1 What is the purpose of this document?
1.1 Joining Ventures Limited (we, our or us), trading as Joining Ventures, is committed to protecting and respecting your privacy. This privacy notice sets out what personal data we hold about you, why we hold your personal data and our legal bases for using your data. It also provides you with other information about your personal data, such as, what rights you have regarding your data.
1.2 Personal data means any information relating to an individual from which that person can be identified, either directly or indirectly.
1.3 For data protection purposes we are a controller. This means that we are responsible for deciding how we hold and use your personal data and for explaining this clearly to you.
1.4 This privacy notice applies to visitors to our website who do not register with us as well as those who do.
2 Our use of your personal data
2.1 Our main reason for using your personal data is to provide our services to you and to other users. Further information on this and our principle legal bases for processing are set out in the tables in sections 3 and 4 below. In some circumstances, more than one basis will apply.
2.2 Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
3 The information we hold about you, why we use it and our legal basis for doing so
|Information we collect from you|
|Information||How and why we use this information||Our legal basis|
|Name and email address.||We use this information to manage and administer your account.||This isnecessary for our legitimate interest in making sure our service is working
well. Also to perform the contract between us.
|Name,email address, occupation and information about your business and investment
|We may use this information to provide you with marketing information.||We obtain your consent (where applicable) to send you marketing information. We may also send you marketing information on the basis that it is necessary for our legitimate interest in
promoting our business. However, this would only be if your consent is not legally required and you have not asked us to stop sending you marketing information.
|Any information which you provide in the message box when signing up to receive our
|To provide updates and to respond to any questions you have asked us or feedback
which you have provided.
|This is necessary for our legitimate interest in engaging with interested users and
potential users of Joining Ventures.
|The information which you provide to set up a Joining Ventures account and profile.
This would usually comprise your username, your name, address, email address, occupation, relevant experience
and a photograph. You an choose what information you provide to an extent but as a minimum we require you to provide your username, your name, and your email address.
|This information is used to create the content of your profile. This enables you to use our services.||This is necessary to perform the contract between us.|
|The information which you may provide to us about your projects and/or about your investment interests.
It is up to you what information you provide but this may include your relevant experience and background. You may also provide details of what type of investment you are looking for (e.g. financial or
skills-based) and the form of incentive for the investor (e.g. profit or equity).
|This information is used to create your profile on our site.||This is necessary to perform the contract between us.|
|Information which you provide to us if you have any queries, for example, about how to use our website. For example, the content of any messages you send to us.||To provide support and assistance.||This is necessary for our legitimate interest in managing and improving our
business. Also to perform the contract between us.
|If you provide a review of someone through our Review & Rating System you may disclose information about yourself.||To enable us to publish your review.||This is necessary for our legitimate interest in having reviews available on our
|Financial information whichyou provide to us. We accept payment using the following three payment methods:
1. Bank transfer;
2. PayPal; and
3. Credit / debit card.
Therefore we may have details such as your account number and sort code.
|To facilitate the payment of any commission owed to us.||This is to enable you to perform the contract between us, specifically pay us commission
owed to us. We also have a legitimate interest in taking payment from you.
|Information we receive from third parties|
|Confirmation of payments you have made via our payment service provider.||To confirm payment.||This is necessary to perform the contract between us, specifically so that we know that payment has been confirmed.|
|We may receive information about you through the Review & Rating System on our website. For example, other users may comment on how helpful you were in relation to their project or what valuable skills you have.||To create the content of this part of our site.||This is necessary for our legitimate interest in having reviews available on our
|We may receive information about you if another user raises a concern with us about your activity on the website.||To provide support to our users and to help ensure that our website and services are used appropriately.||We have a legitimate interest in using this information to manage our services.|
|We may receive information about you from your employer, or your colleagues, if they use our service. For example, about your occupation and skills which they would like to publish on our website. Alternatively, we may receive your information from our users if you are connected to one their projects or have worked with them in the past.||This information is published on users’ profiles. For example, your employer might make your contact details available so that other users can contact you about services you provide.||This is necessary for our legitimate interest in fulfilling our agreement
with our user to publish the information which they would like to be
on our website.
4 Sharing your information and our legal basis for doing so
|How we share your information||Legal basis|
|We may share your information with our auditors if this is relevant to their job.||We have a legitimate interest in making sure that we are performing well as a company.|
|If we consider that you owe us a debt we may share your information with debt recovery
|We have a legitimate interest in recovering money owed to us.|
|We may share your information with our professional advisors, such as lawyers or accountants, if it is relevant to the work that they are doing for us.||We have a legitimate interest in seeking professional advice to assist us where appropriate.|
|We may share your information with HMRC or other government or law enforcement agencies if we have a good reason to do so.||We may be legally obliged to share this information. It also may be necessary
for our legitimate interest in co-operating with the agencies.
|We may share your information with the Financial Conduct Authority (FCA) who regulate our business. For example, this might be regarding an investigation
which they conducting.
|To comply with a legal obligation to provide information to the FCA.
Voluntarily providing information to the FCA in certain circumstances is also in our legitimate interest (specifically our legitimate interest in engaging proactively with our regulator).
|In limited circumstances, we may share your information with our insurance provider. For example, if something unexpected happens and we need to let them know that we may need to make a claim.||We have a legitimate interest in complying with our insurance policy and to make sure that we have the insurance cover that we need.|
|If we sell any business or assets, we may disclose your personal data to the prospective buyer of such business or assets.||We have a legitimate interest in managing our business and commercial opportunities. The other party has a legitimate interest in understanding the business or asset which they might purchase.|
|We may share your information for the purposes of fraud protection and credit risk reduction.||We have a legitimate interest in protecting our business.|
|We will share your information if we have a legal obligation to do so, for
example, to comply with a court order.
|This sharing would be on the basis that we have a legal obligation to do so.|
We share your data with third-party service providers, such as our payment service providers, our website host server, IT support and maintenance service, cloud storage provider, email exchange server and other businesses that provide certain services to us.
All of our third-party service providers are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.
5 Special Category Personal Data
- 5.1 There are certain categories of personal data which are granted additional protection under data protection law. These are as follows: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health information and information about sex life or orientation.
- 5.2 We do not process these types of personal data as part of our usual course of business. However, it is possible that you may choose to provide this type of information to us, for example, if it is relevant to your project or your investment interests.
- 5.3 We may process this type of information:
- 5.3.1 where it is needed to protect your vital interests (or someone else’s interests) and you are not capable of giving your consent;
- 5.3.2 where it is necessary to establish, exercise or defend a legal claim;
- 5.3.3 the processing is necessary for reasons of substantial public interest;
- 5.3.4 where you have manifestly made the information public; or
- 5.3.5 otherwise with your explicit consent.
6 Providing us with personal data
6.1 If you fail to provide certain information when requested, we will not be able to provide our services to you.
6.2 We want to be sure that the personal data we hold about you is accurate and current. You can update the personal data on your profile, or the contact details we hold for you, by clicking on the edit button within your profile.
7 For how long will we keep your personal data?
7.1 We will only keep 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 obligations.
7.2 Where a minimum retention period is required by law (such as retaining records for HMRC purposes) we comply with that minimum period plus up to 12 months to allow time for us to anonymise or delete information in accordance with our internal data management processes.
7.3 Emails are kept for up to six (6) years on our back-up email exchange server.
7.4 Information relating to our contract with our customers, including payment data, may be retained for up to 7 years after termination of the contract to allow us to meet our legal obligations in relation to our accounting records.
8 International transfers
8.1 Our site is available throughout the world which means that your personal data will be available internationally.
9 Your rights
- 9.1 You have the following rights:
- 9.1.1 to ask us to correct or update the personal data we hold about you. Alternatively, you can do this by going to your profile at: My account
- 9.1.2 to object to the processing of your personal data when:
- (a) we are using it for direct marketing purposes (e.g. to send you our newsletter by email);
- (b) the legal basis on which we are relying is legitimate interests. Please see sections 3 and 4 above for information about our legal bases; and
- (c) if we ever use your information for statistical, scientific or historical research purposes.
- 9.1.3 to request a copy of the personal data we hold about you;
- 9.1.4 to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it;
- 9.1.5 to ask us to restrict how we use your personal data for a period of time if you claim that it is inaccurate and we want to verify the position, or in some other limited circumstances; and
- 9.1.6 to ask us to send your personal data to you or to another organisation in a computer-readable format.
- 9.2 If we delete your personal data or restrict our use of it, we may not be able to provide our services to you.
- 9.3 If you want to exercise any of your rights, please contact email@example.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
- 9.4 You have a right to lodge a complaint with a data protection supervisory authority. The supervisory authority in the UK is the Information Commissioner’s Office
- 9.5 If you do have any concerns about how we have handled your personal data we would kindly ask that you contact us in the first instance before you speak to the ICO so that we have an opportunity to put things right.