Privacy policy

1. Introduction

Enteleki LLP (“Enteleki”, “we”, “us”) is a limited liability partnership registered in England and Wales under number OC461317, with its registered office at 10 Greycoat Place, London, England, SW1P 1SB. We are the controller of the personal data described in this privacy policy. When we refer to “personal data” under this privacy policy we mean any information which directly or indirectly identifies or otherwise relates to an individual, which is in the possession or under the control of Enteleki. Enteleki is an adviser to Guernsey Limited Partnerships (the “Funds”) which are Closed-Ended Investment Schemes.

This privacy policy explains how we collect and use personal data across our business, including when you:

• visit our website at enteleki.co or contact us through it;
• invest, or consider investing, in funds or vehicles we manage or advise, or act for an investor as a director, signatory, beneficial owner or adviser;
• work at or with a company we invest in or are considering investing in;
• deal with us as a co-investor, adviser, service provider or other business contact;
• attend one of our events or meetings; or
• apply for a job with us.

We may give you more specific information at the point we collect your data, for example in fund documents or a subscription agreement. Where that information differs from this privacy policy, the more specific terms apply. Funds and other entities we manage may act as separate controllers; where they do, they will tell you. Our services are aimed at professional and institutional audiences and are not intended for children.

2. Your legal rights

You have the right:

• to request access to, or copies of, your personal data;
• to request rectification of your personal data;
• to request that the processing of your personal data is restricted and/or object to such processing;
• to request erasure of your personal data;
• to exercise your right to data portability;
• to withdraw your consent where we rely on your consent to process data; and
• not to be subject to automated decision-making.

Please note that Enteleki does not use automated decision-making. The right to erasure is not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. Erasure of the personal data requested to fulfil the purposes described in this privacy policy may result in the inability to provide certain services to you.

3. Data security

Enteleki has implemented, and will maintain, appropriate technical and organisational measures to ensure a level of security appropriate to the risk presented by our processing of your personal data. We use these measures to protect personal data within our control against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access of it, and against other unlawful or unauthorised forms of processing. These measures include network and database security measures, access controls limited to personnel who need access, staff training and confidentiality obligations, and regular testing and review of the effectiveness of these measures. Where we use third parties to process personal data on our behalf, we require them under written contracts to implement appropriate security measures and to process personal data only on our instructions. We will notify you and any applicable regulator of a breach where we are legally required to do so.

4. Retention of personal data

We will keep your personal data for no longer than is necessary for the purposes for which it was collected and processed. To decide the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes by other means, and any applicable legal, regulatory, tax or accounting requirements. In general, we will keep your personal data for the duration of your investment and your relationship with Enteleki. After that, we will keep it for six years after you cease to be an investor in an Enteleki fund, or for any longer period required by law (for example, under anti-money laundering legislation) or needed to establish, exercise or defend legal claims within the applicable limitation period. The personal data we keep after this point will be limited to your name, contact details, investment and transaction records, and ‘know your client’ and anti-money laundering documentation. When we no longer need personal data, we will securely delete or destroy it, or anonymise it so that you can no longer be identified.

5. International transfers of personal data

We may transfer your personal data to, and store or process it in, countries outside the United Kingdom. This includes transfers to our Funds, service providers and other third parties, as outlined in Section 6 below located in the European Economic Area, the United States and other jurisdictions. If these countries’ data protection laws do not offer the same level of protection as UK law, we will make sure your personal data receives an essentially equivalent level of protection by relying on at least one of the following safeguards:

• Adequacy regulations: we may transfer your personal data to a country that the UK Government has approved, through regulations made under UK data protection law, as providing an adequate level of protection for personal data.
• Standard contractual clauses: if no adequacy regulations cover the transfer, we will put in place a contract with the recipient based on standard data protection clauses approved for use in the UK.

Contact us using the details in Section 8 if you would like more information about the safeguards we use for a particular transfer, or a copy of the relevant safeguards. We may redact commercially sensitive information from any copy we provide.

6. Data processing for different categories of individuals

The categories of individuals covered by this privacy policy are:

• “Clients” (meaning individuals who invest, or consider investing, in funds or vehicles we manage or advise, or act for an investor as a director, signatory, beneficial owner or adviser) and “Portfolio contacts” (meaning those who work at or with a company we invest in or are considering investing in);
• Visitors to the website, newsletter subscribers and attendees to events;
• Business contacts (meaning those who deal with us as a co-investor or adviser) and service providers; and
• Job applicants.

This Section 6 sets out what personal data we hold for each of the below categories of individuals, along with the sources that we obtain that personal data from, the purposes we collect the personal data for, the legal bases we rely on to collect that personal data, and the categories of recipients we may share the personal data with.

6.1 Clients and Portfolio contacts

A. What personal data we collect and how we obtain it

We hold personal data about individuals connected with Clients and Portfolio contacts. This data is provided to us by you directly (by completing subscription forms, by telephone and/or by corresponding with us), from one of our Funds, or which is provided to us by third parties acting on your behalf, from other organisations such as financial institutions or agents, or from publicly available sources. This information may include names, date of birth, contact details, tax identification numbers, bank details and financial information, place of work and job title, nationality, gender, citizenship and tax residency status, the names, contact details and signatures of authorised signatories, copies of IDs, contact details for individuals to receive correspondence and investor information, information we may receive from carrying out background checks and other checks.

It may be necessary for Enteleki to collect certain personal data which is sensitive in nature. This may be necessary, for example, to enable Enteleki and any service provider or a Fund to comply with anti-money laundering laws or other laws, regulations or policies applicable to us, any service provider and/or the Funds. It may also be required for equal opportunity and diversity monitoring purposes or to understand any health requirements you may have. This sensitive personal data includes “special categories of personal data” which includes data about health, racial or ethnic origin, as well as information about criminal convictions and offences. If we collect this type of information, we will do so with your explicit consent.

B. How we will use information about you

Your personal data may be processed by Enteleki or its service providers (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

1. to provide you with information on the Funds (including performance updates) and respond to your queries;
2. to facilitate the opening of an account in a Fund;
3. to allow us to administer and manage your holding in the Funds;
4. to update and maintain records for the Funds including with regulators;
5. to assess your application to invest including carrying out ‘know your client’ and ongoing anti-money laundering checks and related actions which Enteleki considers appropriate to meet any legal, regulatory or tax obligations imposed on the Funds or Enteleki, as required by public interest and/or legitimate business interests (including in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption and tax evasion);
6. to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions or otherwise comply with fund administrator procedures, and to detect, investigate and prevent fraud and other crimes or malpractice;
7. to retain records to assist with the subsequent anti-money laundering screening and checks by the fund administrator or any other service provider;
8. to prepare tax-related information to comply with legal, tax or regulatory obligations;
9. to carry out due diligence on a potential portfolio company and individuals connected with any portfolio company, including for legal, tax or regulatory reasons;
10. for the purpose of, or in connection with, any legal or regulatory proceedings (including prospective legal proceedings) including to obtain legal advice or to establish, exercise or defend legal rights; and
11. such other actions as are reasonably necessary to manage the activities and/or to comply with the legal obligations of the Funds and Enteleki, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for regulatory purposes and enforcing or defending the rights and/or interests of the Funds or Enteleki, in order to comply with the Funds’ or Enteleki’s legal, tax or regulatory obligations and/or to pursue legitimate interests.

C. The basis on which we process your personal data

Such processing is carried out on the following legal bases:

1. it is necessary for the pursuit of legitimate interests, and such legitimate interests are not overridden by your interests, fundamental rights or freedoms;
2. it is necessary to perform our contractual obligations to you (for example, to manage your investments, and verify the information you provide);
3. we have legal or regulatory obligations that must be discharged; and/or
4. it is necessary to establish, exercise or defend legal rights or for the purpose of legal proceedings.

Enteleki and/or the Funds do not anticipate being required to obtain your consent for the processing of your personal data. If Enteleki and/or the Funds wish to use your personal data for other purposes which do require your consent, Enteleki will contact you to request this.

D. Disclosure of your personal data

We may disclose your personal data to the Funds or third parties who are providing services to us and/or the Funds, including, but not limited to, fund administrators, financial institutions, auditors, IT service providers, event management, PR and marketing service providers, background and/or credit reference services, professional advisers such as accountants, consultants and legal or financial advisers, processors of the Funds (including printers, company secretarial services, administrators), communications service providers, document storage providers and backup and disaster recovery service providers.

6.2 Visitors to the website, newsletter subscribers and attendees of events

A. What personal data we collect and how we obtain it

We hold personal data about individuals who visit our website, subscribe to newsletters and/or may attend our events. This data is provided to us by you directly (by completing contact/subscription forms, confirming attendance at events, providing information at events, or general correspondence with us), or from third parties acting on your behalf. This information may include names, date of birth, contact details, place of work and job title, copies of IDs and dietary requirements (where you consent to provide them). We use Fathom Analytics to understand how our website is used, including page visits and traffic sources. Fathom provides website statistics without using tracking cookies. For more information about how Fathom processes analytics data, see Fathom’s data information.

B. How we will use information about you

Your personal data may be processed by Enteleki or its service providers (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

1. to send you updates on the performance of the Funds, newsletters, invitations to events and other electronic communications;
2. to respond to any enquiries you send us;
3. to comply with legal or regulatory requirements; and
4. such other actions as are necessary to manage the activities of Enteleki and/or the Funds, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) and enforcing or defending the rights and/or interests of Enteleki and/or the Funds.

C. The basis on which we process your personal data

We will use your personal data for the above purposes where it is necessary for our legitimate interests, or those of a third party, and where your interests and fundamental rights are not overridden by those interests, or where it is necessary to comply with a legal or regulatory obligation. Where we collect your personal data for the purposes of sending you newsletters and marketing, or to request dietary requirements, we will do so with your consent.

D. Disclosure of your personal data

We may disclose your personal data to the Funds or third parties who are providing services to us and/or the Funds, including but not limited to, fund administrators, IT service providers, event management, PR and marketing service providers, processors of the Funds (including printers, company secretarial services, administrators), communications service providers, document storage providers and backup and disaster recovery service providers.

6.3 Business contacts and service providers

A. What personal data we collect and how we obtain it

We hold personal data about business contacts and (current, previous and/or potential) service providers (and employees of service providers) and individuals who have provided a business card to, or have corresponded with, an employee of Enteleki. This data is provided to us by you directly (such as through general correspondence with us, providing us with your business card, or entering into service contracts together), from publicly available sources or from third parties acting on your behalf. This information may include name, date of birth, contact details, place of work and job title.

B. How we will use information about you

Your personal data may be processed by Enteleki or its service providers (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

1. to hold your personal data on our system and to contact you and respond to you (including in connection with using the services that you provide);
2. in respect of suppliers, to allow us to process payments;
3. to send you updates on the performance of the Funds, newsletters, invitations to events and other electronic marketing communications;
4. to comply with legal or regulatory requirements; and
5. such other actions as are reasonably necessary to manage the activities of Enteleki and/or the Funds, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) and enforcing or defending the rights or interests of Enteleki and/or the Funds.

C. The basis on which we process your personal data

Such processing is carried out on the following legal bases:

1. it is necessary for the pursuit of legitimate interests, and such legitimate interests are not overridden by your interests, fundamental rights or freedoms;
2. it is necessary to perform our contractual obligations to you (for example, if we have a services agreement with you);
3. we have legal or regulatory obligations that must be discharged; and/or
4. it is necessary to establish, exercise or defend legal rights or for the purpose of legal proceedings.

Where we collect your personal data for the purposes of sending you newsletters and marketing, or to request dietary requirements, we will do so with your consent.

D. Disclosure of your personal data

We may disclose your personal data to the Funds or third parties who are providing services to us and/or the Funds, including but not limited to, fund administrators, IT service providers, event management, PR and marketing service providers, processors of the Funds (including printers, company secretarial services, administrators), communications service providers, document storage providers and backup and disaster recovery service providers.

6.4 Job applicants

A. What personal data we collect and how we obtain it

We hold personal data about applicants for jobs or placements, and in relation to potential workers and contractors. This data is provided to us by you directly (such as through an application), from publicly available sources including Companies House records and social media (such as LinkedIn), or from third parties such as recruitment agencies, background check providers, credit reference agencies, Disclosure and Barring Service in respect of criminal convictions, or your named referees. The kind of information we may hold about you in connection with an application includes name, marital status, address and postcode, telephone number, personal email address, date of birth, gender, proof of ID (including copies of passport photo page and utility bills), residency status, employment history, qualifications and other information contained in your CV and cover letter or email, information obtained from social media, details of referees and references, qualifications (including copy certificates of academic and professional qualifications), screening questionnaire for verification by an outsourced firm and summary of findings, and information provided to us during telephone calls, interviews and/or meetings with you.

It may be necessary for Enteleki to collect certain personal data which is sensitive in nature. This may be necessary, for example, to enable Enteleki to undertake criminal conviction checks, to understand any health requirements you have for the workplace or for equal opportunity and diversity monitoring. This sensitive personal data includes “special categories of personal data” which includes data about health, racial or ethnic origin, as well as information about criminal convictions and offences. If we collect this type of information, we will do so with your explicit consent or where it is necessary to meet our obligations as an employer.

B. How we will use information about you

Your personal data may be processed by Enteleki or its service providers (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

1. to assess your skills and qualifications;
2. to carry out background and reference checks, where applicable;
3. to communicate with you about the recruitment process;
4. to keep records related to our hiring processes;
5. to comply with legal or regulatory requirements; and
6. such other actions as are reasonably necessary to manage our activities, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for regulatory purposes and enforcing or defending Enteleki’s rights and interests, to comply with our legal obligations and/or to pursue our legitimate interests.

Once we receive your CV and/or cover letter, we may process that information to decide whether Enteleki has any suitable vacancies and if you meet the basic requirements to be shortlisted for a role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the work. If we decide to offer you the work, we will then take up references and we may carry out a criminal record check or other checks before confirming your appointment. If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

C. The basis on which we process your personal data

We process this personal data on the basis that it is necessary for our legitimate interests (in order to decide whether to appoint you to work for us) or those of a third party, and where your interests and fundamental rights are not overridden by those interests, or where it is necessary to comply with a legal or regulatory obligation. Where we have collected “special categories of personal data” we will do so with your explicit consent or where it is necessary to meet our obligations as an employer.

D. Disclosure of your personal data

We may disclose your personal data to the Funds or third parties who are providing services to us and/or the Funds, including but not limited to, recruitment agencies, background check providers, credit reference agencies, Disclosure and Barring Service in respect of criminal convictions, your named referees, IT service providers, processors of the Funds (including printers, company secretarial services, administrators), communications service providers, document storage providers and backup and disaster recovery service providers.

7. Changes to this policy

We may update this privacy policy from time to time and will communicate such updates when they occur.

8. Further information and complaints

If you have any concerns about the way in which Enteleki uses your personal data, please contact us at legal@enteleki.co or at our registered address:

If you want to complain, you may also contact the data protection authority in your country. In the United Kingdom, this is the Information Commission, which can be contacted at the address below:

Helpline number: 0303 123 1113
Website: www.ico.org.uk