This Privacy Statement covers personal information provided to RAW Wealth Management Limited, RAW Wealth Management Holdings Limited, RAW Nominees Limited, 1818 VC GP Limited and 1818 VC LP Inc. (“RAW” or “We” or “Our”). We are committed to protecting your personal information when you use Our services. Personal data is any information that can be used to identify you as a person. This Privacy Statement relates to Our use of any personal information you provide.
In order to provide you with the best experience, we are required to collect information about you. We are committed to safeguarding your personal information. Whenever you provide such information we are legally obliged to use your information in line with all laws concerning the protection of personal information including the Data Protection (Bailiwick of Guernsey) Law, 2017.
This website contains hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies, including cookies, and we urge you to review them. They will govern the use of personal information you submit or are collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.
What information will RAW collect about me?
When you engage with or receive a service from RAW, such as enquiries about services or making investments we will ask for personal information about you. This will consist of your name, email address, postal address and other personal information. Different services may ask for different information.
By giving us your details you enable RAW to provide you with the services you selected.
How will RAW use the information they collect about me?
We use your personal information in a number of ways including the following:
- to contact you about an enquiry you have made via email, website, telephone or other means of communication, including any content you provide
- to personalise the way we present information to you
- to analyse and improve the services offered by RAW to meet contractual, legal and regulatory obligations
When will RAW contact me?
We may contact you:
In relation to any service you have enquired about, where you have opted to receive further correspondence and in relation to a service we have agreed to provide.
You may opt‑out of receiving marketing material and other information from us at any time.
How will RAW Manage my personal information?
When we interact with clients a certain amount of personal information is required. This includes Customer Due Diligence information, which we are required to obtain by law as a business licensed by the Guernsey Financial Services Commission, in order to provide Our services to you. Your information is protected under the Data Protection (Bailiwick of Guernsey) Law, 2017 (“the Law”) and we have taken steps to ensure compliance with the provisions of the Law.
Howsoever collected, information shall be collected and held by RAW unless otherwise noted below and, as such, we are the controller for the purposes of the Law. The Company may not hold your data exclusively in Guernsey because, for example, it uses cloud-based data storage from reputable providers such as Microsoft, in addition to local data storage.
Are other parties involved and how will they handle my data?
An independent administrator will be a controller for the purposes of the Law with regard to certain information such as client due diligence with respect to 1818 VC LP Inc. and 1818 VC GP Limited. Each independent party will be a processor of data and is required to comply with the same regulations.
Personal data collected from you directly or by the other means described shall only be utilised for the purpose of entering into and maintaining a contract with you and providing services. It shall be held at all times in accordance with and for as long as our statutory and regulatory requirements require it. This includes a retention period following the cessation of our provision of services to you, which shall, at all times, be determined by our legal and regulatory obligations. As soon as such obligations cease to apply, we shall permanently erase all personal information held on you from our records.
From time to time, we may undertake checks utilising accredited screening software, which searches publicly available databases; provide your information to outsourced service providers or be required to provide your information to law enforcement; the regulator(s) and/or associated parties because of our legal obligations. This may require information to be submitted to the United Kingdom, EU or other jurisdictions. We shall not provide your information to any other third parties (e.g. for marketing purposes) without your express consent and acknowledge that such consent may be withdrawn by you at any time.
If at any time you believe we hold information in error or that the information we hold on you is inaccurate or incomplete, you may submit a request to us to consider rectifying and/or erasing it.
If at any time you are concerned with the information held, the way in which we hold it or are unhappy with any response from us in relation to information held or with any other element relating to your personal information, you may lodge a complaint. We would ask that you contact us n the first instance and we will seek to resolve any concerns as soon as possible. You also have a right to lodge a complaint directly with the Guernsey Data Protection Commissioner at:
Guernsey Information Centre
St. Peter Port
Details of the complaints and appeals processes are available on their website at www.odpa.gg
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. RAW aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where RAW relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Cookies, Web Statistics and third-party monitoring
We maintain continuous logs of web server activity. These log files include the details of website users’ IP address, browser type and page last visited etc. The log files are used to analyse how the website is being used by visitors and may be kept in an anonymised form for historical records.
Our website uses hosted web analytics software. This hosted service is provided and managed by a third-party company (Google, Inc). The service ‘Google Analytics’ uses ‘cookies’ (a text file sent to users’ computers as they browse our website) to help analyse how users navigate our website. The information generated by the cookie regarding our website (including IP addresses) will be anonymised and transmitted to and stored by Google, Inc. on servers that may be hosted in the United States. Google, Inc. will use this information for evaluating the use of our website, compiling reports on website activity for website operators and providing other related services to RAW.
Can I find out what personal information RAW holds about me?
Under the Data Protection Law, you have the right to request a copy of the Personal Information We hold about you and to have any inaccuracies corrected. (Information requests are free, though we reserve the right to charge a small fee where more than one copy is requested or where the request is unfounded, repetitive and/or excessive, and we will require you to prove your identity with 2 pieces of approved photographic identification.) We will use reasonable efforts to supply, correct or delete personal information about you on our files within 30 days of the request.