PRIVACY AND COOKIES
ROYCIAN PRIVACY AND COOKIES POLICY
Background
Roycian Ltd (“we” or “us” or “our”) are committed to protecting and respecting your privacy and processing your personal information for legitimate and lawful business purposes. For the purposes of the Data Protection, the Data Controller is Roycian Ltd, Company Number 09076844, whose registered address is 119 Park Road, Chandlers Ford, Hants. SO53 1HX.
The purpose of the legislation is to enforce greater control and rights for individuals to have their privacy respected and their data protected. This includes easier access to the personal information organisations hold about you, ensuring it is updated, accurate and processed lawfully and fairly.
We are registered as a Data Controller with the ICO, under registration reference number ZB097344. We undertake to comply with the General Data Protection Regulation (GDPR) which came into effect on 25th May 2018 and the retained General Data Protection Regulation ((EY) 2016/679). This policy (together with our terms and conditions) sets out the basis of how any personal data we collect from you, or that you provide to us, will be collected, stored, used, and processed by us. Please read the following carefully to understand our practices and procedures regarding your personal data. We keep certain basic information when you visit our website and recognise the importance of keeping that information secure and letting you know what we will do with it. By requesting or using our services and our website you accept and consent to our use of your personal data as outlined in this policy. If you disagree with any part of this policy, please do not use our website. This policy only applies to our website at www.roycian.com and our company Roycian Ltd. If you leave our website via a link or otherwise, you will be subject to the policy of that website provider. We have no control over that policy, or the terms of the website and you should check their policy before continuing to access their site.
Collecting Your Data
We may collect and process the following data about you:
• Information that you provide to us by filling in forms on our website. This includes information provided at the time of registering as a potential investor or subscribing to our newsletter or requesting further services via our contact form:
• We may ask you for information when you report a problem with our site.
• If you contact us, we may keep a record of that correspondence.
• We may also ask you to complete surveys that we use for research purposes.
• We may store your contact details in relation to our dealings with you as a supplier or professional service provider; or
• Details of your visits to our site including, but not limited to, traffic data, location data, weblogs, operating system, browser usage and other communication data.
Cookies
Our website does not directly use Cookies to collect information, nor to retarget or market to you in any way. However, our domain host Shopify and other third party service providers that enable the functionality of the website may do and you should read their Cookies policy where relevant at https://www.shopify.com/legal/cookies are small pieces of information that a website stores on your web browser or software application which can later be used to retrieve user information. This helps improve your experience when you browse the website, and it improves the functionality, security, and performance of the website.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.>
Where We Store Your Personal Data
All information you provide to us is stored on our secure servers and secure laptops and electronic devices. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your investment order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.
Our Use of Your Information
‘Personal’ information means any information that can be directly associated with a specific person, or that reasonably can be used to identify a specific person.
You do not have to submit any personal information to use this website. We will not collect any personal information about individuals, except where it is specifically and knowingly provided by them. When using this website, should we ask you to provide certain information by which you can be identified, such as completing a registration to become a Corporate Finance Contact, we can confirm that this information will only be used in accordance with this Policy.
When you visit Roycian’s website, our web server collects some basic information, such as your internet service provider’s domain name, which pages you accessed on our website, and when. This information is only used to analyse the use of our website to help guide improvements (see ‘Cookies’). We may also store and maintain any content that you provide, including but not limited to postings on our social media applications such as LinkedIn and Twitter.
We use information held about you in the following ways:
• To ensure that content from our site is presented in the most effective manner for you and for your computer.
• To provide you with information, products, or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
• To carry out our obligations arising from any contracts entered into between you and us.
• To allow you to participate in our services when you choose to do so.
• To notify you about changes to our services.
We do not use your data, or permit third parties to use your data, to provide you with information about other goods and services other than our own. We will never sell your data and we will endeavour to keep your details safe and secure.
We may disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, our customers, or others.
For investors and prospective investors in our investments, the personal details provided by you will be used for the purposes providing our services to you. Your personal information will be used for essential servicing of your account including the administration and management of your investments, sending investment proposals, and relevant contact about your investments. We will also use your data to update you about service improvements or changes to services, to administer our website and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
In the course of executing investments, this may include providing your details to our potential investee companies and their advisers and also to regulatory bodies in order to meet our legal and regulatory obligations, including under FCA Rules and Money Laundering Requirements.
Access to Information
You have the right to contact us regarding the personal information we hold about you. You have the right to ask us to delete any personal information we hold.
You can exercise these rights by contacting us at: delhuse@roycian.com or to The Data Protection Officer, Roycian Ltd, 119 Park Road, Chandlers Ford, Hants, SO53 1HX.
We can delete the information we store on you if requested as far as reasonably practical. This can include your personal data as used day to day but cannot for practical and legal reasons be deleted from the back-up files, we make to protect our system and will not be deleted in relation to any investment you have made with us, for legal and compliance reasons.
Updating your information
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us. If you become aware of any errors or your information needs updating, please contact us using the contact details in ‘Contact us’.
Confidentiality
We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except that we may share information with our service providers for the purposes set out in this Privacy Policy. We will maintain the confidentiality of and protect your information in accordance with our Privacy Policy and all applicable laws.
Security
Roycian is committed to safeguarding your personal information and we endeavour to apply appropriate procedures and security features to process and protect your personal data.
All Roycian systems are hosted in securely managed environments, where appropriate disaster recovery and backup up procedures are in place.
Please be aware that the transmission of any data via the Internet is not completely secure but we do take appropriate steps to try to protect the security of your personal data.
Changes to our Privacy Policy
From time to time, we may change this Policy. Changes to this Policy are effective as of the effective date listed below and indicates the last time this Policy was revised or materially changed. Your continued use of this website indicates your consent to the changes to this Policy. This policy is effective from 18 June 2021 and was last updated 16th May 2023.
Contact us
In the event of any query about our marketing to you, please email delhuse@roycian.com. If you wish to make a complaint in connection with the personal information we hold about you, please email delhuse@roycian.com or write to us at:Del Huse (Data Protection Manager)
Roycian Ltd,
119 Park Road
Chandlers Ford
Eastleigh
Hampshire
SO53 1HX
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to our Data Protection regulator:
Information Governance department
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113
https://ico.org.uk/make-a-complaint/
Roycian Ltd is authorised and regulated by the FCA, ref number 955935.