Privacy policy

In this policy when we refer to “personal data” we mean information that could directly identify you (for example your name or national insurance number) and information that could indirectly identify you when combined with other information that we hold on you such as gender or date of birth. Process or processing means just about any conceivable use of personal data including recording, storing, viewing or disclosing such data.

Longwall Venture Partners LLP (registered number OC362933) is the data controller of your personal data (referred to here as “Longwall”, “us” or “we”).

If you have any queries about this policy or about your personal data which are not answered by this policy please contact our data protection officer either by email or by post as follows:

Email: dpo@longwallventures.com
Post: Data Protection Officer, Longwall Venture Partners LLP, 30 Upper High Street, Thame, Oxfordshire OX9 3EZ.

How we collect your data

The way we collect your data can broadly be categorised as follows:

• Information you provide to us directly
  When you visit our website or approach us for funding or as a potential investor or you approach us for a job, we may ask you to provide personal data to us. For example as a potential investor we will need to be sure that you are an eligible investor for our funds, so as well as contact information and information for our legal obligations under the UK’s Money Laundering Regulations, we may also ask you to provide information on your income and investment experience. If you have a funding proposal for us, in the first instance we will require your contact information and if we decide to pursue the opportunity we will require information on your employment history, references and information on your financial circumstances. If you do not want to provide us with this personal data you do not have to, but it may mean that you will not be able to receive information on our investment funds or be able to progress your funding request.
• Information we get automatically
  We collect some information automatically about you when you visit our website, this may include your IP address or type of device. We may also collect information as you navigate through our website, such as what pages you looked at and what links you clicked on. Some of this may be collected using cookies and tracking technology. This is useful for tracking the number of visitors to our website and understanding how they use the site. This information will not be used for any other purpose.
• Information we get from third parties
  In general our information will come directly from you. However in some cases we use a third party to provide us with further details such as publicly available information. This will be used purely to supplement the personal data we already hold about you and to validate the personal information that you have provided.

Special Category Data

Special Category data refers to any data which is sensitive and is subject to additional rules and requirements under the General Data Protection Regulations. Special category data may include information regarding: Criminal convictions and offences, race, ethnicity, religious or philosophical beliefs, political opinions, sexual orientation, trade union membership and information about your health, genetic and biometric data. As a general rule we do not collect any Special Category Data about you. However, we are required to request information relating to criminal convictions as part of our recruitment process for staff and contractors undertaking regulated activities, or as part of our investment process, and as such we require consent from the individual for this. If we are required by law to request any special category data from you, aside from the reasons mentioned above we will provide you with a reasonable explanation as to the nature and purpose for this request and obtain your consent. We would not be able to proceed without your consent unless there was a lawful reason for doing so.

How we use your data and the legal bases for doing do

The personal data we collect will be processed for the following purposes:

• To enable an investment, by potential investors in our funds or by our fund in your business
• To comply with applicable laws and regulations (such as the UK’s Money Laundering Regulations)
• To manage our relationship with you
• To administer our website and capture data on visitors and usage patterns

The legal bases for processing your personal information are:

• In order to perform our contractual obligations
• Where we have legal and regulatory obligations
• Where we have obtained your specific consent (which you have the right to withdraw at any time)
• It is in our legitimate interest to manage and administer our business, for example to respond to a query that we have received from you or make enquiries about your business if you are seeking investment

We do not pass on any of your information to marketing agencies or operate any mailing lists, other than those used to fulfil our contractual obligations to you. We will only use your data to fulfil one of the four criteria noted above.

How we share your data

In very limited circumstances we may need to share your data with third parties. We will only disclose your data to the following groups of people:

• Third party service providers – such as our legal representatives, external software or hosting providers or external identification verification agents, who assist us in providing our fund management services to you
• Regulators, law enforcement agencies, government bodies, courts or other third parties where we believe that it is necessary to comply with applicable laws or regulations or to exercise, establish or defend our legal rights. Where possible and appropriate we will notify you of this type of disclosure, although this may not always be possible
• Other people where we have your specific consent.

International data transfers

When we share data it may be transferred to and processed in countries other than the United Kingdom and in some cases outside the EEA – such as the United States where a number of data hosting providers are located. If this happens we take steps to ensure that the country in question has adequate protection for your data or the third party we use has approved measures in place to protect your personal data, such as adopting the UK’s International Data Transfer Agreement and Addendum.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal grounds for this. We may process your personal data without your knowledge or consent only where this is required and permitted by law.

Security

We are committed to providing a safe and secure environment for the storage of your data. We have implemented appropriate technical and organisational measures to protect the confidentiality of the personal data that you entrust to us. We update our physical and procedural security controls on an ongoing basis including limiting access to your personal data to those who need it and training our employees about the importance of maintaining the privacy and security of your personal data.

Retention

We will only store your data for as long as is necessary to fulfil the purposes outlined in this policy or for as long as we reasonably consider necessary to establish, exercise or defend our legal rights. In the first instance your data will be retained in line with statutory and regulatory requirements as follows:

• To comply with our obligations under the UK’s Money Laundering Regulations
• To comply with the regulatory requirements imposed on us by the Financial Conduct Authority
• To comply with statutory retention periods for accounting records as set out by Companies House and HM Revenue and Customs.

Where retention periods are not governed by legislation our policies are based on commercial justification, set in accordance with the principle of not retaining personal data for any longer than is necessary for the purposes for which it is processed. These include:

• To enable us to provide you with our fund management services
• To allow us to resolve any disputes or complaints
• To detect and prevent fraud.

Once the relevant retention period has ended, we will securely delete that data or anonymise your information (so that we, or anyone else, can no longer identify that it relates to you).

Rights

You have the following rights:

• To know the data that we hold on you and to make sure that it is correct and up to date
• To request a copy of your personal data, ask us to restrict processing it or delete it – unless we have a lawful reason to continue
• To object to our continued processing of your personal data if you believe that it is no longer necessary in relation to the purpose for which it was collected or processed
• To withdraw your consent to our processing your data, if that data was collected based on your consent and there is no other legal ground for processing
• To request that we transfer the personal data we hold on you to another organisation. This right only applies to information which you have provided directly to us.

If you have a query about the personal data we hold on you or wish to request that we no longer process such data, please contact us at dpo@longwallventures.com. We will normally respond to all requests within one month, although if your request is complex or you make several requests we may need additional time to deal with your request.

Cookies

A cookie is a small text file that is downloaded onto your computer, mobile phone or tablet device (‘your device’) when you access our website. Cookies contain information that is transferred to your device.

Cookies collect anonymous information about how visitors use our site which is then used to help improve the site and to provide a good experience. The information collected includes the number of site visitors, where the visitors come to the site from and the pages they visited. We do not automatically capture or store personal data from browsers to the site, other than to log your IP address and session information such as the duration of the visit to our site and the nature of the browser used. This information is used only for administration of the site system and in the compilation of statistics.

We use Google Analytics, a web analytics service provided by Google, which uses cookies placed on your device to help analyse how visitors use our website. These cookies enable us to distinguish users and estimate our audience size and usage pattern by tracking if you’ve visited before.

You can read Google’s privacy policy at:
https://policies.google.com/privacy

You can opt out of having your site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on.

Complaints

If you would like to make a complaint please contact our Data Protection Officer at:
dpo@longwallventures.com

If you are not satisfied with our response, you also have the right to make a complaint to the Information Commissioner’s Office (www.ico.org.uk), the UK’s supervisory authority for data protection.

Changes to this policy

We review our Privacy Policy annually to ensure that it remains up to date and may also update it from time to time. Any changes in this Policy will be posted on our website and, where appropriate, such as if the changes relate to existing investors, will be emailed directly to the affected individuals.

Policy reviewed and updated: March 2026