Privacy notice

1. About this notice

This notice (the “Privacy Notice”) provides information about how Transition Global Management Limited and its affiliates (“we”, “us”, “our”) gather and use personal information. We are committed to respecting the confidentiality of the personal information you supply to us and all data will be processed in accordance with applicable data privacy laws.

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Notice.

2. About us

We are Transition Global Management Limited (company number 13659299), registered at 55 New Oxford Street, London, WC1A 1BS. For the purposes of data privacy legislation, we will be a ‘controller’.

3. Contacting us

Should you have any questions or concerns about this Privacy Notice or how we process your personal data, please contact privacy@transition.vc.

4. Your rights

You have certain rights in relation to your personal data.

4.1 – Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see above).
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.

Please contact us using the details at section 3 if you want to exercise any of these rights. In most cases these rights are not absolute and are subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.

We will respond to your request within one month of receipt of your request. In some cases we may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.

4.2 – Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

4.3 – Fees

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.

4.4 – What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

4.5 – Right to complain

If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, please contact us on the contact details contained in section 3.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/ or 0303 123 1113.

5. Information we collect

We collect your personal information from a variety of sources, as set out in this Privacy Notice. Where necessary we collect information directly from you and through your use of our website.

5.1 – Information you provide us

This section details the information we collect about you in the course of your use of our website and otherwise in your interaction and correspondence with us and our representatives. We will collect:

Identity Data

Basic personal details such as your name and the name of your company.

Contact Data

Email and postal addresses and telephone numbers.

Technical Data

Technical information relating to your use of our website, such as your IP addresses, browser type, time zone setting and location.

Usage Data

Information about how you use our website, such as how often you access it, how long you spend on it and how you navigate around it.

6. How we use the information we collect

6.1 – General uses of information

The information which we collect and what we use it for will depend on the nature of our business relationship with you. We will only use your personal data when we have a lawful basis to do so. Most commonly, we will use your personal data in the following circumstances:

• where it is necessary for our legitimate interests in operating the website and communicating with individuals who express an interest in Transition Global and your interests and fundamental rights do not override those interests; and/or
• where we need to comply with a legal obligation.

6.2 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for any other purpose than those already notified to you, we will notify you and we will explain the legal basis which allows us to do so.

7. Where your information is processed

Your personal information may be processed by staff operating outside the UK who work for us or by our service providers (for example, those who supply support services to us), and the laws of some of these destination countries may not offer the same standard of protection for personal information as countries within the UK.

We will, however, put in place appropriate security procedures in order to protect your personal information. Where your information is transferred to any country outside the UK, we ensure that this is done using specific legally approved safeguards. You can request further details and a copy of these safeguards by contacting us (see section 3).

8. Keeping your information

We will keep your information only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal information are available in our retention policy which you can request by contacting us.

When determining the relevant retention periods, we will take into account factors including:

• legal obligations under applicable law to retain data for a certain period of time;
• statute of limitations under applicable law(s);
• (potential) disputes; and
• guidelines issued by relevant supervisory authorities.

9. Security

We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

In addition, those employees, agents, contractors and other third parties who process your personal data will only do so on our instructions and they will be subject to a duty of confidentiality.

Although we will do our best to protect your personal data any transmission is at your own risk as we cannot guarantee the security of any data transmitted via the internet. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.

10. Links to other websites

Links on our website may take you to third party sites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy notices on those linked websites. We are not responsible for any linked websites.

11. Changes to this Privacy Notice

We reserve the right, at our discretion, to change, modify, add to, or remove portions from, our Privacy Notice. We will of course notify you of any changes where we are required to do so.