Privacy 

Website data

This Privacy Notice applies to our use of any and all personal information collected by us in relation to your use of the Website (“Website Data”) and any services or systems therein.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.

What personal information does CompX collect and why?

The personal information that we may collect about you broadly falls into the following categories:

  • Information that you provide voluntarily
    Certain parts of our Website may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to subscribe to marketing communications from us, book a demo of the platform and/or to submit enquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

  • Information that we collect automatically
    When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws. Specifically, the information we collect automatically may include information such as your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked. Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

  • Information that we obtain from third party sources
    From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. The types of information we collect from third parties include job title and Employer and we use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you and to better understand the needs of our website users and subscribers.

 

who does CompX share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • to our group companies, third party services providers and partners who provide data processing services to us or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. These include for purposes including the facilitation payment handling, delivery of services, advertising and marketing.

  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

  • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;

  • to any other person with your consent to the disclosure.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

 

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is necessary for our legitimate interests, which, given the nature of the processing and the security measures we undertake, are not overridden by your data protection interests or fundamental rights and freedoms, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

 

If we collect and use your Website Data in reliance on our legitimate interests (or those of any third party), these interests will normally be to operate our Website and communicate with you as necessary to provide our services to you and for our legitimate commercial interests, for instance, when responding to your queries, improving our Website, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

 

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details.

 

Cookies and similar tracking technology

 

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. A Cookie is a small file that resides on your computer’s hard drive and often contains an anonymous unique identifier and is accessible only by the web site that placed it there, not any other sites.

How does CompX keep my personal information secure?

 

Data security is of great importance to CompX and to protect your personal information we have put in place suitable physical, electronic and managerial procedures to safeguard and secure personal information collected online.  For example, where appropriate we use encryption in transit and at rest, have strict and secure access controls. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

Platform data

This Privacy Notice applies to our use of any and all personal information collected by us for inclusion on the CompX Platform (“Platform Personal Data“).

If you have any questions or concerns about our use of your personal by reason its inclusion on the CompX Platform, then please contact us using the contact details provided at the bottom of this Privacy Notice.

what personal information does CompX collect and why?

 

The purpose of processing Platform Personal Data is to allow businesses that subscribe to the CompX Platform (“Subscribing Organisations”) and their clients to identify those individuals who have invested in or are involved with ambitious companies. Doing so allows Subscribing Organisations to provide context to the wider data-set that we hold about such companies, thereby facilitating more relevant approaches to the individuals involved in the high-growth company ecosystem and more well-informed offerings of professional services and funding opportunities.

 

The personal information that we may collect about you broadly falls into the following categories:

  • Information that you or one of your company employees provides to us voluntarily
    Occasionally company employees will provide us with personal data relating to themselves and their company, including names and email addresses of key personnel, so that the platform can have the most up to date and accurate data possible.[If, as a company employee, you provide personal information to us about other company personnel, you confirm that you have informed them of our identity and the purposes (as set out in this Privacy Notice) for which their information will be processed. There may be circumstances in which we would tell them where we got the information from.]

  • Information that we obtain from third party sources
    The majority of Platform Personal Data is collected from third party sources, such as official open registers, in-house research and contracted data providers. We can provide further information on these sources on request. This data pertains to the individuals involved with ambitious companies in the UK – directors, shareholders, and management. The data that we hold on these individuals includes names, verified business email addresses and telephone numbers, job titles, and details of directorships and shareholdings. We collect email addresses of employees of companies and funds from a combination of public sources and in-house research. We use an internally developed tool, which uses a variety of third-party APIs and internal data handling tools to find and verify email addresses of the key employees at tracked companies and funds. As a result of these processes, not all the emails on the CompX platform are found on publicly visible websites. We have checked that the relevant third party data providers either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

 

Who does CompX share my personal information with?

We disclose Platform Personal Data to the following categories of recipients:

  • to our Subscribing Organisations, who process Platform Personal Data in accordance with their selected usage privileges for primarily the following purposes: 

    • internal evaluation in connection with making decisions to invest in or offer services or funding opportunities to one or more companies or funds included on the CompX Platform;

    • taking the necessary steps to facilitate any subsequent funding arrangement or provision of services requested by any such company or fund or to deal with any queries by the relevant company or fund in respect of such funding arrangement or provision of services;

    • limited business-to-business direct marketing purposes subject to agreeing to certain constraints around such direct marketing approaches and to carrying out such marketing in accordance with applicable data protection and privacy laws;

    • disclosing Platform Personal Data exported from the Platform on a one-to-one basis to selected clients or prospective clients for the purposes of: (i) internal evaluation by such clients or prospective clients in connection with making decisions to invest in or offer services or funding opportunities to one or more companies or funds included on the CompX Platform; and (ii) taking the necessary steps to facilitate any subsequent funding arrangement or provision of services requested by any such company(y)(ies) or dealing with the company(y)(ies)’ queries in respect of such funding arrangement or provision of services (and on whom Subscribing Organisations will be obliged to impose restrictions in relation to use and onward disclosure of such Platform Personal Data (as per our Data Policy), including in respect of the use of email addresses).

  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

  • Third party service providers (as permitted by CompX in writing from time to time): Accountants, auditors, lawyers and other outside professional advisors; IT systems, support and hosting service providers; document and records management providers; and similar third-party vendors and outsourced service providers assisting CompX or a Subscribing Organisation in carrying out business activities.

  • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Platform Personal Data only for the purposes disclosed in this Privacy Notice;

  • to any other person with your consent to the disclosure.

 

Legal basis for processing personal information

 

The legal basis for which we process Platform Personal Data is Article 6(1)(f) GDPR – Legitimate Interests.

 

The processing of limited Platform Personal Data is necessary for the effective use of the CompX Platform as it enables Subscribing Organisations to identify shareholders, directors and management of companies on the CompX Platform and their relationships to other companies on that platform. Without being able to do so, the rich company and ecosystem data we hold on the CompX Platform has little context for it to be used in a meaningful and relevant way.

 

It’s worth noting that the platform only holds basic information such as names, job titles, business emails, shareholdings and directorships that are needed to identify the relevant individuals and organisations in the high-growth ecosystem. We are not seeking to infer further information about individuals or, for example, build risk profiles.

There are a number of legitimate interests dependent on the effective use of the CompX Platform. In particular, the CompX Platform leads to a better supported high-growth company environment by ensuring that professional organisations and government bodies are better informed in the context of investment and professional services decision-making. Company representatives whose personal information is included on the CompX Platform benefit from more relevant contact from our Subscribing Organisations. Such contact can ultimately help to support their professional role by leading to greater accessibility to investment and more informed professional services for the companies that they represent. Subscribing Organisations clearly benefit from the CompX Platform by being able to make well informed decisions in a variety of areas, from acquiring clients to informing their corporate strategy.

 

All Platform Personal Data is of a limited nature, relates to individuals in a professional capacity and is otherwise publicly available either under the Companies Act 2006 or by virtue of having been made public by the company in which the individuals are involved (usually via the company’s website). Consequently, the proposed use of the personal data is related to the individuals’ role within their company and is likely to elicit relevant contact within the reasonable expectations of those individuals i.e. from professional organisations offering services, funding opportunities and business connections to the company that the data subject represents.

 

The legitimate interests of CompX and our Subscribing Organisations are not overridden by any particular interests or fundamental rights and freedoms of the data subjects included on the CompX Platform, particularly taking into consideration the substantial potential professional benefits for the data subject, the fact that the processing of the relevant personal information is likely to align with the reasonable expectations of the data subject and the safeguards that we put in place, for example:

  • Our Data Policy imposes strict requirements on our Subscribing Organisations’ use of data subjects’ contact details to ensure that the rights and freedoms of data subjects are protected.

  • We have various other technical and organisational processes in place to reduce any risks to data subjects, such as only showing their name and company position as displayed on their company’s website or on their own professional social media page.

  • Our research team takes reasonable steps to verify Platform Personal Data and to check/update it at regular intervals.

  • Our Terms dictate that, on cancellation, all Subscribers delete Platform Personal Data exported from the CompX Platform and requires certain contractual restrictions to be placed on use of any Platform Personal Data disclosed to Subscribing Organisations’ clients.

 

How does CompX keep my personal information secure?

 

Data security is of great importance to CompX and to protect your personal information we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Platform Personal Data. For example, where appropriate we use encryption in transit and at rest, have strict and secure access controls. Our Terms and Conditions and Data Policy prescribe certain practices and procedures to which our Subscribing Organisations must adhere. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

Other

 

Your data protection rights

 

You have the following data protection rights:

  • If you wish to request access to, or correction, updating or deletion of, your personal information, you can do so at any time by contacting us.

  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. You may also update your email preferences to choose the types of emails you receive.

  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

  • You have the right to complain to a data protection authority about our collection and use of your personal information, though we would ask that you try to solve any issue with us directly first.

 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

international data transfers

 

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Specifically, our Subscribing Organisations and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

 

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for international transfers of personal information, which require all partners to protect personal information they process from the EEA in accordance with European Union data protection law.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so. Please note:

  • If you sign up for marketing emails from us we retain your personal data until you opt out of receiving such communications using the “opt-out” or “unsubscribe” link provided in such communications. In such circumstances, we retain a suppression file that contains the details necessary to ensure that we continue to respect such opt-out.

  • If you register for a demo and do not subsequently subscribe to the CompX Platform on behalf of your organization, we retain your details for 24 months after any interaction.

  • Details of an individual’s involvement with a company on the platform will remain visible for the duration that it is in the public domain.

 

Your information may be retained for longer for example, to provide you or your organisation with a service you have requested or to comply with applicable legal, tax or accounting requirements. It may also be retained for shorter periods if required to do so by applicable law. When we have no ongoing business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

updates to this privacy notice

 

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform those impacted, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.