Privacy

At ICG, we are committed to maintaining the confidentiality, integrity, and security of the personal information of all individuals who engage with us in any capacity whether as shareholder, investor, prospective investor or prospective employee.

Collecting personal data
What data do we collect?
How we collect data?
What we do with data?
Arrangements to disclose data
Transfer of personal data from EEA
What are your rights?
How we look after your data
Changes to this policy
Use of cookies by ICG
Group entities

We have designed this privacy policy to inform you about the way in which we manage your personal data.

Collecting personal data

In the course of providing you with funds and services, we collect personal data from:

Our investors (including any employees or agents of our investors) and prospective investors
Our shareholders
Suppliers and prospective suppliers
Companies in which our funds make investments (or have previously made investments or are contemplating making investments) and individuals involved in the management of those companies
Job applicants
Any other person who provides their details to us or otherwise contacts us or is contacted by us by phone or email

This makes us, ICG, data controller of your personal data. A list of our entities is appended to this document. Accordingly, we owe you certain obligations as set out below.

ICG employees in the firm's City of London office

What data do we collect?

We may hold some of the below types of data on you.

Investors and prospective investors’ data

Contact details: Name, address, email address, phone number, job title, employer or associated entity
Financial information: bank account details, payment details and confirmations
Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations.
Date of birth
National Insurance number or similar national registration number
Identity documents (including all data): Passport, driving licence, utility bill, other proofs of address or identity
Any additional data voluntarily provided by you

Shareholder data

Contact details: Name, address, email address, phone number
Financial information: bank account details, payment details and confirmations
Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations.
Date of birth Any additional data voluntarily provided by you

Suppliers and prospective suppliers’ data

Contact details: Name, address, email address, phone number, job title, employer or associated entity
Financial information: bank account details, payment details and confirmations
Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations.
Any additional data voluntarily provided by you

Investee, former investee and prospective investee data

Contact details: Name, address, email address, phone number, job title, employer or associated entity
Financial information: bank account details, payment details and confirmations, salary and bonus details
Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations.
Employee HR records
Date of birth
National Insurance number or similar national registration number
Identity documents (including all data): Passport, driving licence, utility bill, other proofs of address or identity
Any additional data voluntarily provided by you

Job applicant data

Contact details: Name, address, email address, phone number, job title, employer or associated entity, education and employment history
Financial information: current salary and package
Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations.
Date of birth
National Insurance number or similar national registration number
Identity documents (including all data): Passport, driving licence, utility bill, other proofs of address or identity and right to work documentation
Any additional data voluntarily provided by you

Data from other persons who provide their details to us or who we contact

Contact details: Name, address, email address, phone number, job title, employer or associated entity
Correspondence/conversations: hard copy and soft copy correspondence and recordings of telephone conversations.
Any additional data voluntarily provided by you

Technical data

We may automatically process some technical data such as your Internet Protocol (IP) address to identify what companies have interacted with the website. This processing only identifies a company name and will not be used to identify an individual. We use this to process traffic flows to our website.

Unless (a) we separately obtain your freely given, specific, informed and unambiguous consent for use for a specific purpose or (b) such collection is required by law or regulation, we do not collect from you any sensitive personal information (which includes, for example, information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, biometric data or health).

How do we collect personal data?

The personal data you submit to us may come in a variety of physical or electronic formats. Such data may also be transferred to, or processed by, third party providers for the purposes of them providing communications and IT services both to us and to you; this will be held in compliance with applicable law and will be subject to appropriate data protection obligations. Through the use of cookies, we also collect generic information about the way in which you use our internet website. Because of the financial services that we provide, we are also required by law to record certain telephone conversations held by our employees.

What do we do with your data?

We aim to collect only personal information that we can justify we need for our legitimate business purpose in order to provide to you our financial services.

We collect, store and process your personal information for the following purposes:


Type of data	Purpose for collecting	Data retained for how long?	Disclosed to which third party?
Investor and prospective investor data	To perform the services that you have asked us to and to conduct our investment activity To perform a contract to which you are a party To answer questions and enter into discussions with you about the services and funds that we offer. To conduct identity and credit checks in line with our obligations under legislation To comply with other legal obligations to which we are subject as a provider of financial services	For seven years after we cease to deal with you	ICG affiliates, our fund administrators and lawyers and other advisors and service providers where we have a legitimate business need for them to know this. Governmental or regulatory bodies (e.g. the Financial Conduct Authority) to the extent required by law.
Shareholder data	To manage your shareholding To perform a contract to which you are a party To answer questions and enter into discussions with you To comply with other legal obligations to which we are subject under company law	For seven years after you cease to be a shareholder	ICG affiliates, our group registrars, brokers and other advisors and service providers where we have a legitimate business need for them to know this. Governmental or regulatory bodies (e.g. Companies House) to the extent required by law.
Supplier and prospective supplier data	To consider whether to enter into a contractual arrangement with you To perform a contract to which you are a party To answer questions and enter into discussions with you about the services provided To comply with other legal obligations to which we are subject as a provider of financial services	For seven years after we cease to deal with you	ICG affiliates, our fund administrators and lawyers and other advisors and service providers where we have a legitimate business need for them to know this.
Investee, former investee and prospective investee data	To consider whether to enter into a contractual arrangement with you To perform a contract to which you are a party To answer questions and enter into discussions with you about the investment made To comply with other legal obligations to which we are subject as a provider of financial services	For seven years after we cease to deal with you	Governmental or regulatory bodies (e.g. the Financial Conduct Authority) to the extent required by law.
Job applicant data	To consider whether to offer your employment To comply with other legal obligations to which we are subject as a provider of financial services	For two years	ICG affiliates, our fund administrators and lawyers and other advisors and service providers where we have a legitimate business need for them to know this.
Data from other persons who provide their details to us or who we contact	To engage with you To comply with other legal obligations to which we are subject as a provider of financial services	For seven years after we cease to deal with you	Governmental or regulatory bodies (e.g. the Financial Conduct Authority) to the extent required by law.

Our arrangements with parties to whom we need to disclose your data

We may share your personal data with the third parties described above where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so or where required by law to do so.

Our Affiliates are our group companies listed in the appendix hereto.

All third parties (including our Affiliates) to whom we disclose your personal data are also legally obliged to take appropriate security measures to protect your personal information in line with ICG’s data protection and security policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transfer of personal data outside the European Economic Area

We may transfer the personal information we collect about you to the following countries outside the EEA order to perform our contract with you or to continue the operation of our business:

Hong Kong, United States, Canada, Singapore, Japan, South Korea, Australia, India

To ensure that your personal information receives an adequate level of protection we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection:

The use of binding Corporate Rules for inter-group transfers
The adoption of standard contractual clauses where required
The EU/US Privacy Shield

What are your rights?

Changes to your personal data: It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us (for example if you change your email address or if you wish to cancel a request for information).

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a "data subject access request")	This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you	This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information	This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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.	You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information	This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.	This enables you to seek a transfer of your personal data to a third party elected by you.
Complain to the Information Commissioner’s Office (ICO) or other EU domiciled Supervisory Body	If you have a complaint about the way in which we are managing and processing your personal data.

How we look after your data

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and the ICO of a suspected breach where we are legally required to do so.

Changes to this policy

If we change our privacy policy we will post the changes on this page, and may place notices on other pages of the website, so that at all times you may be aware of the information we collect and how we use it.

If you have any questions about the privacy policy and cookies please contact us.

Use of cookies by ICG

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

See more information on the cookies used by ICG.