Privacy Policy

Last updated: 1 August 2023

Welcome to Excelerator Partners’ privacy policy.

We are Excelerator Partners Ltd (“Excelerator Partners”, “we” or “us”). Our company registration no. is NI699374 and our registered address is at 6b Upper Water Street, Newry, County Down, Northern Ireland, BT34 1DJ.

We are the controller of the personal information we process about you. We are registered with the Information Commissioner’s Office (ICO): ZB569197.

This privacy policy applies to individuals who visit our website at www.exceleratorpartners.com (the “Website”) or mobile applications (“Apps”), or engage with us via our Website, Apps or social media accounts. It also applies to all our business contacts, including clients, contractors, suppliers, employees, candidates and job applicants, and investors. 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 information about you so that you are fully aware of how and why we are using your information.

Excelerator Partners Ltd – Privacy Statement

At Excelerator Partners, data protection is of extreme importance to us. We believe in a responsible and pro-active approach when dealing with personal information.

This policy sets out how and why we collect, store, use and share personal information, our dedication to protect it, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a question, comment or complaint.

If you have any questions about how we use your personal information, please contact: info@exceleratorpartners.com.

1. The types of personal information we collect

We collect and use the following information about you:

• Identity Data including your gender, job title, first name and surname.
• Contact Data including your address, email address, and telephone numbers.
• Financial Data including your payment and bank account details.
• Transactional Data including information about our business dealings, transactions and interactions with you.
• Technical Data including your IP address, device type, browser type and broad geographical location when you visit or engage with our Website, Apps or social media accounts.
• Usage Data including information about how you use our Website and Apps.
• Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.
• Recruitment Data including your CV, information held on your social media accounts such as LinkedIn, data relating to your performance during the application process and information provided by recruitment agencies, third party references, health information to make reasonable adjustments, information from anti-money laundering and sanctions checks, information from criminal records checks, any relevant recruitment test results.
• Employment Data including job title, attendance and performance information, salary and pay information, pension information, date of birth, tax codes, national insurance number, right to work documentation, health information to make reasonable adjustments, information from anti-money laundering and sanctions checks, information from criminal records checks.
• Any additional personal information you provide when you engage with us.

We will indicate where any personal information we have requested is mandatory. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances this may mean we are unable to provide you with a certain service.

2. If you fail to provide personal information

Where we need to collect personal information by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. How we use your personal information

The personal information we process depends on our relationship with you as follows:

Individual	Data Processed
Visitors / users of our Website, Apps and social media accounts	Identity Data Contact Data Transactional Data Technical Data Usage Data Marketing and Communications Data
Client and supplier contacts	Identity Data Contact Data Transactional Data Marketing and Communications Data
Candidates and Job applicants	Identity Data Contact Data Transactional Data Marketing and Communications Data Recruitment Data
Employees and contractors	Identity Data Contact Data Financial Data Transactional Data Marketing and Communications Data Recruitment Data Employment Data
Investors	Identity Data Contact Data Financial Data Transactional Data Marketing and Communications Data

We use personal information relating to you that we collect, or that you provide to us, for the following purposes:

• So you can register with us and set up your accounts with us;
• To engage with you and to provide our products and services;
• For processing your application to work for us (including to onboard our talent pool, consultants, and contractors), improving the application process, and for carrying out pre-employment checks;
• To employ and engage our employees and contractors;
• For managing and administering our investor relationships;
• To deliver, manage and improve our Website and Apps;
• To provide you with marketing information related to our services which we believe may be of interest to you;
• To comply with the law;
• To perform our day-to-day business activities.

4. Lawful basis for processing

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case, the legal basis will be one of the following.

• Consent. This applies where for example we obtain your consent to certain marketing communications.
• Our legitimate business interests. Where it is necessary for us to carry out the services or perform our business activities, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
• Performance of an agreement with you. For example:
  • where you have provided your information in order to receive details in relation to our products and services;
  • to provide customer support and ensure we provide a good level of customer service;
  • to employ or engage you as an employee or contractor of our business.
• Compliance with the law. Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

5. How we share your personal information with third-parties

We may share your personal information within our group of companies for the purposes set out in this privacy policy.

We may share your personal information with our suppliers, business partners and service providers, where they are helping us to market, advertise or supply our services, for them to use for the purposes set out in this privacy policy. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

If you are an employee or contractor, we may share your personal information with our clients as part of our efforts to win work and deliver our services to them.

We may disclose your personal information to other third parties in the following cases:

• If we or substantially all of our assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
• If we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request; or
• To protect our business and enforce our rights (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

6. Marketing

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

We are committed to protecting and respecting your personal information. We will not sell or rent your personal information to any third parties.

You can ask us to stop sending you marketing messages by contacting us at any time.

7. Cookies

Our Website and Apps use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our Website and Apps and also allows us to improve them. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our Website and Apps. They include, for example, cookies that enable you to log into secure areas of our Website and Apps, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Website and Apps when they are using them. This helps us to improve the way our Website and Apps work, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our Website and Apps. This enables us to personalise our content for you, greet you by name and remember your preferences.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.

We do not share the information collected by the cookies with any third parties.

8. Where we store your personal information

In the event that we transfer your personal information internationally, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy policy. In these cases, we rely on approved data transfer mechanisms (such as the EU and UK “Standard Contractual Clauses”) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

9. Your Rights

We take your privacy very seriously and wants you to be aware of your tights, as follows:

• you have the right to request (i) confirmation of whether we process your personal information and (ii) access to a copy of the personal information retained;
• you have the right to request proper rectification or removal of your personal information or restriction of the processing of your personal information;
• where processing of your personal information is either based on your consent or necessary for the performance of an agreement with you and processing is carried out by automated means, you have the right to receive the personal information concerning you in a structured, commonly used and machine-readable format or to have your personal information transmitted directly to another company, where technically feasible (data portability);
• where the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time without impact to any data processing activities that have taken place before such withdrawal;
• you have the right not to be subject to any decisions based solely on automated processing, including profiling, which has legal or other similarly significantly effects on you unless we have your consent, it is authorised by law or it is necessary for the performance of an agreement;
• you have the right to object to processing if we are processing your personal information on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal information, and to balance our legitimate interests in carrying out the processing and your objection to this processing;
• the right to object to processing your personal information for direct marketing purposes; and
• the right to lodge complaints before the competent data protection regulator, the UK Information Commissioner’s Office, and you may do so at https://ico.org.uk/make-a-complaint/.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. This is a security measure to ensure that personal information 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.

Please send us an email at info@exceleratorpartners.com if you would like to exercise any of your rights.

10. Data Security

We have put in place appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We take steps to ensure that your personal information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, for example, by encryption or by using pseudonymisation, we cannot guarantee the security of your information transmitted via the internet; any transmission is at your own risk.

We have appropriate technical and organizational measures designed to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other individuals. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

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.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

11. How long we keep your personal information

We retain your information for as long as it is necessary to provide you with the service we supply to you or to fulfil our obligations to you. Where we do not need your information in order to provide the service or to fulfil our obligations to you, we retain it only for so long as we have a legitimate business purpose in keeping such data.

However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After our agreement with you expires or terminates, or our relationship with you has otherwise ended, we may store your information in an aggregated and anonymised format.

12. Information relating to children

The services provided by Excelerator Partners are not directed at children under the age of 18. If you believe that we have personal information about or collected from a child under the relevant age, please contact us at info@exceleratorpartners.com.

13. Queries and complaints

In the event that you wish to discuss, or make a complaint about, how we process your personal information, please contact us in the first instance at info@exceleratorpartners.com and we will endeavour to deal with your request as soon as possible.

This is without prejudice to your right to submit you complaint to the relevant data protection authority.

14. Changes

We will generally notify you of any material changes to this policy, through a notice provided via the Website and Apps or otherwise supplied to you. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued engagement with us after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop your engagement with us.