1. INTRODUCTION

Regionally Limited (“Regionally”) respects the privacy of every individual whose Personal Data it handles. This Privacy Policy explains how Regionally collects, stores and uses that Personal Data and sets out our approach to the UK General Data Protection Regulation as defined by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (“GDPR”) and applicable UK laws such as the Data Protection Act 2018 (“DPA”).

This policy may be amended or updated from time to time and revised versions will be shown on our website. It is your responsibility to check for the most recent version of this policy.

It is important that you read this Privacy Policy together with any other policy or notice 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.

For the avoidance of doubt, our website is not intended for children under the age of 18 years old. We do not knowingly collect data relating to children individuals. If you become aware of any data we have collected from children under the age of 18, please contact us using the details below.

2. WHO WE ARE AND HOW TO CONTACT US

Regionally Limited is a limited company based in the United Kingdom, under company No. 12601561, and an Appointed Representative of The Fund Incubator Limited which is authorised and regulated by the Financial Conduct Authority (FRN 208716). Our registered office is at 34 High Street, Aldridge, Walsall, England, WS9 8LZ.

“We”, “us” or “our” means Regionally. “Site” (which includes any platform offered through or via the site, where the context requires or admits) is www.regionally.com. This site is owned and operated by Regionally, who is the data controller for the purpose of the DPA and the GDPR.

We are registered with the Information Commissioner’s Office as a data controller under number ZA775694.

To contact us, please email support@regionally.com or telephone us on 0330 332 4808.

3. THIRD PARTY LINKS

Please note that our website and platforms may contain links to third party websites/platforms, plug-ins, and applications which are provided for your convenience. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or their handling of your data. When you leave our website or platform, we recommend that you check the privacy and security policies and procedures of each and every other website/ platform that you visit.

4. THE DATA WE COLLECT ABOUT YOU

Personal Data refers to 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, last name, username or similar identifier, title, date of birth and gender.

• Contact Data includes billing address, email address(es) and telephone number(s).

• Financial Data includes details of investments made or proposed via our platform (which may include bank account details).

• Transaction Data includes details about investments made or proposed via our platform, payments to you by third parties or their advisors and from you to us or third parties and details of services you have purchased from us.

• Technical Data includes Internet Protocol (IP) address, your login data, 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 or our platform.

• Profile Data includes your username and password, your transactions, your interests, preferences, experience, feedback and survey responses.

• Usage Data includes information about how you use our website or platform, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect your Personal Data about you from publicly available sources for the purposes of completing our Anti-Money Laundering (AML) checks and Know Your Customer (KYC) checks that we are legally required to carry out.

We also collect, use and share Aggregated Data (such as statistical or demographic data) for any purpose. Aggregated Data includes data collected and reported at the group, cohort, or institutional level that is aggregated using protocols that are effective for preserving the anonymity of each individual included in the data. For example, we may aggregate profile data to assess interest in our service. Aggregated Data could be derived from your Personal Data but is not itself considered Personal Data in law, as this data will not directly or indirectly reveal your identity.

Regionally does not collect any special categories of Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) without your consent. We may collect information about criminal convictions and offences for the purposes of KYC and AML checks conducted by third- party providers. We may also share that information with third parties for verification and checking purposes. We only collect this information with your consent. You understand that your refusal to provide consent for us to conduct the necessary KYC and AML checks, may result in delays or in the rejection of your application to the platform. It is your responsibility to ensure that you have the appropriate internal and external policies, and lawful bases, to disclose or to consent to the processing by Regionally of Personal Data of your officers or employees (where applicable).

5. NOTICE OF DISQUALIFICATION

In some cases, we will not be able to deal with you further without receiving certain information, such as KYC information. Where we need to collect Personal Data by law or pursuant to or for the purpose of any contract we have with you, and you fail to provide that data upon request, we may not be able to perform the contract we have or are trying to enter into with you or progress or accept your application for access to or fundraising across our platform(s). In this case, we may have to cancel or suspend our services or reject your application. In such circumstances we will explain this to you including the possible consequences of not providing particular information.

6. LAWFUL BASIS FOR PROCESSING

We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. The valid lawful bases we most commonly rely on are as follows:

• Contractual Obligation – This applies where processing is necessary to comply with our obligations arising out of a contract or proposed contract with you, for example, taking payment or sharing information with a third party as part of our service.

• Legitimate Interest – This applies where processing is necessary for our legitimate interests or those of a third party as long as your interests and fundamental rights do not override those interests.

• Legal Obligation – We will process your Personal Data if we need to do so to comply with a legal obligation.

• Consent – We will seek to obtain your consent to process your data outside our Contractual Obligations unless we have identified a legitimate interest or legal obligation.

7. 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, Contact and Financial Data by filling in forms or by corresponding with us. This includes Personal Data you provide when you:

  • Create or apply for an account on our website.

  • Use our services, including our platform.

  • Request marketing to be sent to you.

  • Enter a promotion or survey.

  • Give us feedback or contact us.

• Automated Technologies or Interactions. As you interact with our website or platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

• Third Parties or Publicly Available Sources. We may receive Personal Data about you from various third parties, such as other users of our website/services or advertising networks, and public sources, including analytics providers (such as Google) or search information providers (such as Companies House).

8. BUSINESS CONTACTS

As part of its day to day operations, Regionally meets large numbers of business contacts at meetings and receives emails about investment opportunities. It is likely to receive and store Personal Data relating to those it meets.

If you have had contact with Regionally, for example through emailing us or meeting a colleague, it is likely that we will want to make a note of that email or meeting and may store limited amounts of Personal Data relating to you, such as your name, job title, employer organisation and contact details.

We will process this Personal Data for the purposes of:

• Maintaining a record of contacts.

• Providing periodic business updates.

• Drawing to your attention working opportunities which may be of mutual benefit to us as described below.

• Organising meetings with you.

The Personal Data we hold about business contacts may be shared with:

• Professional advisors.

• Companies who process Personal Data on our behalf or provide cloud-based products such as Microsoft 365.

The legal basis for processing such Personal Data about you is that such processing is necessary for our legitimate interests in running and promoting our business.

9. PERSONAL DATA OF SUPPLIERS, REGIONAL ASSOCIATES, REGIONAL CORPORATE ADVISORS AND REGIONAL PARTNERS

As part of its day to day operations Regionally is likely to receive and store Personal Data to enable it to buy office and other supplies or engage with professional advisors.

If you are a supplier to Regionally, associate of Regionally, a professional advisor or professional partner in the Regionally service or a professional advisor to an investor or investee using our platform, we will capture and use limited amounts of Personal Data relating to you, including your name, job title, qualifications, employer organisation and contact details. We will store this Personal Data for the purposes of administering and maintaining records of services or advice we have received and commissioning further services.

The Personal Data we hold about suppliers and professional advisors may be shared with:

• Other professional advisors.

• Companies who process Personal Data on our behalf or provide cloud-based products such as Microsoft 365.

We process information in this way because it is necessary to:

• Perform a contract to which you may be a party;

• Comply with a legal or regulatory obligation; and/or

• Protect our legitimate interests in running and promoting our business.

10.   PERSONAL DATA COLLECTED DURING A TRANSACTION

Regionally is likely to receive and store Personal Data as part of its investment facilitation process.

If you are involved in a transaction that Regionally (potentially) facilitates, we may store Personal Data relating to you. This might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), banking details, and results of other due diligence carried out.

We collect and store this information for the purposes of:

• Facilitating transactions.

• Assisting in monitoring of investments, once made.

• Maintaining records of investments.

• Meeting regulatory and legal obligations e.g. KYC checks.

• Safeguarding our legal rights and interests.

• Providing periodic business updates to the platform.

The Personal Data we hold about investors or the members of a management team may be shared with:

• Professional advisors, such as accountants, lawyers or other consultants.

• Financial intermediaries.

• Credit and other reference agencies.

• Other persons who have an interest or involvement in, or who are considering an interest or involvement in, a Regionally transaction, including co-investors.

• Companies who process Personal Data on our behalf or provide cloud-based products such as Microsoft 365.

We process information in this way because it is necessary to:

• Facilitate performance of a contract to which you may be a party.

• Comply with a legal or regulatory obligation; and/or

• Protect our legitimate interests in running and promoting our business.

11.   PERSONAL DATA COLLECTED DURING VISITS TO OUR WEBSITE

When you interact with our website and/or platforms, we may also automatically collect the following information about your visit. This is primarily to help us better understand how people use our website and/or platforms to enable us to create better content and more relevant communications:

• How you have reached our website and/or platform and the Internet Protocol (IP) address you have used.

• Your browser type, versions and plug-ins, and your operating system.

• Your journey through our platform, including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information.

• What content you like or share.

• Information collected in any forms you complete or contained in any request or contact made by you via the website (for example by you contacting us by completing a contact form on our website).

12.   KEEPING YOU INFORMED

We wish to build a long-term relationship with you and would like to use Personal Data that we hold to send you updates about our business, activities and opportunities to work together. We would usually do this by email and/or post. You can opt out of receiving updates at any time by contacting us using the information below, or by clicking the “unsubscribe” link in any email that you receive.

13.   NEWS, OFFERS AND OPPORTUNITIES FROM US (WHICH WE PROVIDE ONLY WITH YOUR CONSENT)

We may, from time to time, participate in Facebook’s ‘Custom Audience’ service. This service enables Regionally to display to you personalised advertisements when you visit Facebook’s social media platforms. It works by converting your email address to a unique number that Facebook uses to match to unique numbers that Facebook generates from email addresses of its users. Where we use Facebook Custom Audiences, we will only share your Personal Data with Facebook if you have consented to receive marketing from us. If you have given us your consent, you can change your mind at any time by contacting us using the information below or by clicking the “unsubscribe” link in any email that you receive.

14.   INTERNATIONAL TRANSFERS OF PERSONAL DATA

Regionally is based in the United Kingdom and your data is stored by us and our processors in the UK, EEA or in a country where an adequacy decision has been made by the European Data Protection Board (EDPB).

Where we transfer your Personal Data outside of the EEA, we will ensure that all appropriate technological and organizational measures are in place to provide your data with the levels of protection as required under the Data Protection Laws.

15.   RETENTION OF PERSONAL DATA

The period for which Regionally will retain Personal Data will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

Otherwise, 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 more than six years 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.

16.   YOUR RIGHTS TO SEE AND CORRECT DATA

As a Data Subject you have a number of important rights:

• Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it, or you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

• Object to processing of your Personal Data where we are relying on a legitimate interest or those of a third party) and there is something about your particular situation which makes you want to object on this ground, as you feel it impacts on your fundamental rights. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request access to your Personal Data This enables you to ask us to suspend the processing of your Personal Data: if you want us to establish the data’s accuracy; where our use of the data is unlawful, but you do not want us to erase it; where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

If you wish to exercise the right of making a data subject access request, please contact us in whatever format you deem appropriate using the contact details below or by calling 0330 332 4808.

To exercise any other rights, in the first instance, please email support@regionally.com and request to speak to our data privacy manager. Please note that all rights are subject to some statutory qualifications.

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.

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

17.   SECURITY

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. In addition, we will ensure anyone acting under our authority who has access to your Personal Data will only process your Personal Data on our instructions (unless required to do so by law) and are subject to a duty of confidentiality.

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.

When you submit your data to us on the website or platform, we use industry standard Secure Sockets Layer (SSL) encryption technology to protect your information. In addition, we have security procedures in place to protect our paper-based systems and computerised databases from loss and misuse, and only allow access to them when it is absolutely necessary to do so, and then under strict guidelines as to what use may be made of the Personal Data contained within them.

Where a password or other security information is required to access certain areas of our website or platform, you are responsible for keeping your password or other security information secure and confidential. Please do not share your password with or disclose it to any other person.

18.   WHO WE SHARE YOUR PERSONAL DATA WITH

Regionally works with a variety of carefully selected companies that we share Personal Data with as part of its investment facilitation process.

We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you.

Please see the list below which sets out the categories of recipients of Personal Data:

• Website Developers.

• Website Designer.

• Online payment providers.

• Banks.

• IT Support Services.

• Email Provider.

• Identification and verification providers.

• Professional advisors, including solicitors, accountants, IFA’s.

19.     QUESTIONS AND FURTHER INFORMATION

If you have any questions about this Privacy Policy or about your Personal Data please email support@regionally.com and request to speak to our data privacy manager or write to us at the following address:

34 High Street,
Aldridge,
Walsall,
England,
WS9 8LZ.

20.   WHERE TO MAKE A COMPLAINT

You have the right to complain at any time to the Information Commissioner’s Office at the following address:

Information Commissioner’s Office Wycliffe House
Water Lane Wilmslow 
Cheshire
SK9 5AF

You can also contact the Information Commissioner’s Office using their online form: https://ico.org.uk/global/contact-us/email/

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.