Introduction

Zinc is an early stage investor that exists to build and scale brand-new ways to solve the most important societal problems faced by the developed world. This Privacy Policy will explain how Zinc collects, uses, processes and shares your personal data. This policy is in accordance with the European Union General Data Protection Regulation 2016/679 (“GDPR”) and is in relation to individuals outside of Zinc (referred to as “you” or “your” in this Notice).

Zinc Ventures Limited is a Limited company registered in England and Wales 10796984. Zinc is registered at the following address: 6th Floor, Euston House, London, NW1 1AD. This privacy policy is issued on behalf of the Zinc, so when we mention ” Zinc”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Zinc responsible for processing your data.

Zinc is considered a controller of your personal data for the purposes of data protection legislation. You can contact us about this policy by writing to ‘Zinc, 6th Floor, Euston House, 24 Eversholt Street, London, NW1 1AD’ or you can contact us electronically by sending an email to data@zinc.vc.

Zinc is committed to protecting your data and puts information security at the forefront of its processes.

This policy (“Privacy Policy“) explains what information Zinc collects from you, or that you provide to us, what we will use it for and with whom we share that information. The policy also sets out your rights and who you can contact for more information.

What information we collect from you and how we collect it

By ‘information,’ we mean personal information about you that we collect, use, share, store and transfer in physical and electronic form.

This information can be grouped together in the following categories:

Website

We collect and use information from those who visit our website, www.zinc.vc. Our website server automatically logs the IP address that was used when you accessed our website. We also gather information about your visit to our website. This includes what content was accessed, information that could have been requested, the date and time that requests were made or data was accessed and also the source of access to our website. This could include the URL link which linked you to the website or perhaps the browser used.

Data Collection Forms

We collect information that you provide to us when applying to join the Zinc programmes or when you complete an expression of interest form on our website. These forms can include your email address, name, telephone number, interest in Zinc and educational and employment details.

Recruitment

We collect your personal data when you submit a job application to us or if you choose to submit a job application or CV to us in any other way. This may include but not be limited to your contact information, such as your home address and contact details (including your mobile telephone number), your date of birth; your educational and professional qualifications, your right to work, visa status, employment status; and any other information about you that you disclose to us during the application process.

In considering your application we may also obtain information from third party sources, including any referees that you specify, educational institutions and publicly available sources including LinkedIn, Facebook and Twitter.

Emails

When we receive an email to a zinc.vc email address Zinc collects the email address and any information that is provided within that email. This could be classed as personal information such as name, telephone number etc. This applies to information you provide to us for the purpose of subscribing to our email notifications and/or newsletters including your full name, email address and interests.

Phone

If the contact is made by telephone, then we also process the telephone number that made the phone call and any information provided to the company on that call. Our telephone calls are not recorded.

Post

If information is provided to us, in person and by the use of a form, then we shall collect the information that has been highlighted there.

We also process the personal data of certain individuals (e.g. founders, directors, shareholders, representatives of suppliers) in the day to day running of our business activities.

What we use your Personal Data for

We use your personal data to administer the business of the Zinc. Specifically personal data may be used by us for the following reasons:

– Internal record keeping;
– Administration purposes;
– To carry out our obligations arising from any contracts entered into between you and us;
– Improvement of our products/services and to ensure that the content from our site and other communications is presented in the most effective manner for you;
– Recruitment purposes;
– Transmission by email of materials in which you may have expressed interest;
– Contact for market research purposes which may be done using email, telephone or mail. Such information may be used to customise or update the website.

If you do not want us to use your data in this way, please ensure you opt out of these kinds of communication if you have already opted in.

Lawful basis

Our processing of your personal information is necessary:

– For the performance of contracts to which you will be a party and in order to take steps at your request prior to you entering into those contracts;
– For the purposes of legitimate interests pursued by us; o
– In order to comply with a legal obligation to which we are subject.

In relation to any processing of special categories of personal information such as information about your health, we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information.

Legitimate interests

Where our processing is based on the legitimate interest grounds described above, those legitimate interests are: collecting personal information to provide you with a smooth and efficient experience and running our business.

Security of your personal data

All personal data is stored securely in accordance with the principles of the Data Protection Act, 2018 and to ensure that your data is protected we have put in place suitable physical, electronic and organisational procedures on our website and other data processing systems.

We endeavour to do our best in order to protect your personal data. However as you will be aware the transmission of information over the internet is not entirely secure and so carries certain risks.

Disclosing your personal data

Unless we are obliged to or permitted by law or regulatory requirements to do so, and subject to third party disclosures specifically set out within this policy, your data will not be disclosed to third parties. This does not include our affiliates and/or companies within the group.

Zinc may, for the purpose of running our business, share your information with the following categories of companies:

– Professional service providers, such as marketing agencies, advertising partners and website hosts who help us run our business;
– Analytics and search engine providers that may assist us in the improvement and optimisation of our Site;
– Third parties who support our information technology or handle mailings or events on our behalf;
– Law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site, our technology assets or the rights, property or personal safety of any person);
– Other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
– Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity; and
– Any successor in interest, in the event of a liquidation or administration of Zinc.

International transfers of personal data

Information which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). This includes the United Kingdom following the UK’s exit from the European Union and the United States of America.

When we, or our permitted third parties, transfer your information outside the EEA, we or they will impose obligations on the recipients of that data to protect your information to the standard required in the EEA or otherwise require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers made by us, we will put in place appropriate safeguards to ensure that your information remains adequately protected in transit and at rest.

How long we will keep your information for

Zinc shall not keep or process your personal data for longer than is necessary. We will retain documents including electronic documents containing personal data:

– to the extent that we are required to do so by law;
– if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
– in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Your Rights

Subject to limitations on certain rights, you have the rights set out below in relation to your information, which you can exercise by writing to data@zinc.vc or to “The Data Controller at Zinc”, 24 Old Bond Street, London, United Kingdom, W1S 4AP

At any time, you have the right to:

– request access to or a copy of any information which we hold about you;
– rectification of your information, if you consider that it is inaccurate;
– ask us to delete your information, if you consider that we do not have the right to hold it;
– withdraw consent to our processing of your information (to the extent such processing is based on previously obtained consent);
– ask us to stop or start sending you marketing messages as described below in the marketing section;
– restrict processing of your information;
– data portability (moving some of your information elsewhere) in certain circumstances;
– object to your information being processed in certain circumstances; and
– not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your information.

Access to your information

The General Data Protection Regulation (GDPR) enshrined into UK law as the Data Protection Act, 2018 allows any data subject affected by the processing of personal data, the right to request at any time, information about them and a copy of the personal data stored about their person. This is free of charge and will take a maximum of 30 days to return.

As the data subject, you will also have the right to be informed about whether your data has been transferred to a different organisation or country by law. Any changes will be immediately posted on the website. Zinc reserves the right to change this policy as we may deem necessary from time to time or as may be required by law.

By providing us with your personal data, including sensitive data such as your health, gender or race you consent to the collection and use of any information you provide in accordance with the above purposes and this privacy policy.

IP Address and Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

Zinc only uses cookies from a functional standpoint. For further information on how we use cookies, please see our Cookie Policy.

Zinc will collect data on how you browse our website to help us improve it. We will use Google Analytics to collect data on:

– The pages you visit;
– The links that are clicked on; and
– The terms you enter in the search box.

When visiting www.zinc.vc you will notice a cookie file at the bottom of the screen that you can read more on and that shall collect data. Cookies collect information by:

– Recording the ways in which you use the websites and content provided; and
– Recording the notifications and advertisements that are presented to limit repetition.

We shall not use cookies for any other reason and the reasons highlighted will enable us to improve our services.

If you are not happy with any of the cookies that are used on or via our website you can change your browser settings. This can sometimes have an effect on the way you use the services provided, including some of the features of the website. For further information about cookies you can visit http://www.allaboutcookies.org.

The website and this privacy policy are owned and operated by Zinc Ventures Limited. We are registered in England and Wales under registration number 10796984, and our registered office is 24 Old Bond Street, London, United Kingdom, W1S 4AP.

Contacting us and the ICO

You can contact us by writing to the business address given above, by using our website contact form, or by email to: data@zinc.vc.

We are registered as a data controller with the UK Information Commissioner’s Office – our data protection registration number is: A8357398

Zinc is not required by law to have in place a Data Protection Officer (DPO) however our nominal DPO is Lily Macfarlane, who can be contacted at lily@zinc.vc.

If you have any concerns about our use of your information, you also have the right to make a complaint to the data protection regulator in your country. If you are a UK resident, this is the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.