C5 Capital Privacy Policy

SECTION 1. About the Company

C5 Capital is a venture capital company that exclusively invests in the secure data ecosystem including cybersecurity, cloud infrastructure, data analytics and space. Data security goes to the heart of what we do, and we are committed to protecting your personal information in accordance with applicable laws, to include the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).

This Privacy Policy (the “Policy”) is provided by the following C5 companies:

C5 Capital Limited, a company registered in England and Wales with company with company number 7015428 whose registered office is at 4th Floor, Saville Row House, 7 Vigo Street, London, W1S 3HF (C5 UK); and

C5 Accelerate LLC and C5 Capital USA LLC whose addresses are both at: 1701 Pennsylvania Avenue, N.W, Washington D.C. 20006 (collectively C5 US),

(we refer to C5 US and C5 UK collectively in this policy as “C5” or “we”).

How to contact us

If you have questions about this Policy, please contact us at:

The Chief Financial Officer, C5 Capital Limited, 4th Floor, Saville Row House, 7 Vigo Street, London, W1S 3HF, UK.

You can also email us at enquiries@c5capital.com.

SECTION 2. Who this Policy applies to

From time to time, as part of running our business, we collect and use certain personal information about individuals who we interact with, in relation to the provision of our products and services (we refer to such individuals in this Policy as “contacts” or “individuals” or “you”).

This Policy applies to individuals whose personal information we collect, regardless of your geographical location. You may be located in the UK, Europe, America, or indeed worldwide. This policy is drafted in accordance with UK data protection law (in particular the UK GDPR and Data Protection Act 2018) – a standard which both C5 UK and C5 US adhere to.

In particular:

Part A of this Policy is generic and is provided for individuals, wherever they are located in the world and regardless of whether C5 UK or C5 US handles their personal information.
Part B of this Policy only applies to individuals whose personal information is collected and processed by C5 UK only, where such data is protected by UK data protection law.

For residents of the United States: We do not sell consumer personal data, and this website is not intended for children under the age of 16. We treat customers equally on service and price, regardless of whether they have exercised their rights under the law. If you are based in the United States and wish to exercise any of your rights under applicable State or Federal law, please contact us. Please note that C5 UK and C5 US are not within the scope of the California Consumer Privacy Act (CCPA). However, because there is some overlap between the requirements of the CCPA and UK data protection law, we hope our Californian visitors will find this Policy useful and informative.

This Policy explains our privacy practices and covers the following:

Part A – General information (applicable to individuals worldwide whose personal information both C5 UK and C5 US collect and use)

1.  Details of personal information that we collect 
     (including types of individuals whose data we collect) 
2. Where we get your personal information from  
3. What we do with the personal information that we gather 
4. Who we share your personal information with 
5. Other relevant information, including how to contact us 
6. How long we retain your personal information for

Part B – UK data protection law specific information (only applicable to individuals whose personal information is protected under UK data protection law – in particular, data which is collected by and under the control of C5 UK only)

7. Any transfers involving your personal information
8.  How we legally justify using your personal information 
9.  Your legal rights in relation to your personal information

Part A – General information (applicable to individuals worldwide whose personal information both C5 UK and C5 US collect and use)

1. DETAILS OF PERSONAL INFORMATION THAT WE COLLECT

We collect and use personal information relating to the following types of individuals:

(a) Contacts at our existing investors – we collect contact details about certain individuals who work at our existing investors (their name, email address, place of work, job title and telephone number).

(b) Contacts at our existing suppliers and partners – we also collect contact details about certain individuals who work at our existing suppliers and partner organisations (their name, email address, place of work, job title and telephone number).

(c) Contacts at our investee companies – we collect details of the management team and other key members of staff at our various investee companies (their name, email address, place of work, job title and phone number) as well as information on investee companies’ future hiring plans.

(d) Contacts at potential investors, investee companies and other prospects – we collect contact details of individuals who work at potential investors and investees, to whom we wish to market our products and services (their name, email address, place of work, job title and phone number).

(e) Users of our website – we collect the IP addresses of individuals who use our website and possibly also your basic contact details (name, email address, phone number) if you provide details to us via a website chat tool etc. Such website users could be existing investors, suppliers, partners of ours or potential investors.

As we outline above, the personal information that we collect and use about individuals is not sensitive personal information (such as details of someone’s health, ethnicity, race or religion), and it is mostly business contact details.

2. WHERE WE GET YOUR PERSONAL INFORMATION FROM:

We collect personal information from a number of sources, including:

(a) From you directly – we receive personal information directly from some individuals, for instance, if you contact us via our website, register for marketing information, by email, telephone us or give us your business card at a networking event.

(b) From your employer – if you work at an investor, supplier or partner of ours, your employer may pass your contact details to us, for instance if you are appointed to act as a point of contact for a particular project.

(c) From social networking and internet sites – we obtain personal information about contacts (particularly for contacts at potential investors and investees) using platforms such as LinkedIn or via your business’ website.

(d) Trade shows and other events – we gather business contact details of certain individuals who work for investors, suppliers, partners and for potential investors, from events such as trade shows, webinars and other industry events that we organise or are otherwise involved in.

(e) From third party marketing companies – we use third party marketing services suppliers to provide us with lists of contact details of leads for potential investors.

3. WHAT WE DO WITH THE PERSONAL INFORMATION WE GATHER

Our investors and investees – we need to communicate effectively and efficiently with our investors, in order to facilitate our provision of high quality and timely communications and to manage relationships. Therefore, our main use of your personal information will be in the context of performing our contractual obligations to your business, for example provision of our services, responding to queries and managing the financial aspects of the relationship. However, we also use personal information of individuals who work at our investor organisations for the following purposes:

(a) from time to time, we may also use your personal information to contact you for market research purposes and to send you surveys. We may contact you by email, phone, fax or by mail. We use such information to try and constantly improve our products and services and where possible, tailor these to suit the particular needs and preferences of you and your business; and

(b) to provide our existing investors with certain marketing information from time to time, for instance, trends reports and details of new products, special offers or other information which we think you and your business may find interesting.

Our suppliers and partners – we need to use certain personal information in order to provide and receive services, for communicating effectively and efficiently with various parties in the supply chain. Where your organisation provides services to us, we will need to know which individuals at your organisation we have to communicate with and keep details of their personal information. Therefore, our main use of your personal information will be in relation to projects which we are involved in and services which we provide and receive, to enable us to liaise effectively with our suppliers, partners and other third parties.

Prospective investors and investees – as a business, we want to make organisations in the industry aware of the range of products and services which we can offer, including trends reports. We keep lists of contacts on our client relationship management (CRM) system and from time to time we may send marketing information to you by email, or we may also contact you by telephone.

Users of our website – users of our website (who may be contacts at existing investors, suppliers, partners or potential investors) may provide us with their contact details if they have a particular query. We will use this information to get in touch with you by email or telephone and seek to assist with your query. Please also see paragraph 5 below regarding how we collect the IP addresses of visitors to our website, in relation to cookies.

4. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

Internal sharing: C5 UK shares information it collects with C5 US, to include personal data. For individuals whose data is protected by UK data protection law, please see details on transfers to the US under paragraph 7 below, and sharing personal information with C5 US in paragraph 8 below.

External sharing: from time to time, C5 may share data with external third parties. These include:

Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide professional services.
Regulators and authorities including HM Revenue & Customs and the Financial Conduct Authority.
Third parties with whom we work in the course of providing our services and carrying out ancillary activities, such as banks and card and other payment service providers, market researchers, and fraud prevention agencies.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

5. OTHER RELEVANT INFORMATION, INCLUDING HOW TO CONTACT US

Security

We are committed to ensuring that your personal information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information we collect. However, please note that no transfer of personal information over the internet is ever completely secure. Consequently, we cannot guarantee the security of any personal information which you transfer to us, or which we transfer to you or a third party, over the internet.

How we use cookies (C5 website visitors only)

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual as they recognise your IP address. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to investor needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than your IP address and the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. Apart from any strictly necessary cookies (e.g. those which are essential to enable our website to function), we will only use cookies on our website if you have provided your consent to us doing so.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Policy. You should exercise caution and look at the privacy policy applicable to the website in question.

Ensuring that your personal information is accurate and up to date

If you believe that any personal information we are holding on you is incorrect or incomplete, please write to us or email us as soon as possible, at the below address. We will promptly correct any information found to be inaccurate.

Your right to object to receiving direct marketing communications from C5

You have the right to object to receiving direct marketing communications from us (which we will promptly comply with) and where any other use of your personal information is based on consent, you have the right to withdraw that consent at any time. To do so, simply email our DPO at enquiries@c5capital.com.

6. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION FOR

The length of time that we retain your personal information for varies, according to the type of individual whose personal information we have collected, and what this data is being used for:

Type of individual	Applicable retention period
Contacts at existing investors	For the duration of the contract between us and the investor plus 6 years.
Contacts at existing suppliers and partners	For the duration of the contract between us and the supplier / partner plus 6 years.
Contacts at potential investors	24 months (unless you object to receiving any more marketing information before then).
Users of our website	As above, depending on whether the website user is a contact of an existing investor, supplier or partner; or a contact at a potential investor.

7. ANY TRANSFERS INVOLVING YOUR PERSONAL INFORMATION

Under UK data protection law, when personal information is being transferred outside the UK, C5 UK as data controller, are under an obligation to ensure that such transfer is performed in a manner that ensures that your personal information is adequately protected.

C5 UK shares personal data which it collects with C5 US – in order to ensure that such a transfer is compliant with UK data protection law, C5 UK and C5 US have entered into the UK standard contractual clauses, which are a method recognized under the UK GDPR for ensuring the adequate protection of personal data transferred between the UK and US. C5 UK have also carried out due diligence on the security measures employed by C5 US, and are satisfied that your personal data will be suitably protected, and your rights upheld, in relation to any such transfers to the US.

Apart from transferring data to C5 US as described above, C5 UK do not transfer any other personal data outside of the UK.

8. HOW WE LEGALLY JUSTIFY USING YOUR PERSONAL INFORMATION

Every use that we make of your personal information must meet a legal ground in the list set out by UK data protection law. The grounds which we rely upon are as follows:

Marketing – in relation to marketing activity which we perform using your personal information, we rely on the following conditions:

(a) For marketing to corporate subscriber investors / potential investors – the vast majority of the marketing activity which we undertake is to investors/potential investors who are corporate bodies or companies. For marketing to people who work for such investors, we rely on the condition that such marketing is necessary for us to achieve our legitimate interests, where your rights and freedoms are not jeopardised so as to override this legitimate interest. Our legitimate interests are to inform organisations about the products and services which we can offer, enhancements to the same and informing organisations about forthcoming events and special offers.

(b) For marketing to investors / potential investors who are sole traders or partnerships – on very rare occasions we may also market to people who work for sole traders or partnerships. In such circumstances, we will only send you marketing communications where we have received your prior consent to our doing so. If you withdraw your consent to receive marketing information at any time we will cease sending you any more marketing information. For any marketing activity, you have the right to object to receiving further direct marketing information and if you do so, we will cease sending you any more marketing information. However, we will keep minimal personal information about you on a screening list, to ensure that we do not accidentally send you marketing information against your wishes in the future.

Day to day communications and managing existing relationships – the legal ground which is relevant to us processing your personal information for such purposes (for investors, suppliers, partners and website users) is that such processing is necessary for us to achieve our legitimate interests, and where your rights and freedoms are not jeopardised so as to override this legitimate interest. Our legitimate interests are ensuring that we can communicate effectively with the relevant personnel at such parties, in order for us to provide our products and services in a timely and professional manner, and to honour our contractual and other obligations to the parties who we work with.

Sharing personal information with C5 US – the legal ground which is relevant to C5 UK sharing your personal information with C5 US is that such sharing is necessary for us to achieve our legitimate interests, and where your rights and freedoms are not jeopardised so as to override this legitimate interest. The particular legitimate interests in this case is that C5 US controls our marketing activities and therefore requires access to contact details of individuals who work at organisations to whom C5 US wish to market its products and services.

9. YOUR LEGAL RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

If you have any questions in relation to our use of your personal information, you should first contact us using the contact details above. Under certain conditions, you may have the right to require us to:

provide you with further details on the use we make of your personal information and/or transfer a copy of your personal information to another data controller;
provide you with an electronic copy of personal information that we hold;
update any inaccuracies in the personal information we hold and/or restrict processing of your personal information;
delete any personal information that we no longer have a lawful ground to use;
object to our use of your personal information which is based on the ‘legitimate interests’ legal ground. If our use of your personal information based only on this legal ground is causing you undue harm, then we must cease using your personal information for that purpose.

You also have the right to object to receiving direct marketing communications from us (which we will promptly comply with) and where any other use of your personal information is based on consent, to withdraw that consent at any time.

Your exercise of most of these rights is subject to certain conditions and exemptions, for example to safeguard the public interest in investigating crimes, or protecting legal privilege. If you exercise any of these rights we will check your entitlement and respond in most cases within a month.

If you are not satisfied with our use of your personal information or our response to you, please contact us and we will attempt to resolve the issue as soon as possible. . You also have the right to complain to the UK Information Commissioner’s Office (ICO) at any time.