PRIVACY POLICY

NICL is committed to user privacy and recognises the importance of implementing effective and meaningful privacy protections in place when it collects, uses and discloses private information. This privacy policy “The Policy” explains what we do with your personal data, why we want to use it, how we protect it, and what rights you have to control our use of it.

It applies not just to visitors to our website, but also personal data that we process through other interactions with individuals in the course of running our business and delivering our services, such as people working for our clients, partners and suppliers. Our website and services are not intended for children and we do not knowingly collect data relating to children.

This privacy notice is for Northwood Infrastructure Capital Limited (“NICL”, “Northwood Infrastructure Capital” “we”, “us” or “our”).  We collect, use and are responsible for certain personal data. When we do so we are regulated under the General Data Protection Regulation (“GDPR”), which applies across the European Union including the United Kingdom and we are responsible as a “data controller” of that personal information for the purposes of the law.

If you want to contact us about any of the points on this notice, or just generally about how we protect your privacy, please email us at info@nicl.co.uk.

Our contact address is Devonshire House, 1 Mayfair Place, London W1J 8AJ.

What data do we process?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We use personal data from different categories of individual for several different purposes and each with its own lawful basis. This section describes these in detail. For different categories of people, we describe:

·      The types of personal data we process

·      Where the data comes from

·      Our purposes and “lawful basis” for processing

·      How long we hold it for

If you visit our website: we use Squarespace Analytics on our website to track visitor numbers and user activity. This records the IP address of people browsing our site (an IP address is also a piece of personal data) as well as browser type and information about technology on the devices used to access it. This helps us understand visitor behaviour (in order to make the website more useful and easier to use) and find out things such as the number of visitors. We do this on the basis that it is necessary for our legitimate interests in monitoring and improving our website. Information on website visitors is held for xxx after last user activity.

If you fill in a form on our website to contact us or download a document: we will store the data you enter (usually name, contact details, comment) for the purposes of responding to your enquiry and business development. We do this on the basis that it is necessary for our legitimate interests in promoting our business to interested parties. We store your data for as long as we need to interact with you for these purposes.  In all cases if you would like us to update or delete your information, please send us an email (see “How to contact us” below) or use the unsubscribe links on marketing emails.

If you work for one of our clients or partners or if you are an industry contact or working in a field relevant to our mission: we may hold your name, company, job title and contact details. We will have been provided with this data either by you or your employer or in some cases we may have sourced it from publicly available sources, such as LinkedIn and internet searches. We need this data in order to interact with you (or your employer) for the following purposes:

·      Operating and promoting our business;

·      Communicating with interested people regarding events, news and updates;

·      Gathering and disseminating information and sharing knowledge relevant to clean energy.

We do this on the basis that it is necessary for our legitimate interests in running and growing our business and in supporting the transition to a clean energy future. We will hold your details for as long as we need to interact with you for these purposes. In all cases if you would like us to update or delete your information, please send us an email (see “How to contact us” below).

If you are a supplier or work for a supplier: we may hold your name and contact details because we have a legitimate interest in doing business with your company. Our purpose for processing your personal data is to interact with you or your employer to procure and pay for goods and services. We will hold this information for as long as we need to interact with you for these purposes. In all cases if you would like us to update or delete your information, please send us an email (see “How to contact us” below).

As a business regulated by the Financial Conduct Authority we are legally obliged (under laws to prevent money-laundering and terrorist financing) to undertake “Know Your Client” (KYC) checks in relation to our clients.  We therefore ask for and retain copies of documents to help us establish the identity of directors and significant shareholders of clients.  These items of personal data could include copies of passports, utility bills, council tax bills, date of birth, registry of business interests and homes address.  We retain these for as long as legally required.

Who we share your data with

Data processors

We use a number of different service providers (acting as ‘data processors’) who provide services or cloud-based software to enable us to operate our business and the services we provide to our customers. Your personal data is transferred to (and stored by) these service providers (as our ‘data processors’), who generally fall under the following categories:

·      Website analytics

·      Website and data hosting

·      IT and system administration

·      Document storage

·      Email, contacts and calendar

·      CRM, accounting and billing

These ‘data processors’ only process data on our behalf and won’t use your personal data for their own purposes and we only permit them to use it in accordance with our instructions and the law.

For security reasons we do not name all our service providers in this privacy notice. The types of personal data we hold about you (and that may be transferred to our data processors) are set out above. Please contact us (see below) if you want further information on specific data processors or the types of personal data they process for us.

If you attend one of our events

Occasionally we may organise events to share knowledge and promote our services and the Clean Energy & Infrastructure sector.  The name and company of attendees at our events are usually shared with speakers, third party event hosts and may be shared with other attendees.  This is done to share knowledge and enable access to the venue.

Other circumstances in which we may need to share personal data with third parties

We may also share your personal data with the following third parties in certain circumstances:

·      Other partner companies we collaborate with on a case-by-case basis

·      Law enforcement or regulatory authorities (such as tax authorities) if required by applicable law

·      Professional advisors such as lawyers, bankers, accountants or auditors in order to provide legal, finance, accounting or auditing services.

We may disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of a bankruptcy.

International transfers of data and safeguards

We do not directly transfer any of your personal data outside the European Economic Area (EEA). However, some of our data processors may do so and this section explains the impact of these international transfers and how your information is protected.

Many of our data processors operate “cloud-based systems”, which means the information is held in information data centres in different locations.  Most of them reserve the right to hold copies of your personal information outside the EEA. Please note that the reason companies may choose to do this is to hold back-up copies, so they can guarantee recovery.

In each case we and our processors employ one or more of the following mechanisms that are designed to help safeguard your privacy rights:

Certain processors only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Providers storing data in the US, may be self-certified to the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

With certain service providers, we may use specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us (see below) if you want further information on the specific mechanisms used by our data processors when transferring your personal data out of the EEA.

Personal Data Rights

The personal data we hold about you is your data, so you have certain rights over the data under the GDPR. This section summarises your rights and how you can exercise them (generally free of charge).

You have the right to request a copy of all personal data we hold relating to you. You also have the right to require us to correct any mistakes in the personal data we hold relating to you.

Where we are processing your data based on your consent you can withdraw that consent and we must immediately stop processing your data. Please note that up to that point, we’re acting lawfully with your consent, withdrawal of consent cannot be backdated.

Where we process your data based on a “legitimate interest” you still have the right to object to our processing of that data if you feel it impacts on your fundamental rights and freedoms. From that point, we must stop processing your data until we have determined whether your rights override our interests.

You also have the right to object where we are processing your personal data for direct marketing purposes.  The easiest way to do this is to use the unsubscribe links at the bottom of all marketing emails.

In certain situations, you have the right to require us to erase personal data where there is no good reason for us continuing to process it. However, note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Finally, you have the right to request the transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format. Note that this right only applies to automated processing of information about you, if carried out based on your consent or where it is necessary to perform a contract with you.

For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of these rights, the easiest way is by dropping us an email (see “How to contact us” below). Please note:

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

We try to respond to all legitimate requests quickly, but in any event within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Automated decision-making using personal data

You have a right to object to any decisions being taken through the processing of your personal data by automated means if they produce legal effects concerning you or similarly significant effects on you. We can confirm that we do not undertake any automated decision-making, or profiling, based on the processing of personal data.

Rights to lodge complaint

At all times, you have the right to report a concern or lodge a complaint with the Information Commissioner’s Office. Please refer to the ICO at https://ico.org.uk/concerns/ or by calling them on 0303 123 1113. Of course, we hope that we can resolve your issue quickly and fairly ourselves.

Keeping personal information secure

We have appropriate measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this privacy notice

This privacy notice was last updated on 18 June 2019.  We may change this privacy notice from time to time by amending this page.

How to contact us

If you have any questions, concerns or just want some more information about our privacy management please drop us an e-mail on: info@nicl.co.uk.