Privacy Policy
Invest2Scale respects your privacy and is committed to protecting your personal data. This privacy policy will let you understand how we collect, process and look after your personal data when you visit our website (regardless of where you visit it from) and from your use of this website, including any data you may provide when you contact us. It also gives you information on how Invest2Scale processes your personal data provided when you register to attend or attend our events.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Invest2Scale collects and processes your personal data through your attendance at our events, including any data you may provide when you register to attend our events or communicate with us.
Our events are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Joint Controllers
MBM Commercial LLP, Chiene + Tait LLP, Eden Scott Ltd and Linc Scotland are joint controllers and responsible for the personal data they collect about you (collectively referred to as “Invest2Scale”, "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entities: MBM Commercial LLP, Chiene + Tait LLP, Eden Scott Ltd and Linc Scotland
Email address: hello@invest2scale.com
Postal address: Invest2Scale, c/o Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, United Kingdom, EH4 2HS
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in September 2022.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name and last name.
Contact Data includes email address.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your Eventbrite user ID, preferences, feedback and survey responses.
Usage Data includes information about how you use our products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
register to attend our event and attend our event; or
give us feedback or contact us.
Third parties. We do not intentionally collect or receive personal data about you from third parties.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
At events, we may want to take images (still photographs or moving images) for the purpose of publicising the work of Invest2Scale. If this is the case, we will make you aware of this on the website relating to the event. We will display notices at the event to inform you that filming or photography is taking place, and our staff will advise you what to do if you do not wish to be in the images. Where images are of groups of people and there is a minimal impact on privacy, we rely on legitimate interests to take and use images. Where you are the focus of an image and are clearly identifiable in the image, then we will ask for your consent to use the image
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Marketing
You may receive marketing communications from us if you (i) have requested marketing communications from us, (ii) have consented to marketing communications from us, or (iii) have registered an interest in and/or attended an event run by us, and we have assessed that it is in our legitimate interest to send you relevant marketing information that we think you would be interested in, in order to continue to run and grow our business.
If relying on legitimate interest we will always ensure that our interest in doing so has been balanced against any potential impact on you (both positive and negative) and your rights before we process your personal data. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
In each case, we will not send any marketing communications if you have asked us to stop contacting you or opted out of receiving that marketing.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
External Third Parties
Service providers such as AWS and Eventbrite acting as processors based in the UK who provide IT and system administration services.
Event organisers, such as Dovecot Studios, for the purpose of managing your attendance at that event and managing any specific requirements such as access or catering needs.
Professional advisers, acting as processors, including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
Our event sponsors, who may contact your business about their products and services.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Attendee List
We will produce a list of attendees for any events we run and this will be made available to other attendees. The information included on this will be limited to your name, company and job title. You can notify us at any time that you do not want your information to be included on this list.
6. International transfers
We do not transfer your personal data outside the EEA.
7. Data security
The integrity of your personal data is of utmost importance to us. With that in mind, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under data protection legislation, you have a number of rights in relation to your personal data, including the right to:
withdraw consent, at any time, where that is the lawful basis of our processing;
access your personal data and obtain a copy, free of charge;
rectify inaccuracies in personal data that we hold about you;
erasure, that is have your details removed from systems that we use to process your personal data;
restrict the processing in certain ways;
obtain a portable copy of data you have given to us in a commonly used electronic form; and
object to certain processing of your personal data by us.
Your ability to exercise these rights will vary and depend on the lawful basis under which the processing is being carried out.
If you wish to exercise any of the rights set out above or have any questions on these rights, please contact us on hello@invest2scale.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
If you wish to make a complaint about how we have handled your personal data, you can contact us at hello@invest2scale.com.
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you also have the right to complain to the Information Commissioner’s Office.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as an attendee of our event
(a) Identity
(b) Contact
Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, attendee relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)