Funds Privacy Notice

ABOUT US

FSE C.I.C. is a community interest company, registered in England under company number 04463599. Its registered office is at First Floor, Linea House, Harvest Crescent, Ancells Business Park, Fleet, Hampshire, GU51 2UZ. 

FSE C.I.C. is registered with the UK Information Commissioner under number Z6964923.

The FSE Group comprises a number of related companies and businesses. A list of current group members is available here. 

In this privacy notice, references to “FSE”, “we”, “us” or “our” mean the relevant member of the FSE Group that determines the purposes and means of processing your personal data (the “controller”).

Different members of the FSE Group provide different services and may act as independent controllers of your personal data depending on your interaction with us. If you would like to know which entity is responsible for your personal data in your circumstances, please contact us.

WHAT WE DO

We provide fund management and related services to public sector bodies and other organisations that invest in, or provide loans or grants to, small and medium sized enterprises (SMEs).

We invest in, make loans and grants and provide support to SMEs. We also run a business angel network. 

Different members of the FSE Group are responsible for managing different funds and activities.

Please contact us if you want to know which members of the FSE Group control the use of your personal data.

WHY THIS NOTICE IS IMPORTANT 

This privacy notice explains:

• how we collect and use personal data; and 
• the rights of individuals whose personal data we process.

The FSE Group publishes separate privacy notices for specific categories of individuals (for example, website users, mailing list subscribers, angel network members and investors). These are available on our website.

This privacy notice should be read together with any additional privacy notice we may provide in specific circumstances. Those notices supplement this one and do not replace it.

INTRODUCTION

Personal data means any information relating to an identified or identifiable individual (a “data subject”).

Data that has been anonymised so that individuals can no longer be identified is not personal data.

WHO THIS NOTICE APPLIES TO

This privacy notice applies to personal data relating to individuals who:

• make a general enquiry about any of our funds, including about investing any fund and any support we may be able to provide to their business;
• are individuals who are interested in investing in one of our funds or have invested in one of our funds; 
• are contacts, officers or employees of any organisation interested in providing funding or investing in one of our funds or of any of our funding providers or investors;
• are contacts, officers or employees of a business looking for or which has received investment, a loan or other support; 
• have given or offered to give a guarantee or other security; or
• are individuals who introduce potential investors and/or businesses to the members of the FSE Group (Introducers).

This notice applies where a member of the FSE Group acts as a data controller.

It does not apply where we process personal data solely on behalf of another organisation acting as the controller. In those circumstances, that organisation’s privacy notice will apply, and we will process personal data only on their instructions.

OUR DATA PROTECTION OBLIGATIONS

Under data protection law, we are required to:

1. process personal data lawfully, fairly and transparently;
2. collect personal data only for specified, explicit and legitimate purposes;
3. ensure personal data is adequate, relevant and limited to what is necessary;
4. retain personal data only for as long as necessary;
5. keep personal data accurate and up to date; and
6. ensure appropriate security of personal data.

HOW WE COLLECT PERSONAL DATA 

The personal data we collect depends on your relationship with us, including whether you:

• make an enquiry about our services or funds;
• are a current or prospective investor;
• act on behalf of a business seeking or receiving funding or support;
• provide or propose to provide a guarantee or other security; or
• introduce potential investors or businesses to us.

Further detail on the sources of personal data is set out in the table below.

COOKIES AND WEBSITE DATA

We use cookies and similar technologies to collect information about how visitors use our website.

This may include data such as time zone setting, general location, browser type and version, operating system and referral source (for example, whether you have accessed our website via another website or social media).

We use Google Analytics to support this analysis.

Where data is collected in this way, it is not used to identify you directly.

Please see our Cookie Notice for more information.

TYPES OF PERSONAL DATA AND HOW WE USE IT

The table below sets out:

• the personal data we collect and use;
• the purposes for which we use it; and
• the lawful basis we rely on.

Where the lawful basis is our legitimate interests or the legitimate interests of someone else, we have also indicated what those interests are.

We may have more than one lawful basis. Please contact us if you want to know which basis applies.

Special Categories of Personal Data: 

Special categories of personal data include information relating to race or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic and biometric data.

We do not collect special category personal data about visitors to this website.

Convictions and Offences: 

We do not collect or use data relating to criminal convictions or offences about visitors to this website.

Aggregated Data: 

We may collect, use and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data does not directly or indirectly identify individuals and is therefore not considered personal data.

Where aggregated data is combined with personal data in such a way that individuals can be identified, it will be treated as personal data and processed in accordance with this privacy notice.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another purpose that is compatible with the original purpose.

If we need to use your personal data for a different purpose, we will:

• notify you and explain the legal basis for doing so; or
• ensure the data is anonymised and used solely for research or statistical purposes.

MARKETING

We may contact you for marketing purposes in the following ways:

• By post: You may opt out at any time.
• By telephone: We will not make unsolicited marketing calls where you have objected, or where your number is registered with the Telephone Preference Service (TPS) or Corporate Telephone Preference Service (CTPS), unless you have expressly requested contact.
• By email or text (SMS): We will only send marketing communications where:
  • you have provided your consent; or
  • you have previously engaged with us (for example, by attending or registering for an event), and the communication relates to similar services (in accordance with applicable laws).

You can unsubscribe or opt out of marketing communications at any time.

We do not share personal data with third parties for their own marketing purposes. However, where we co-host events, we may share limited attendee data with the joint host. Please refer to our Events Privacy Notice for further information.

AUTOMATED DECISION MAKING AND PROFILING

We do not carry out automated decision-making or profiling using your personal data.

SHARING PERSONAL DATA 

We may share your personal data where necessary with:

• funders or investors, where you are associated with a business seeking funding or support;
• other companies within the FSE Group;
• our service providers (including consultants, contractors and IT providers) who process data on our behalf;
• professional advisers (who are subject to confidentiality obligations);
• regulatory bodies, law enforcement, or other authorities where required by law;
• prospective buyers or sellers in the event of a business sale, merger or acquisition; and
• other parties where necessary to protect our rights, property or safety, or those of others.

Where we use third party processors, they are required to:

• process personal data only on our instructions;
• use it solely for specified purposes; and
• implement appropriate security measures.

INTERNATIONAL TRANSFER

Our staff may access personal data outside the UK or European Economic Area (EEA). In such cases, we ensure appropriate safeguards are in place.

We will only transfer personal data internationally where one of the following applies:

• the destination country has been deemed to provide an adequate level of protection;
• appropriate safeguards are in place (such as Standard Contractual Clauses);
• you have provided explicit consent; or
• the transfer is necessary for contractual performance, legal claims, or important public interest reasons.

Further details of safeguards can be provided on request.

SECURITY

We implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction or damage.

Access to personal data is limited to individuals who have a legitimate business need. All such persons are subject to confidentiality obligations.

We maintain procedures for managing personal data breaches and will notify the Information Commissioner’s Office (ICO) and affected individuals where legally required.

HOW LONG WE KEEP PERSONAL DATA 

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including for legal, regulatory, accounting or reporting requirements.

As a general rule, we retain client and customer records for six years after the relationship ends, in line with legal obligations.

Where personal data is anonymised, it may be retained indefinitely.

Further detail is available in our Data Retention and Deletion Policy upon request.

YOUR RIGHTS 

You have the following rights under data protection law:

• Access: Request confirmation of whether we hold your data and obtain a copy.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion where there is no lawful basis to retain data.
• Restriction: Request suspension of processing in certain circumstances.
• Objection: Object to processing based on legitimate interests or for direct marketing.
• Withdraw consent: Where processing is based on consent.
• Data portability: Request transfer of data where applicable.

Requests can be made using the contact details below. We aim to respond within one month.

We may require proof of identity and may refuse or charge a reasonable fee for manifestly unfounded, excessive or repetitive requests.

PROVIDING PERSONAL DATA

You are not required to provide personal data. However, if you do not provide information necessary for:

• delivering services; or
• verifying your identity

we may be unable to fulfil your request.

OTHER WEBSITES

Our website may include links to third-party websites. We are not responsible for their content or privacy practices. Please review their privacy notices before providing personal data.

COMPLAINTS AND QUESTIONS

If you think we are using your personal data is unfairly or we are misleading you, please let us know.

It is important that your personal data is accurate and up to date. Please let us know if your personal data changes.

We also welcome suggestions for improving our procedures.

Please let us know if you want more information about how we use your personal data.

You have the right to make a complaint about the way we have used your personal data to the UK Information Commissioner’s Office at: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or www.ico.org.uk. 

Or you can go to court.

Please contact us and give us a chance to set things right before you contact the Information Commissioner’s Office or go to court.

HOW TO CONTACT US

We have appointed a Data Protection Manager. 

If you have any questions about this privacy notice, you want to exercise your rights, or you want to make a complaint, please:

• email FSE’s Data Protection Manager at privacy@thefsegroup.com;  or 
• write to us at First Floor, Linea House, Harvest Crescent, Ancells Business Park, Fleet, Hampshire, GU51 2UZ, marking your letter for the attention of The Data Protection Manager.

CHANGES TO THIS PRIVACY NOTICE 

This privacy notice was last updated on 17th September 2025. Reviewed on 28th May 2026, other than format changes no policy amendments were made.

If we change how we use your personal data, we will let you know, either by posting a notice on our website or sending you an email.

If you don’t agree to the changes, you can stop giving us personal data.