This website (“Site”) is maintained by PXN Group Limited on its own behalf and on behalf of its subsidiary and affiliate companies, which include the following entities and collectively known as “PXN” and “we”, “us” or our”:
Par Fund Management Limited (trading as Par Equity)
Par Equity Holdings Limited
Par Advisers Limited
Par Equity Managements (US) LLC
Praetura Ventures Limited (trading as Praetura Investments and Praetura Ventures)
PXN respects your privacy and is committed to protecting your Personal Data (as defined, unless otherwise stated, under the UK General Data Protection Regulation ("UK GDPR")). This privacy notice will inform you as to how we look after your Personal Data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
The General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 govern the controlling and processing, such as the use or holding, of personal data, which is essentially any information about identifiable living individuals, and also gives those individuals certain rights and remedies in respect of that information.
The purpose of this notice is to supply you with the required information at the time of providing us with your personal data. This will lay out the essentials such as the what; where; when; and how in relation to the personal information collected. This should help you feel more confident about the privacy and the security of your personal information.
This privacy notice covers the specific areas set out below.
1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
Purpose of this privacy notice
This privacy notice aims to give you information on how PXN collects and processes your personal data through your use of our websites and services, including any personal data you may provide, for example personal details in our Application Management System (AMS) provided by you for the purposes of seeking investment, or personal details used to sign into our Client Management System (CMS).
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controllers
The operating subsidiaries of PXN that act as Data Controllers are: Praetura Ventures Limited and Par Fund Management Limited and those entities are responsible for your personal data.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details:
Rosie Bhattacharjee
Data Protection Officer
PXN Group Limited
dpo@pxngroup.co.uk
Changes to the Notice
This version was last updated on the date shown at the top of this page.
Changes to your data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We also may collect, use and share aggregated data such as statistical or demographic data for research or analytic purposes. Aggregated data may be derived from your personal data but we remove your identity when we process it. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, we may combine or connect aggregated data with other data we hold about you so that we can directly or indirectly identify you.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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.
Personal data required for regulatory / contractual reasons
Where we need to collect personal data by law for example to perform Anti Money Laundering (AML), or Know Your Client (KYC) or under the terms of a contract we have with you and you fail to provide that data when requested, we will not be able to perform the contract we have or are trying to enter into with you. In this case, we will notify and discuss this with you at the time.
We use different methods to collect data from and about you including through:
Direct interactions. You may provide details of your Identity, Contact, Financial Data, Past Investment Experience by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section 4 about the use of cookies.
We do not use automated data processing.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Purposes for which we will use your personal data
We have set out below, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
General Information
We strive to provide you with choices regarding certain personal data uses, particularly around the information we provide to you. Please contact us at dpo@pxngroup.co.uk there is information you no longer wish to receive.
Information relating to an investment
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which potential investments and services and may be relevant for you.
You will receive important and time sensitive information from us if it relates to an investment you have made, or has been made on your behalf, or relates to a company that you have a relationship with. You will receive this important information by virtue of successfully completing an application process for investment or are a member of one of our investee companies or have asked to be sent information.
Provision of confidential information to third-parties
We will get your express opt-in consent before we share your personal data with any individual or company outside the PXN group of companies. For example, your data may be provided to 3rd party client relationship managers.
However, where a third-party is contracted by us for example for the purposes of executing a transaction with the a custodian or registrar, we will not explicitly request your permission. Similarly, your personal information may be provided to investee companies, for example as part of an investment process.
Opting out
You can ask us or third parties with whom we have shared data to stop sending you information at any time by contacting us at the DPO email address above.
Where you opt out of receiving marketing information, this will not apply to personal data provided to us as a result of becoming a member of the our investment syndicates or investor of one of our managed funds. It will also not apply to the investee companies that you may have investments in as they have a legal responsibility to keep a record of their investors.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Our Website makes use of cookies. Cookies are files which our server uses to identify your computer. Cookies cannot identify which person is using the computer.
We use cookies to understand site usage and to improve the content and offerings on our site. For example, we may use cookies to personalise your experience on our web pages and to provide you with a better service.
Cookies can only be placed on a computer where the user has given their express consent. You can choose to accept or decline cookies when you first access our Site. We require you to indicate your choice via an automated “pop-up” box, which explains the cookies we use and what we use them for.
Most web browsers automatically accept cookies, but you can also usually modify your browser setting to decline cookies if you prefer. If you decline to accept our use of cookies or set your web browser to decline their use, you will have only limited functionality in the use of our site.
Change of purpose
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 we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with anti-money laundering and any other regulatory requirement, where this is required or permitted by law.
We may have to share your personal data with both internal and external parties as detailed in the Glossary and paragraph 4 above for the purposes set out in the table in paragraph 4.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will share your personal data within the PXN Group. This may involve transferring your data outside the United Kingdom (UK).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to access it. 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 actual or suspected personal data breach and will notify you and the applicable regulators of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
By law we have to keep basic information about our investors (including Contact, Identity, Financial, Transaction Data and Investment Experience) until they cease being customers for regulatory purposes. We will also keep information about the companies we have invested in (investee companies) including personal data relating to employees of those companies.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
You have rights under data protection laws in relation to your personal data.
We may not be able to respond to a request to delete or transfer data from our encrypted archive storage systems.
No fee usually required
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 repetitive or excessive in terms of the volume of data requested or is unfounded.
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 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, for example, a set time frame for the search to be conducted.
Time limit to respond
We try to respond to all 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.