Your Privacy

Privacy Notice

Who We Are

Keystone Impact Investments Limited (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

Keystone Impact Investment Limited registered office is at 41 Lothbury, City of London, London. EC2R 7HF and we are a company registered in England and Wales under company number 12562834 . We are registered on the Information Commissioner’s Office Register; registration number ICO:00015461791 , and act as the data controller when processing your data. Our designated Data Protection Officer/Appointed Person is Leigh Hyldon, who can be contacted at lh@ki.investments.

Information That We Collect

Keystone Impact Investments Limited processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We may collect and use the following information:

  • Internal Protocol (IP) address. This information is collected passively when you use our website or client portal.
  • Identity details. This information is collected directly from you when you complete our forms on our website or provide information directly to us. This includes:
  • Name, address and contact details including but not limited to phone number and email address
  • Date of birth and gender
  • Demographic information such as preferences and interests
  • Professional and employment details
  • ID and/or passport number
  • National/tax identification number
  • Any other similar information.

When you visit our site, we, or third parties on our behalf, automatically collect and store information about your device and your activities.

This information could include (a) your computer or other device’s unique ID number; (b) technical information about your device such as type of device, web browser or operating system; (c) your preferences and settings such as time zone and language; and (d) statistical data about your browsing actions and patterns. We collect this information using cookies in accordance with the Cookie section of this policy and we use the information we collect on an anonymous basis to improve our website, our events and the services we provide, and for analytical and research purposes.

We collect information in the below ways: –

  • Online forms
  • Website 
  • Investment Portal

Marketing Communications

If you opt in to receive marketing communications from us you consent to the processing of your data to send you such communications, which may include newsletters, blog posts, surveys and information about new events. We retain a record of your consent.

You can choose to no longer receive marketing communications by contacting us at hi@ki.investment  or clicking unsubscribe from a marketing email. We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer wish to receive marketing emails from us.

We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and/or marketing, you are free to withdraw this consent at any time.

We will only use your personal data on relevant lawful grounds as permitted by the EU General Data Protection Regulation and Privacy of Electronic Communication Regulation.

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • To identify you
  • To communicate with you
  • To comply with our legal and regulatory obligations
  • Internal record keeping
  • We may use the information to improve our products and services
  • We may periodically send emails about articles or other information which we think you may find interesting using the email address which you have provided

From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests

Who do we share your data with?

We may share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers, event providers, email communication providers, IT service providers, accountants, auditors and lawyers.

Under certain circumstances we may have to disclose your personal data under applicable laws and/or regulations, for example, as part of anti-money laundering processes or protect a third party’s rights, property, or safety.

We may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company

Your Rights

You have the right to access any personal information that Keystone Impact Investments Limited processes about you and to request information about:

  • What personal data we hold about you
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified. 

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. 

We require all third party processors to take appropriate steps to protect your information and only use your information for the purposes of performing the relevant services. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

Keystone Impact Investments uses third parties to provide certain services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

Security

Keystone Impact Investments Limited takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:

  • 3rd Party Managed Services Provider
  • Network Monitoring and Virus protection
  • Restricted access Virtual Desktops
  • Encryption and End point protection
  • Secured Webportal 

However, you acknowledge that no system can be completely secure.

Transfers Outside the EU 

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. Some or all of your personal data may be stored or transferred outside of the EU for any reason, including for example, if our email server is located outside the Eu or if any of our service provider or their servers are based outside of the EU. We shall only transfer your personal data to oragnisation that have provided adequate safeguards in respect of your personal date.

Cookies. 

A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any personal data about you, such as your name and/or address. These files are then used by websites to identify when users revisit that website.

Our website  cookies so that we can recognise you when you return and personalise your settings and preferences. Most browsers are initially set up to accept cookies. You can change your browser settings either to notify you when you have received a cookie, or to refuse to accept cookies.

We also use Google Analytics to monitor how our website is used. Google Analytics collects information anonymously and generates reports detailing information such as the number of visits to the website, where visitors generally came from, how long they stayed on site, and which pages they visited. Google Analytics places several persistent cookies on your computer’s hard drive. These do not collect any personal data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent Google Analytics from logging your visits.

Consequences of Not Providing Your Data 

You are not obligated to provide your personal information to Keystone Impact Investments Limited, however, as this information is required for us to provide you with our services/deliver your products/legitimate interests, we will not be able to offer some/all our services without it.

How Long We Keep Your Data

As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate. 

We use the legitimate interests’ legal basis for processing [insert what data/purpose for processing is based on legitimate interests] and have identified that our interests are [state the legitimate interests that you are relying on]. 

How Long We Keep Your Data

Keystone Impact Investments Limited only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.

We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. 

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Keystone Impact Investments Limited will occasionally send you products, services and promotions by email, Social media, SMS or post that have been identified as being beneficial to our customers and in our interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time.

Lodging A Complaint

Keystone Impact Investments Limited only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint

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