Privacy Policy

Personal Information

Business contacts

If you have interacted with Horizon Capital, whether through email, meeting someone from Horizon Capital, or otherwise, we may keep limited amounts of your personal information. This might include your name, job title, employer organisation and contact details. We do this for the purposes of:

• providing business updates (further described below);
• maintaining a list of contacts; and
• asking you along to events such as presentations or organising meetings between you and Horizon Capital’s representatives.

In accordance with Data Protection Laws, our legal basis for collecting and storing such personal information is that such processing is necessary for our legitimate interests in running and promoting our business. Whilst Horizon Capital does not routinely obtain consent as the legal basis upon which it stores and processes personal data, it will, if necessary, and to the extent required by Data Protection Laws, obtain the consent of the data subject to hold and process personal information. If consent is provided, it can be withdrawn by the data subject at any time.

The length of time such personal information will be held by Horizon Capital will depend on why it was collected initially. The requirements of applicable laws or regulations will also affect this.

Actual or potential management teams

If you are involved in a transaction that Horizon Capital and/or the funds that it manages enters into, or a potential transaction that Horizon Capital is contemplating, we may keep certain limited amounts of your personal information.

This might include information relating to your financial status and dealings, your CV, details of your previous employment history and professional activities, your nationality (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence we may have conducted. We collect and store this information for the purposes of:

• evaluating potential transactions;
• keeping records of assets and investments;
• assessing your suitability for involvement in a transaction, including by verifying your identity;
• meeting with our regulatory/legal obligations, including assessing and managing risk;
• administering any transaction that we are involved with;
• safeguarding our own legal rights and interests;
• receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
• providing business updates (further described below).

As required under Data Protection Laws, our legal basis for collecting and storing such personal information is that such processing is necessary for our legitimate interests in running our business, in particular in order to properly review potential investments, and administering any and all transactions that we are party to. In addition, Horizon Capital may be required to obtain and hold personal information (such as passports and other key identifying documentation) so as to comply with money laundering and related regulation and in order to conduct satisfactory ‘Know Your Client’ checks.

For any matter or transaction that you are involved in, it may also be necessary for us to process your personal information for performing that transaction and to comply with our relevant regulatory/legal duties. Whilst Horizon does not routinely obtain consent as the legal basis upon which it stores and processes personal data, it will, if necessary, and to the extent required by Data Protection Laws, obtain the consent of the data subject to hold and process personal information. If consent is provided, it can be withdrawn by the data subject at any time.

In certain limited circumstances personal information may be received by Horizon from a third party, for example a recruiter. In such circumstances it will be held in accordance with this Notice and Data Protection Law. The length of time such personal information will be held by Horizon Capital will depend on why it was collected initially. The requirements of applicable laws or regulations will also affect this.

Please note that Horizon Capital has carefully considered and balanced the rights and interests of its data subjects and does not believe such rights and interests have been overridden by Horizon Capital’s own interests. In making this assessment, Horizon Capital has considered the nature of all such data subject’s interests, any impact of processing and the relevant safeguards that have been put in place.

Suppliers and professional advisors

We will store limited amounts of personal information relating to suppliers to Horizon Capital, or one of Horizon Capital’s professional advisors. This may include names, job titles, qualifications, employer organisations and contact details. This personal information will be stored for the purposes of managing and preserving records of services or advice we have received and authorising further services.

In accordance with the Data Protection Laws, our legal basis for storing personal information that you provide to us is that such storage is necessary for our legitimate interests in running and promoting our business. Whilst Horizon does not routinely obtain consent as the legal basis upon which it stores and processes personal data, it will, if necessary, and to the extent required by Data Protection Laws, obtain the consent of the data subject to hold and process personal information. If consent is provided, it can be withdrawn by the data subject at any time.

The length of time such personal information will be held by Horizon Capital will depend on why it was collected initially. The requirements of applicable laws or regulations will also affect this.

MAILING LISTS

As part of our marketing activities, Horizon Capital collects and use personal information to provide updates on our activities and to issue invitations to events we host. We don’t rent or trade email lists with other organisations and businesses.

Horizon Capital uses third-party provider, Affinity to deliver its updates and issues events. Horizon Capital gathers statistics around email opening and clicks using industry standard technologies to help us monitor and improve the mailings. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of Horizon Capital’s emails or by emailing: team@horizoncapital.co.uk

Horizon Capital will take all reasonable steps to maintain the accuracy of your personal information. Where necessary, it will keep it up to date. You can request that Horizon Capital update or correct any information by contacting Horizon Capital at any time by emailing: team@horizoncapital.co.uk

INFORMATION VIA THE Horizon WEBSITE

You can visit our website without telling us who you are or revealing any information about yourself. However, the website does contain user-submitted forms where we collect personal information from you, which can include your name, email address and telephone number. This personal information will be held by Horizon Capital.

HOW INFORMATION ABOUT YOU WILL BE USED

When personal information is collected we generally use the information you provide, or which we collect via this website, for the purposes of:

• updating our records about you
• responding to your enquiries or to process your requests in relation to your information
• administering offers, competitions and other promotions
• evaluating the effectiveness of our marketing and for research, training and statistical analysis with the aim of improving our services
• making the website easier for you to use and providing you with access to certain parts of the website
• providing you with services which you have requested and notifying you about important changes or developments to these services

We may contact you by post or by phone unless you have told us not to, and by email, text or other electronic means if you have told us that we can or as otherwise allowed by law. You may tell us at any time if you change your mind.

We only hold records for as long as it is needed for the purpose it was collected. Furthermore, as required by the UK Data Protection Legislation, we follow strict security procedures in the storage and disclosure of information, which you have given us, to prevent unauthorised access.

MANDATORY PROVISION OF INFORMATION

You will be notified when the provision of particular information is mandatory, including the possible consequences of not providing particular information. This may include, for example, preventing us from proceeding with a transaction involving you. Horizon Capital will only process the personal information you provide to Horizon Capital for the purposes listed above. In particular, Horizon Capital may be required to obtain and hold personal information (such as passports and other key identifying documentation) so as to comply with money laundering and related regulation and in order to conduct satisfactory ‘Know Your Client’ diligence checks.

SENSITIVE OR SPECIAL CATEGORY PERSONAL DATA

Please be aware that different rules apply to data concerning certain sensitive categories, including race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences. All such categories are deemed to be either sensitive or special category personal data. We kindly ask you not to send us such information.

THIRD-PARTIES

Horizon Capital will not sell, distribute or lease your personal information to third parties unless Horizon Capital has your permission or are required by law to do so.

WHAT ARE YOUR RIGHTS?

If Horizon Capital holds your personal information you may be entitled to access it. Additionally, you may be able to request that it is deleted or that any processing of it is limited. You may request that any inaccurate personal information is corrected. If you wish to make any such request (or if you wish to object to the processing of your personal information or obtain a copy of it) you should submit it by email to the Data Protection Team (horizoncapital.co.uk).

You also have the right to complain about the use of your personal information to the relevant Supervisory Authority. In the UK this is the Information Commissioner’s Office (www.ico.org.uk). Horizon Capital is registered with the ICO under the Data Protection Register, with registration number: Z9939866.

BUSINESS UPDATES

We may use personal information that we hold to send you periodic updates about Horizon’s business, activities and opportunities, in particular, by email and post. You can opt out of receiving updates at any time by contacting us or by clicking the “Unsubscribe” link in any email that you receive.

ACCURACY AND SECURITY

Horizon Capital will take all reasonable steps to maintain the accuracy of your personal information. Where necessary, it will keep it up to date. You can request that Horizon Capital update or correct any information by contacting Horizon Capital at any time by emailing  team@horizoncapital.co.uk.

Horizon Capital will take all reasonable steps to protect the confidentiality and security of your personal information but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information online over the Internet and will not hold Horizon Capital responsible for any breach of security unless this is due to Horizon Capital’s negligence or wilful default.

For all queries, please do not hesitate to email team@horizoncapital.co.uk. You can also make enquires in writing by contacting the Finance Director at Horizon Capital’s registered office, which is listed on the website. Horizon Capital, may update this Notice periodically and such changes will be notified to the website.