without Adequacy to which we transfer your data is legally not deemed in general to provide an adequate level of protection for your personal information. However, to ensure that your personal data receives an adequate level of protection we will put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU laws and the laws of the Bailiwick of Guernsey on data protection. Any entity having access to your personal data outside Guernsey or the EEA will be required by binding legal contract to protect and only process your data as though it were in the EEA or Guernsey and subject to the same level of protection as applies in those territories.

Retention of personal data

Your personal data will be retained for the longest of the following periods:

• for the Processors and/or any authorised third parties to carry out the Purposes for which the data was collected or as long as is set out in any relevant agreement you enter into with us;
• in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations;
• seven years following the point from when the business relationship with INPP has ceased; or
• any retention period that is required by data protection laws and any applicable laws or regulatory requirements.

We endeavour and require all third parties with access to your personal data, to store such data securely on computer systems and/or manually in accordance with accepted market standards.

Whilst we have taken every reasonable care to ensure the implementation of appropriate technical and security measures, we cannot guarantee the security of your personal data over the internet, via email or via our websites nor do we accept, to the fullest extent permitted by law, any liability for any errors in data transmission, machine, software or operating error or any other cause.

Your rights

You have, under certain circumstances, the following rights in respect of your personal data:

• the right to request access to or a copy of your personal data and port personal data;
• the right to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
• the right to rectify personal data;
• the right to restrict the use of personal data;
• the right to request that personal data is erased;
• the right to object to processing of personal data;
• the right to request not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data; and
• where INPP has relied on consent to process the personal data, the right to withdraw consent at any time by contacting us via the contact details below.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.

You also have the right to lodge a complaint with the Guernsey Data Protection Authority if you consider that the processing of your personal data carried out by INPP of any other service provider to INPP, has breached data protection laws. You may also have similar rights to complain to equivalent authorities in your jurisdiction of residence in the EU or the United Kingdom. You may also appeal to certain courts against (i) any failure of the Guernsey Data Protection Authority to give written notice of whether the complaint is either being investigated or not being investigated and where applicable, the progress and the outcome of the investigation and (ii) a determination of the Guernsey Data Protection Authority not to investigate the complaint or a determination that a controller or processor has not breached or is not likely to breach an operative provision in connection with the complaint.

In limited circumstances we may approach you for your written consent to allow us to process certain particularly sensitive data or to use data for another purpose. Where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us by using the contact details below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Cookies

We work with third parties to research certain usage and activities on the website on our behalf. In the course of conducting this research these third parties may place a unique ‘cookie’ on your browser. Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors to their sites. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.

The website uses Google Analytics (http://www.google.com/analytics/) for website analytics purposes – meaning that we use them to see how many visitors come to our website, the pages that generate interest and the links that visitors most often click on (amongst other things). In order to do this, Google Analytics uses cookies for website analytics purposes. You can opt-out of receiving Google Analytics cookies here.

• In addition, we use two specific types of cookie on this website:
• Session cookies, which are temporary cookies that remain in the cookie file of your computer until you close your browser (at which point they are deleted).
• Persistent or stored cookies that remain permanently on the cookie file of your computer.

Swipe table at bottom of page for more information.

How to manage cookies

The web browsers of most computers are initially set up to accept cookies. If you prefer, you can set your web browser to disable cookies or to inform you when a website is attempting to add a cookie. You can also delete cookies that have previously been added to your computer’s cookie file.

You can set your browser to disable persistent cookies and/or session cookies but if you disable session cookies, although you will be able to view this website’s unsecured pages, you may not be able to log onto any authenticated pages. Please visit http://www.allaboutcookies.org/manage-cookies/ to discover how to disable and delete cookies.

Web beacons and spotlight tags

This website may also contain electronic images, known as web beacons or spotlight tags. These enable us to count users who have visited certain pages on the website. Web beacons and spotlight tags are simply tools used to obtain generic information about the web pages visited.

Your queries

If you have any questions about our use of your personal data, our retention procedures or our security processes or privacy issues generally, please contact:

International Public Partnerships Limited
c/o Ocorian Administration (Guernsey) Limited
PO Box 286
Floor 2
Trafalgar Court
Les Banques
St Peter Port
Guernsey
GY1 4LY

Email: inppteam-GG@ocorian.com

Telephone: + 44 1481 742742

Changes to this policy

This Privacy Policy is dated 27 August 2020.  

We reserve the right to amend this Privacy Policy at any time without notice, in which case the date of the policy will be revised.