Data Privacy Notice
SV Health Managers LLP, SV Health Investors LLP and SV Health Investors UK Limited (jointly referred to as “SV Health UK”) regarding retention of contact information in respect of potential scientific advisors, potential investors, directors and employees in portfolio companies and SV Health UK.
The Data Protection Legislation (meaning any law applicable from time to time relating to the processing of personal data and/or privacy, as in force at the date of this Agreement or as re-enacted, applied, amended, superseded, repealed or consolidated, including without limitation, the General Data Protection Regulation (EU) 2016/679, and the Privacy and Electronic Communications (EC Directive) Regulations 2003, in each case including any legally binding regulations, direction and orders issued from time to time under or in connection with any such law) requires SV Health UK to provide its investors with information about how it uses and processes their personal data (meaning information relating to a living individual who can be identified from that information), including any transfer of such personal data to countries outside the European Economic Area (“EEA“).
This Data Privacy Statement sets out how SV Health UK uses your personal data. Our Data Protection representative can be contacted at firstname.lastname@example.org or by writing to us at 71 Kingsway, London WC2B 6ST.
Types of personal data collected and used by SV Health UK
Most of the personal data held by SV Health UK will have been collected when you first contacted SV Health UK or an affiliated organisation in the wider SV Health group.
The personal data held by SV Health UK may include:
- Full name and personal details including contact information (e.g. home address and address history, email address, home and mobile phone numbers); and
- Any other personal data collected or received by SV Health UK from time to time.
We will always inform you if providing some personal data is optional.
The legal basis and purposes for using your personal data
SV Health UK may process your personal data on the basis of one or more of the following:
- as necessary for the performance of a contract;
- as necessary in accordance with SV Health UK’s legitimate interests;
- as necessary to comply with a legal obligation; and/or
- where you provide express, freely given consent.
The purposes for using your personal data
We may process your personal data in order to (in reliance on one or more of the above legal bases): (a) carry out our obligations arising from any contracts; (b) provide you with information, products or services that you request from us and correspond with you; (c) provide support to you in respect of our services; (d) comply with our legal and regulatory obligations; (e) establish and defend legal rights; and (f) for our internal business processes.
Sharing your personal data
Subject to applicable Data Protection Legislation and where it is necessary for the performance of our contract with you or for our internal business processes, SV Health UK may share your personal information with third parties such as our suppliers, contractors, affiliates, professional advisers, regulatory bodies, auditors, technology providers, third party partners, any duly authorised agents or affiliates of the foregoing, and the employees, directors, consultants, officers, advisers, suppliers, investors, distributors, customers and agents of any SV Health UK companies, including but not limited to SV Health Investors LLC.
In processing your personal data, it will sometimes be necessary for us to transfer your personal data from one jurisdiction to another. For example, it may be necessary for us to transfer your personal data from within the EEA to outside the EEA, to SV Health Investors LLC, organisations associated with SV Health Investors LLC, or staff operating outside the EEA who work for us or for one of our suppliers or group companies. Where this is the case, we will take steps to comply with applicable Data Protection Legislation with regard to such transfer (and we will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Data Privacy Statement). Where any such cross-border transfer is undertaken, such steps may include: (i) incorporating certain standard terms into the contracts that govern the data transfer of data; or (ii) or only transferring data to countries that have the prior approval of the appropriate regulator in a particular jurisdiction. For the avoidance of doubt, in the event that the UK is no longer a part of the EEA, references in this paragraph to the EEA shall mean the EEA and the UK.
Retention and accuracy of personal data
SV Health UK will keep personal data for as long as we reasonably require and, in any event, in line with the provisions of the Data Protection Legislation.
You should ensure that your personal data is kept up to date and is accurate. If you believe that any of your personal data is incorrect, please inform our Data Protection representative, who will take all reasonable steps to amend inaccurate or out-of-date data.
Your rights under data protection law
Please note that pursuant to the Data Protection Legislation you have the following rights:
- The right to be informed about the processing of your personal data;
- The right to have any personal data corrected if it is inaccurate and the right to have incomplete data completed;
- The right to object to the processing of your personal data in certain circumstances;
- The right to restrict processing of your personal data in certain circumstances;
- The right to request access to your personal data together with information about how it is processed by SV Health UK;
- The right to have your personal data erased where there is no longer a legal ground for us to hold it;
- The right to move, copy or transfer your personal data in certain circumstances – “data portability”; and
- The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Your right to complain
If you have any questions or concerns about how your personal data is used or held, in the first instance you should contact our Data Protection representative using the contact details set out above. Should you wish to take any complaints further you have the right to complain to the Information Commissioner’s Office (“ICO”). The ICO has enforcement powers and can investigate compliance with data protection law.
Effective as of May 24, 2018