Privacy Policy

Important information and who we are

Welcome to Waterspring’s privacy policy.

This privacy policy explains how Waterspring Ventures Limited collects and processes your personal data where you have contacted us to receive more information about us or through your use of this website.  This covers any data you may provide to us if you make contact with us or we meet with you or which you provide through this website including:

  • when you send us a message via “Contact Us” on this website;

  • when you subscribe to our news and updates; or

  • when you send us a proposal via “Pitch to Us” on this website.

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

Waterspring Ventures Limited is the controller and responsible for your personal data (collectively referred to as “Waterspring”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data protection manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data protection manager by email to sam@waterspring.vc

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

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

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

Our 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 policy of every website you visit.

Please be aware that subscriptions to our news and updates are managed on our behalf by a third party, Squarespace. In subscribing to our news and updates, you will be providing your email address to both us and Squarespace and:

1: The data we collect about you

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 as follows:

  • Identity Data includes first name and last name and job title.

  • Contact Data includes email address, business address, telephone number, website domain.

  • Technical Data includes 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.

  • Profile Data includes your username and password, your interests and preferences.

  • Usage Data includes information about how you use our website and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

2: How is your personal data collected?

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

  • Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us through our website or by post, phone, email or otherwise or in person if we meet with you. This includes personal data you provide when you:

o   apply for our services;

o   send us a business proposal;

o   subscribe to our news and updates;

o   contact us; or

o   request marketing to be sent to you.

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

3: How we use your personal data

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:

  • Where we need to perform a contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party). Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To review and assess the business proposal you have submitted to us via the Pitch to Us page.

(a) Identity

(b) Contact

(a) In some cases, in connection with performance of a contract with you or your business

(b) Necessary for our legitimate interests (for running our business and provision of services)

To register you as a new business customer if we have approved your business proposal.

(a) Identity

(b) Contact

Performance of a contract with you

To respond to your query/message from the Contact Us page.

(a) Identity

(b) Contact

(a) In some cases, in connection with performance of a contract with you or your business

(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services and to develop our services and grow our business)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy.

(a) Identity

(b) Contact

(a) In some case, in connection with performance of a contract with you or your business

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a) Identity

(b) Contact

(c) Technical

(a) 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)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, services, marketing, customer relationships and experiences.

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you .

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will only receive marketing communications where you have requested information from us and you have opted-in to receive our marketing communications.  You have the right to opt-out at any time (see further "opting out" below).

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, we may still hold personal data about you in accordance with this Privacy Policy in connection with any contract we have with you and any services we are providing to you (including if you have access to our customer portal).

Cookies

For more information about the cookies we use, please see here.

4: Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above:·

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.

  • Typeform acting as a processor for storing and processing Identity Data and Contact Data.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

5: International transfers

We do not transfer your personal data outside the UK. 

Please be aware that in subscribing to our news and updates through our website, your personal data may be processed by Squarespace (please see our "Third Party Links" section above for further details including a link to Squarespace’s Privacy Policy).

6: Data security

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 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.

8: Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

8.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

8.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

8.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, 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.

8.4 Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

8.5 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:

  • If you want us to establish the data’s accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • 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.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

8.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

8.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

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 unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.