The Pioneer Group has responsibility under data protection legislation to provide individuals with information about how we collect and process their personal data. We do this in a number of ways, one of which is the publication of tailored privacy notices.

For details of our general approach to how we deal with your personal data, including an explanation of what rights you have in relation to us processing your personal data, how you can control how we use your information and how to inform us about your wishes, please see our Privacy Statement, available on our website.

This privacy notice applies to individuals we interact with who are not employees, workers, contractors, agency workers, directors, members and others working under the direction of the Pioneer Group. This will include suppliers and consultants providing services, co-investors or potential candidates for investment, those who engage through our website or event attendees.

We may update this notice at any time and will make an updated copy available on our website.

What Data Will We Collect?

Personal data, or personal information, means 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 will collect different personal data from you depending on our exact relationship with you, and we have set this out in general groups below. The exact information collected will vary from individual to individual.

Supplier Data

We collect and process a range of personal data about our suppliers, including:

  • Identity and personal contact details, such as your name, title, address, email address and telephone number
  • Bank account details, bank references, and credit check results
  • Service delivery records
  • Health and safety records
  • Breach of contract terms/complaints
  • Notices and correspondence regarding contractual arrangements
  • Geographic location data
  • General correspondence in all formats (letters, emails, text messages, etc)

Investor Data

We collect and process a range of personal data about investors, including:

  • Identity and personal contact details, such as your name, title, address, email address, telephone number, date of birth
  • Background information such as company details, accountant details, financial status
  • Bank account details, bank references and credit check results
  • Financial Conduct Authority category
  • General correspondence in all formats (letters, emails, text messages etc).

Potential Candidates for Investment

Where we receive applications or information from companies in relation to potential investment opportunities, we collect and process the following personal data:

  • Identity and personal contact details, such as your name, title, address, email address, telephone number, date of birth
  • Background information such as company details, accountant details, financial status
  • General correspondence in all formats (letters, emails, text messages etc).

Tenants/Occupants/Event Attendees

We collect and process a range of personal data about our tenants/occupants/event attendees, including:

  • Identity and personal contact details, such as your name, title, address, email address, telephone number
  • Background information such as details of your employer or businesses you are associated with
  • If you attend a paid event, payment-related details, such as bank account or credit card details as well as any requirements for attending the event (like access requirements or dietary requirements)
  • General correspondence in all formats (letters, emails, text messages.

Expert Network

We also collect the following personal data from panels of experts that we maintain for participation in accelerator programmes or events:

  • Identity and personal contact details, such as your name, title, address, email address, telephone number
  • Information provided through LinkedIn or other social media platforms.

Special Category Data

We do not collect special category data by default, but we may collect, store and use medical/health information (including any disabilities) or religious/ethnic information where we need to make allowances if you at one of our locations or events. Where we do collect special category data, it will mainly be with your express consent.

How will we collect your data?

Personal data will be collected from a number of sources, including:

  • Direct interactions. You may give us your personal information directly by engaging with us, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you subscribe to our publications or other marketing information, or where you give us feedback more generally
  • When you use our websites or apps, we collect information such as the browser and device you’re using, your IP address, your location, the site you came from, what you did and didn’t use our site/app for, or the site you visit when you leave us. Our Cookie Policy available on our website has more details on our use of cookies
  • When you use a social media feature within our website or apps, and you post to social media platforms, the social media site will provide us with some information about you
  • Through third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, like due diligence service providers (including credit reference agencies) our sub-contractors and support service providers or from your employer/organisation you are linked to). We may also get information from public sources like Companies House and the Electoral Register (or equivalents outside the UK)
  • From CCTV and security/access card systems at our locations
  • The data we hold will be stored in a range of places, including in paper files and in our IT systems (including email systems). We have appropriate policies and controls in place to prevent your personal data from being lost, accidentally destroyed, misused, or disclosed.

How Will We Use Your Data?

Where we process personal data, we have to identify appropriate lawful grounds for doing so. The main reasons we will use your personal data for is to perform the contract we have with you (or are entering into with you), where we need to comply with a legal obligation or where it is necessary for our legitimate business interests. We have set out in the table below examples of when we will process information and the legal basis we rely on.

Purpose

  • To take steps at your request in relation to provision of our services
  • To confirm your identity
  • To decide on your suitability as a co-investor and whether or not to supply our services to you
  • To manage and perform our services
  • To enrol you in an accelerator programme which we run
  • To manage the arrangements, including contractual, with you
  • To ensure fees are billed appropriately
  • To update our records.

Legal Basis

As necessary to perform our contract with you.

Purpose

  • For good governance, accounting, and managing and auditing of our business operations
  • To monitor and store emails, calls, other communications, and activities with you
  • For market research, analysis and developing statistics
  • To secure payment of fees due under an agreement between you and us
  • To monitor and enforce performance of your obligations under an agreement between you and us
  • To handle complaints
  • To monitor emails, calls, other communications, and activities in relation to your use of the services
  • To bring to your attention additional products or services provided by us which we think may be of interest to you
  • To bring to your attention 3rd party contacts, events, networks or opportunities we think might be of interest to you.

Legal Basis

As necessary for our own legitimate interests or those of other persons and organisations (including: to keep our records updated and manage our relationship with you; to study how customers use our products/services, to develop them and grow our business and inform our marketing strategy; to carry out marketing).

Purpose

  • When you exercise your rights under data protection law and make requests
  • For compliance with legal and regulatory requirements and related disclosures
  • To fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service
  • To prevent and detect abuse of our services or any of our rights and to protect our (and others’) property and rights
  • To prevent and detect, including investigation of, crime and anti-social behaviour, including creating and keeping audio and CCTV recordings
  • For establishment and defence of legal rights, including bringing and defending legal claims
  • To verify your identity, and make fraud prevention and anti-money laundering checks
  • To address health and disability matters relating to delivery of your service or product to us.

Legal Basis

As necessary to comply with a legal obligation.

Purpose

  • When you request us to disclose your personal data to other people or organisations such as a company handling a matter on your behalf, or otherwise agree to disclosures
  • When we process any special categories of personal data about you at your request (e.g. your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation) or to make reasonable adjustments where required for health and disability matters
  • When we carry out background checks (where required for a specific role or interaction)
  • To send you marketing communications where we’ve asked for your consent to do so.

Legal Basis

Based on your consent.

You’re free at any time to change your mind and withdraw your consent for any processing we are undertaking based on your consent. We do not use automated decision making or undertake automated profiling in the provision of our services to you.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to enter into and/or perform the contract we have with you (such as contact details for negotiations or where we need information to pay you as a supplier), or we may be prevented from complying with our legal obligations (like ensuring the health and safety of our Company personnel).

Who will we share your data with?

Your information will be shared internally within the Pioneer Group with colleagues for the purposes set out above. We may also share your data with third parties where required by law, where it is necessary in order to administer the relationship with you or where we have another legitimate interest in doing so. Information can be shared with:

  • Professional advisers, including solicitors and accountants
  • Sub-contractors engaged to perform any of our obligations to you
  • Suppliers contracted to provide services that support our performance of our obligations
  • 3rd party due diligence service providers, including credit reference agencies
  • Police/enforcement agencies
  • Internet service providers
  • Banks/building societies
  • Financial Conduct Authority
  • H M Revenue and Customs.

When we engage third parties to process personal data on our behalf, we do so on the basis of written instructions, including a duty of confidentiality and an obligation to implement appropriate technical and organisational measures to ensure the security of your personal data. This may include transfers out within the UK or European Economic Area to service providers who support the operation of our business. In such instances, any data will only be transferred internationally where we have a written agreement in place with the service provider which ensures the same levels of personal data protection that would apply within the UK or the EEA. When information is shared with third parties detailed above it will be limited to the minimum required to achieve the purpose it is being shared for and will be adequately protected.

How long will we keep your data?

We will keep your personal data for as long as it is needed for the purpose for which it was originally collected (including legal, accounting or reporting requirements). We may retain your personal data for a longer period 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
  • The applicable legal, regulatory, tax, accounting or other requirements.

Generally, we will keep your personal data for the duration of our relationship with you and following the end of our relationship, we will keep basic information (including Contact, Financial and Transaction Data) for six years after you cease being customers for tax and accounting purpose.