Terms & conditions of use

To access all areas of this website please read the Terms & Conditions set out below confirm that you are allowed to view and then click ‘submit’

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By clicking the "Submit" button you certify that you are an individual resident in the UK and that you have read and understood the Terms of Use set out below.

The information contained in this website does not constitute an offer to sell, or the solicitation of an offer to acquire or subscribe for, any securities of Tellworth British Recovery & Growth Trust plc in any jurisdiction in which, or to any person to whom, such offer or solicitation is unlawful.

Terms of Use

The materials contained herein have been prepared for use solely by individuals who are resident in the United Kingdom for tax and investment purposes. The materials contained herein are not for release, publication, or distribution, directly or indirectly, in whole or in part, to US persons or into or within the United States (including its territories and possessions, any state of the United States and the District of Columbia), Australia, Canada, Japan, the Republic of South Africa or any other jurisdiction where to do so would constitute a violation of the relevant laws or regulations of such jurisdiction.

The information contained herein and on the pages that follow does not constitute an offer of securities for sale or a solicitation of an offer to purchase securities in the United States or in any jurisdiction in which such an offer or solicitation would be unlawful.  The securities referred to herein and on the pages that follow have not been and will not be registered under the US Securities Act of 1933, as amended (the “Securities Act”), or with any securities regulatory authority of any state or other jurisdiction of the United States, and may not be offered, sold, resold, pledged, delivered, distributed or otherwise transferred, directly or indirectly, into or within the United States, or to, or for the account or benefit of, US persons as defined in Regulation S under the Securities Act (“US Persons”).  No public offering of the securities referred to herein and on the pages that follow is being made in the United States.  Tellworth British Recovery & Growth Trust plc (the “Company”) has not been and will not be registered under the US Investment Company Act of 1940 (the “Investment Company Act”) and, as such, holders of the securities referred to herein and on the pages that follow will not be entitled to the benefits of the Investment Company Act.  No offer, sale, resale, pledge, delivery, distribution or transfer of the securities referred to herein and on the pages that follow may be made except under circumstances that will not result in the Company being required to register as an investment company under the Investment Company Act.  The offer and sale of the securities referred to herein and on the pages that follow have not been and will not be registered under the applicable securities laws of Australia, Canada, Japan, the Republic of South Africa or any other restricted jurisdiction.  There will be no public offering of the securities referred to herein and on the pages that follow in Australia, Canada, Japan, the Republic of South Africa or any other restricted jurisdiction.  The securities referred to herein and on the pages that follow may not be offered, sold, resold, pledged, delivered, distributed or otherwise transferred, directly or indirectly, into or within Australia, Canada, Japan or the Republic of South Africa or to any national, resident or citizen of Australia, Canada, Japan or the Republic of South Africa.  Potential users of this information are requested to inform themselves about and to observe any such restrictions.

The information on the pages that follow may contain forward‑looking statements.  Any statement other than a statement of historical fact is a forward‑looking statement.  Actual results may differ materially from those expressed or implied by any forward‑looking statement.  The Company does not undertake any obligation to update or revise any forward‑looking statements, whether as a result of new information, future events, or otherwise.  You should not place undue reliance on any forward‑looking statement, which speaks only as of the date of its issuance.

By using this website you confirm that you have read, understood, and accepted these conditions.  The Company may change these conditions.  The changes will be posted on the website and you should check regularly to see any changes or updates to these conditions.  Your access to this website is governed by the version of these conditions then in force.

  1. Terms and conditions
    1. The terms and conditions set out below apply to your use of the Company’s website. Please read them.
    2. The “Company” means Tellworth British Recovery & Growth Trust plc and any of its subsidiaries and related companies and references to “the Company’s website” are to the website available at tbrgt.co.uk and also include, but are not limited to, the text, documents, images, links, sounds, graphics, and video sequences displayed on the website (the “Materials”).
    3. By clicking “Submit” and entering tbrgt.co.uk you agree that you have read and accept these terms and conditions. If you do not agree, do not use www.tbrgt.co.uk. The information in the Company’s website is for the attention of residents of the United Kingdom only. It is your responsibility to be aware of and to observe all applicable laws and regulations in the United Kingdom.
    4. No information contained in these pages should be taken as a recommendation to buy, sell, or hold the shares of any entity. Nothing on the Company’s website or in the Materials constitutes or is intended to constitute financial or other advice and you should not act upon any information contained on the Company’s website or in the Materials without first consulting a financial or other professional adviser.
    5. The Company’s website is not intended to offer or to promote the offer or sale of the shares in the Company (the “Shares”) in the United States or to US Persons. Each acquirer of the Shares will be deemed to represent, amongst other things, that (i) it is not in the United States, (ii) it is not a US Person or acquiring the Shares for the account or benefit of a US Person, and (iii) it is acquiring the Shares in an “offshore transaction” meeting the requirements of Regulation S under the Securities Act.
    6. The Shares may not be acquired or held by, or transferred to, (i) an “employee benefit plan” as defined in Section 3(3) of the US Employee Retirement Income Security Act of 1974, as amended (“ERISA”), that is subject to Title I of ERISA; (ii) a “plan” as defined in Section 4975 of the US Internal Revenue Code of 1986, as amended (the “US Tax Code”), including an individual retirement account or other arrangement that is subject to Section 4975 of the US Tax Code; (iii) an entity which is deemed to hold the assets of any of the foregoing types of plans, accounts or arrangements that is subject to Title I of ERISA or Section 4975 of the US Tax Code; or (iv) a governmental, church, non-US or other employee benefit plan that is subject to any federal, state, local or non-US law that is substantially similar to the provisions of Title I of ERISA or Section 4975 of the US Tax Code, and whose purchase, holding, or disposition of the Shares would constitute or result in a non-exempt violation of any such substantially similar law.
    7. The Company delivers (or will deliver) to its shareholders annual financial reports, interim management statements and such other shareholder notices as the Company deems appropriate. Unless a shareholder indicates otherwise by written notice to the Company, the shareholder hereby consents to receive the Company’s financial statements, shareholder newsletters, and other shareholder notices and materials via email to the shareholder’s email address in the Company’s records or via the Company’s website at tbrgt.co.uk. Although the Company does not impose any additional charges for electronic delivery, the shareholder may, of course, incur costs associated with the shareholder’s electronic access, such as usage charges from the shareholder’s Internet access providers.  The shareholder may revoke its election to receive such documents via electronic delivery at any time by written notice to the Company requesting that the Company send such documents via facsimile or in hard copy via the postal service to the address notified to the Company by the shareholder from time to time.
  2. Privacy policy — The Company respects the privacy of individuals who visit the Company’s website and is careful to ensure that information disclosed to the Company in confidence is treated confidentially. Please see the Company’s full privacy policy.
  3. Limitation of liability
    1. Use of the Company’s website and the Materials are at your sole risk. The Company will not be liable to any person for any direct, indirect, special or consequential, losses, damages, or awards of any kind, howsoever caused, as a result of the use of or inability to use, or reliance on, the Company’s website or any of the Materials. To the maximum extent permitted by law, the Company excludes all warranties, conditions, terms, undertakings, and representations (excepting fraudulent misrepresentation) of any kind, express or implied, statutory or otherwise in connection with the Company’s website and the Materials. Nothing in these terms and conditions shall be taken to limit or exclude any liability which may not otherwise be limited or excluded under applicable law.
    2. Nothing in this website should be construed as investment, tax, legal, or other advice, nor is it to be relied upon in making an investment decision. Those accessing the website should consult their financial advisers regarding the suitability of any of the products referred to on this website. The value of investments and the income from them may go down as well as up and an investor may receive back less than the original investment. Past performance is not necessarily a guide to future performance.
  4. Disclaimer
    1. The Materials and the Company’s website are provided on an “as is” and “as available” basis and do not purport to be full or complete. The Company gives no warranties (express, implied, or statutory) as to satisfactory quality or fitness for purpose of the Materials, including, without limitation, as to the accuracy, validity, timeliness, merchantability, or completeness of any information or data contained therein (whether prepared by the Company or by any third party), or that any of the Materials or the Company’s website will be provided uninterrupted or free from errors or that any identified defect will be corrected.  The Company has the right to suspend or withdraw the provision of all or any of the Company’s website or the Materials without prior notice at any time.  You are entirely responsible for your use of the website and for the consequences of relying on any content.  Further, no warranty of any kind is given that the Company’s website and the Materials are free from any virus or other malicious, destructive, or corrupting code, program, or macro.  The Company does not warrant that the Company’s website or the server(s) that make(s) them available are free of any virus or other harmful elements.
    2. To the maximum extent permitted by law, the Company disclaims all liability to you arising out of your use of the website. In particular, the Company shall not be liable for any direct or indirect loss or damage to you, any loss of profits, loss of business, revenue, data, goodwill, or anticipated or consequential loss or damage.
    3. Reference in the Company’s website and/or the Materials to any hypertext link, product, process, or service does not imply the Company’s support for, or endorsement or recommendation of the provider thereof or the product, process, or service to which reference is made. The Company’s website may contain hypertext links to other websites, resources, or other third parties.  The Company is not responsible for the availability of, and accepts no liability in relation to, these external websites or their contents.  The Company is not a sponsor, partner, promoter, or publisher of any such website.
  5. Copyright and trademarks
    1. The Materials are the copyright of the Company and its third-party licensors and may not be copied, distributed, uploaded, posted, republished, decompiled, disassembled, reverse-engineered or transmitted in any way without the prior written consent of the Company. You may, however, download one copy of the Materials for your personal non-commercial use or non-commercial use within the organisation in which you work on condition that you do not delete or change any copyright, trademark, or other proprietary notice contained in the Materials or alter the way in which they are presented.  Modification or use other than as permitted above violates the Company’s intellectual property rights in the Materials.
    2. The trademarks, service marks, and logo used and displayed on the Company’s website are registered and unregistered trademarks of the Company and others. The intellectual property rights in the “Tellworth British Recovery & Growth Trust plc” name and logo are owned by the Company or are used by the Company under licence.  Nothing in these terms and conditions or on the Company’s website should be construed as granting any licence or right to use any trademark displayed on the Company’s website. The Company enforces infringements of its intellectual property rights to the fullest extent permitted by the law.
  6. Governing law — The agreement between you and the Company relating to your use and browsing of the Company’s website is governed by and shall be construed in accordance with the laws of England and Wales and you agree that the Courts of England shall have exclusive jurisdiction over any disputes arising in relation to such use and browsing. These terms and conditions may not be modified unless the Company agrees in writing.
  7. Use of cookies — This website will use a cookie to confirm that this disclaimer has been acknowledged. The cookie lasts only as long as your browser is open and cannot be used to obtain any private data about you.  You do not have to accept cookies from this site but if you do not you will be required to acknowledge the disclaimer on every page. Please refer to the Company’s cookies policy for further information on how cookies are used.
  8. The Materials that you are seeking to access are not directed at and may not be viewed by or distributed to persons who are resident outside the United Kingdom, including but not limited to:
  • who are in the United States or who are, or are acting for the account or benefit of, US Persons; or
  • who are in a jurisdiction where it is not lawful to access the Materials.

By clicking “Submit” above, you represent, warrant and agree that you (1) have read and understood the terms and conditions and other information set out above, (2) agree to be bound by its terms and acknowledge that the Company and its affiliates, subsidiaries, directors and advisers may rely on your agreement, (3) are permitted under applicable laws and regulations to receive the information contained in the pages that follow and, (4) agree that you will not transmit or otherwise send any information contained in this website to any person in the United States, to any US Person, or to publications with a general circulation in the United States.  If you cannot so certify and agree, you must not click the “Submit” button above and exit this website.

Tellworth British Recovery & Growth Trust PLC

Website Privacy Policy

Tellworth British Recovery & Growth Trust plc (“TBRGT“, “we“, “us” or “our“) is committed to protecting and respecting the confidentiality, integrity and security of personal data about individuals whose data we hold (“you“, “your“).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and how we comply with our responsibilities under applicable data protection laws, including the General Data Protection Regulation (Regulation (EU) 2016/679) and the Data Protection Act 2018 (“Data Protection Laws“). Please read this policy carefully.

Structure of this policy

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE PERSONAL DATA WE COLLECT AND HOW WE USE IT

(A) VISITORS TO OUR WEBSITE

(B) INVESTORS

(C) BUSINESS CONTACTS

(D) JOB APPLICANTS

  1. DISCLOSURES OF YOUR PERSONAL DATA
  2. DATA RETENTION
  3. INTERNATIONAL TRANSFERS
  4. HOW WE PROTECT YOUR DATA
  5. YOUR LEGAL RIGHTS
  6. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
  7. CONTACT US


1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website and the services we provide to you. It applies to (a) visitors to our website, (b) investors (actual or potential), (c) business contacts (including consultants, suppliers, advisers, business partners and associates), and (d) job applicants and prospective job applicants.

This website is not intended for children and we do not knowingly collect data relating to children.

Data Controller

For the purpose of the Data Protection Laws, the data controller of your personal information is Tellworth British Recovery & Growth Trust plc, a public listed company registered in England (registered number 12814859). You can contact us by post at Level 13 Broadgate Tower, 20 Primrose Street, London EC2A 2EW or by email at DPM.PFS.UK@PraxisIFM.com

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

2. THE PERSONAL DATA WE COLLECT AND HOW WE USE IT

(A) VISITORS TO OUR WEBSITE

The following section of this policy sets out how we may process personal data (as a controller) about visitors to our website.

Personal data we collect

We may collect, use, store and transfer different kinds of personal data about you which you provide to us though our website including:

  1. Identity data – includes your name, title, marital status, date of birth, gender and job title.
  2. Contact data – includes contact details such as your address, email address and telephone number(s).
  3. Technical data – includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  4. Usage data – includes information about how you use our website, products and services, information about your visit, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page).

We do not collect any sensitive personal data or special categories of personal data about you through our website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we collect your data

We use different methods to collect data from and about you including through:

  • Direct interactions, whereby you give us your personal data by filling in forms, leaving a business card or by engaging with us by post, phone, email, social media or otherwise; and
  • Automated technologies. As you interact with our website, we may automatically collect technical data, including about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. For further information in relation to our use of cookies, please see our cookies policy here: http://www.tbrgt.co.uk/cookie-policy/;
  • Third parties or publicly available sources.We may also receive personal data about you from public sources and from various third parties, including analytics providers such as Google Analytics.

How we will use information about you

  • Your personal data may be processed by us or our third party processors for the following purposes:
Purpose Lawful basis for processing
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
To scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems. Necessary for our legitimate interests (for the provision of IT services and network security).
To ensure that content from our website is presented in the most effective manner for you and for your computer and to use data analytics to improve our website, marketing, user experiences. Necessary for our legitimate interests (to define types of clients for our products and services, to study how visitors use our website, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To manage our relationship with you which will include:

(a) responding to enquiries from you; and

(b) notifying you about changes to our terms and conditions and privacy policy.

 (a) Performance of a contract with you;

(b) Necessary to comply with a legal obligation;

(c) Necessary for our legitimate interests (to keep our records updated and to study how visitors use our products/services).
To scan and monitor emails sent to us for viruses and other malicious software.

 

 Necessary for our legitimate interests (for the provision of IT services and network security).

 

 

Links to websites

Where the website provides links to other websites, we will not be responsible for the data protection/privacy/cookies policies of such other websites, and you should check these policies on such other websites if you have any concerns about them. If you use one of these links to leave our website, 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 a linked website and such websites are not governed by this policy. You should always review the policies of such websites as their terms may differ to ours.

Cookies

Our website uses cookies to distinguish you from other users of our website. For detailed information on the cookies we use and the purposes for which we use them please refer to our cookies policy, available at http://www.tbrgt.co.uk/cookie-policy.

 (B)      INVESTORS

The following section of this policy sets out how we may process personal data (as a controller) supplied by, and collected in relation to, shareholders and potential investors in TBRGT. Please note that if you visit our website, we may also collect personal data about you as described in Section A above.

Personal data we collect

In connection with your investment (or potential investment) in TBRGT, we may collect, store, and use the following categories of personal information about you:

  1. Identity data – includes your name, title, marital status, date of birth, gender, job title, and information required to verify your identity, including copies of your passport, identification documents (such as driving licences) and proof of address (such as utility bills);
  2. Contact data – includes contact details such as your address, email address and telephone number(s);
  3. Financial data – includes your bank account details, your tax residency, personal identifiers (such as your national insurance number and tax file number) and details relating to your investment activity;
  4. Special category data – in limited cases, we may collect what is known as “special categories” of data. Our money laundering, sanctions, financial crime and fraud prevention checks sometimes result in us obtaining information about political opinion, actual or alleged criminal convictions and offences. You are not obliged to provide us with your information where it is requested but we may be unable to provide certain products and services or proceed with our business relationship with you if you do not do so. Where this is the case, we will make you aware. Please see the “Consent” section in Section 7 below for further details.

We may also process personal data about individuals that are connected with you as an investor (for example, directors, trustees, representatives, beneficiaries, shareholders, investors, clients, beneficial owners or agents).

How we collect your data

We use different methods to collect data from and about you including:

  • Direct interactions, whereby you give us your personal data directly as a result of your holding and/or investment in TBRGT (by completing application forms, engaging with us by post, phone, email, social media or otherwise;
  • Third parties or publicly available sources.We may also receive personal data about you from various third parties, including background check providers which may include credit references, or for compliance purposes such as screening, and from third party publicly accessible sources, including Companies House records and social media (such as LinkedIn).

How we will use information about you

Your personal data may be processed by us or our third party processors for the following purposes:

Purpose Lawful basis for processing
To send you information about the company (including updates on the company’s performance relevant to your investment, annual financial reports, interim management statements and such other shareholder notices or ‘service’ correspondence as we consider appropriate). (a) Performance of a contract with you;

(b) Necessary for our legitimate interests (to ensure the information we are providing is accurate and up-to-date and we are providing a good service to our investors, and to grow our business).
To allow us to administer and manage your investments in TBRGT (including the payment of dividends and collation of due diligence as a result of holding your investment), and to perform our financial management, reporting and administration functions. (a) Necessary to comply with a legal obligation;

(b) Necessary for our legitimate interests (including to perform activities relating to client management, promotion of our business to potential investors, performing accounting, auditing and other internal functions, managing existing investments, and providing updates of investments to clients).

 
To update and maintain our company records, including maintaining statutory registers. Necessary to comply with a legal obligation.
To carry out anti-money laundering checks and other actions in an attempt to detect, prevent, investigate and prosecute fraud and crime. (a) Necessary to comply with a legal obligation;

(b) Necessary for our legitimate interests (including the prevention of fraud, money-laundering, sanctions, terrorist financing, bribery, corruption and tax evasion).
To prepare tax related information in order to report to tax authorities. Necessary to comply with a legal obligation.
To scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems. Necessary for our legitimate interests (for the provision of IT services and network security).
To meet our legal or regulatory responsibilities, including our fiduciary duties and FCA obligations to our clients or when we make disclosures to courts, tribunals, authorities, regulators or supervisory or governmental bodies. Necessary to comply with a legal obligation.
Such other actions as are necessary to manage the activities of TBRGT, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and/or as required by any regulatory body, and enforcing or defending the rights and/or interests of TBRGT. (a) Necessary to comply with a legal obligation;

(b) Necessary for our legitimate interests (including the prevention of fraud, money-laundering, sanctions, terrorist financing, bribery, corruption and tax evasion).

 

 

To the extent that any personal data we collect contains special category data then the processing of such data shall solely be for the purpose of complying with any duty imposed on us and/or our processors (including managers, registrars and administrators) by an enactment including, but not limited to, legislation and regulatory obligations relating to anti-money laundering and combatting the financing of terrorism and other related legislation. In limited circumstances, we may ask for your explicit written consent to process special category personal data and we will inform you of our intended purpose(s) of processing such data at the relevant time.

We may only use information relating to criminal convictions where the law allows us to do so. We may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

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

(C)       BUSINESS CONTACTS

The following section of this policy sets out how we may process personal data (as a controller) about our business contacts and service providers (and employees of service providers) and data subjects that have provided a business contact to, or have corresponded with, us. Please note that if you visit our website, we may also collect personal data about you as described in Section A above.

Personal data we collect

We may collect, use, store and transfer different kinds of personal data about you which you provide to us including:

  1. Identity data – includes your name, title, date of birth, occupation, job title;
  2. Contact data – includes contact details such as your address, email address, telephone numbers and place of work.

How we collect your data

We use different methods to collect data from and about you, including:

  • Direct interactions, whereby you give us your personal data information which is provided to us by you directly from time to time (including any personal data included on business cards or provided when you engage with us by post, phone, email, social media or otherwise);
  • Third parties or publicly available sources.We may also receive personal data about you from various third parties, including information provided to us by your employer, or information from publicly available sources, including Companies House records and social media (such as LinkedIn).

How we will use information about you

Your personal data may be processed by us or our third party processors for the following purposes:

Purpose Lawful basis for processing
To carry out our obligations arising from any contracts entered into between you and us (including receiving goods and/or services from you for use in our business). (a) Necessary for the performance of a contract.

 
To communicate with you in relation to the provision of such goods and services to us. (a) Necessary for the performance of a contract;

(b) Necessary for our legitimate interests (including the management of our business).
To scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems. Necessary for our legitimate interests (for the provision of IT services and network security).
Such other actions as are necessary to manage the activities of TBRGT, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and/or as required by any regulatory body, and enforcing or defending the rights and/or interests of TBRGT. (a) Necessary to comply with a legal obligation;

(b) Necessary for our legitimate interests (including the prevention of fraud, money-laundering, sanctions, terrorist financing, bribery, corruption and tax evasion).

 

 

(D)       JOB APPLICANTS

The following section of this policy sets out how TBRGT may process personal data (as a controller) about applicants of jobs or placements and potential workers and contractors. Please note that if you visit our website, we may also collect personal data about you as described in Section A above.

Personal data we collect

In connection with your application for work with us, we will collect, store, and use the following categories of personal data about you:

  1. Identity data – includes your name, title, marital status, date of birth, gender, job title;
  2. Contact data – includes contact details such as your address, email address and telephone numbers;
  3. Recruitment data – includes your employment history, qualifications, information provided to us during telephone calls, interviews and/or meetings with you, information contained in your CV and cover letter or email, and references.

We may also collect, store and use the following “special categories” of sensitive personal data: Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions, information about your health, including any medical condition, health and sickness records and/or information about criminal convictions and offences.

How we collect your data

We may collect personal data about candidates from the following sources:

  • Direct interactions whereby you may give us your personal data by filling in forms, providing a curriculum vitae or business card, corresponding with us by post, phone, email or otherwise, or during interviews and/or meetings with you;
  • Third parties or publicly available sources, including recruitment agencies, background check providers, credit reference agencies, your named referees on a curriculum vitae provided to us, and data from publicly accessible sources, including Companies House records and social media (such as LinkedIn).

How we will use information about you

Your personal data may be processed by us or our third party processors for the following purposes:

Purpose Lawful basis for processing
To assist with our recruitment process  including:

(a)        to assess your skills and qualifications, to consider your suitability for the position;

(b)        to carry out background and reference checks, where applicable;

(c)        to communicate with you about and in connection with the recruitment process;

(d)        to keep records related to our hiring processes; and

(e)        to comply with legal or regulatory requirements.

 (a) In order to take steps prior to entering into a contract with you;

(b) Necessary for our legitimate interests (in order to decide whether to appoint you to work for us, to grow our business and perform adequate due diligence on employment candidates);

(b) Necessary to comply with legal obligations (including our obligations to the FCA).
To manage our relationship with you which will include:

(a) responding to enquiries from you; and

(b) notifying you about changes to our terms and conditions and privacy policy.

 (a) Performance of a contract with you;

(b) Necessary to comply with a legal obligation;

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To scan and monitor emails sent to us for viruses and other malicious software. Necessary for our legitimate interests (for the provision of IT services and network security).
To update and maintain our records (a) Necessary for our legitimate interests (including the prevention of fraud, money-laundering, sanctions, terrorist financing, bribery, corruption and tax evasion);

(b) Necessary to comply with a legal obligation.
To prepare tax related information. Necessary to comply with a legal obligation.
Such other actions as are necessary to manage the activities of TBRGT, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) as required by any regulatory body and enforcing or defending the rights and/or interests of TBRGT. (a) Necessary to comply with a legal obligation;

(b) Necessary for our legitimate interests (including the prevention of fraud, money-laundering, sanctions, terrorist financing, bribery, corruption and tax evasion).

 

 

Our recruitment process

Once we receive your CV and covering letter or your application form, we may process that information to decide whether we have any suitable vacancies and if you meet the basic requirements to be shortlisted for that role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the work. If we decide to offer you the work, we will then take up references and we may carry out other checks before confirming your appointment.

If you do not provide information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

Special category data

In addition to any special category data processed as part of our recruitment process as set out above, we will process special category data in the following ways:

  • we will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during the interview; and
  • we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure equal opportunity monitoring and reporting.

Such special category data will be processed on the basis that it is necessary for compliance with a legal obligation (including equality laws) and in order to pursue our legitimate interests (being to ensure a safe and accessible environment for visitors suffering from disabilities, and to ensure we are an equal opportunities employer), and in addition that such processing is necessary for the purposes of carrying out our obligations and your rights in the field of employment law.

We envisage that we, or our recruiter, will process information about criminal convictions. We will only collect information about your criminal convictions history if we would like to offer you the work or a position (conditional on checks and any other conditions, such as references, being satisfactory). We are required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Automated decision-making

 

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

 

3.DISCLOSURES OF YOUR PERSONAL DATA

We will not disclose personal information we hold about you to any third party except as set out below.

We may disclose your personal data to the following third parties and/or for the following purposes:

  • other members of our group;
  • to the board of TBRGT;
  • to the company secretary;
  • to third parties who are providing services to us, including IT service providers, marketing service providers, background and/or credit reference services, telephone service providers, document storage providers, backup and disaster recovery service providers;
  • to processors of TBRGT, including printers, registrars, administrators, investment managers, proxy service company, depositaries, auditors, tax advisers and other professional advisors;
  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if we are permitted by law to disclose your personal data to that third party; and/or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation.

 

4. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will take reasonable steps to destroy, or erase from our systems, personal data which is no longer required. In some circumstances you can ask us to delete your data.

At the latest, we will destroy each shareholder’s personal data 20 years after they cease to be a shareholder.

In respect of job applicants, if your application is unsuccessful, the information you have provided will be retained by TBRGT for six (6) months after we have communicated to you our decision to you. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information. If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

 

5. INTERNATIONAL TRANSFERS

Some of the external service providers used by TBRGT are based outside the European Economic Area (“EEA“) so their processing of your personal data will involve a transfer of data outside the EEA. We will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Whenever your personal data is transferred out of the EEA by us, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you would like further information on the specific mechanism used when transferring your personal data out of the EEA.

 

6. HOW WE PROTECT YOUR DATA

We have put in place what we consider to be appropriate measures to ensure the security of the personal data we collect and store about you. We will use reasonable endeavours to protect your personal data from unauthorised disclosure and/or access, including through the use of network and database security measures, although we cannot guarantee the security of any data we collect and store. In addition, we limit access to your personal data to those employees, agents, 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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

7. YOUR LEGAL RIGHTS

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

  • 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 lawfully processing it;
  • 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 below);
  • object to processing of your personal information where we are relying on a legitimate interest (or those 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 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; and
  • request the transfer of your personal information to another party.

Exercising your legal rights

If you wish to exercise any of the rights set out above, please contact us at DPM.PFS.UK@PraxisIFM.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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 may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests 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.

Consent

  • In most cases, TBRGT does not anticipate needing to ask for your consent to the processing of your personal data, other than as specifically highlighted in this policy. If we wish to use your personal data for other purposes which do require your consent, we will contact you in advance of any processing to request this. In such circumstances, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
  • If you decide to provide your consent, you have the right to withdraw your consent at any time, although this will not affect the lawfulness of any processing based on your consent which took place before its withdrawal. To withdraw your consent or to opt out of receiving any of our marketing communications, please contact us at PFS.UK@PraxisIFM.com or follow the unsubscribe instructions included in any electronic communications (in respect of electronic marketing). Once we have received a notification that you have withdrawn your consent, we will no longer process the information which was collected on the basis of your consent. Please note that withdrawal of your consent will not affect any processing which is carried out on a lawful basis other than your consent (please see Section 2 above for further details), which we may be entitled to continue processing.

8. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. We may update this privacy notice from time to time, and will communicate such updates through our website. This version was last updated in September 2020. Please check back frequently to see any updates or changes to our privacy policy.

It is important that the personal data we hold about you is accurate and current and we try to ensure that we keep our records up-to-date. Please keep us informed if your personal data changes during your relationship with us.


9. CONTACT US

If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please contact us at DPM.PFS.UK@PraxisIFM.com

TBRGT plc is a public limited company incorporated in England with registered number 12814859 and is an investment company within the meaning of section 833 of the Companies Act 2006.

© 2020 Tellworth British Recovery & Growth Trust plc. All rights reserved

Data Protection and Privacy Policy
Last updated: September 2020