Bridges Fund Management Ltd – Privacy Notice
Bridges Fund Management Limited (company number 10401079) (“Bridges”) is committed to protecting your privacy. At all times we aim to respect any personal information you share with us or that we collect about you and keep it safe. This Privacy Notice (“Notice”) sets out our data processing practices when you interact with us including online through our website – www.bridgesfundmanagement.com – and your rights and options regarding the ways in which your personal information is used.
Please note that we have additional privacy notices that apply if you choose to enter into a formal relationship with us e.g. as an Investor. You may access the privacy notice for investors here.
This Notice contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal information.
The provision of your personal information to us is voluntary. However, without providing us with your personal information, your use of our services may be impaired. For example, you will be unable to contact us via this website.
- We collect personal information about you
- What personal information do we process?
- How and why will we use your personal information?
- Communications for marketing/ fundraising
- How long do we keep your personal information?
- Lawful bases
- Will we share your personal information?
- Security/ storage of and access to your personal information
- Exercising your Rights
- Changes to this Notice
- Links and third parties
- How to contact us
1. We collect personal information about you
1.1 When you give it to us directly
For example, personal information that you give us by signing up for our email newsletter, contacting us through our Contact Us page or if you apply for a job with us, or personal information that you provide in any way to any of our staff.
1.2 When you visit our website
When you visit our website, we automatically collect the following types of personal information:
- Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
- Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.
We also collect and use your personal information by using cookies on our website – please see our Cookie Notice here.
- When we obtain it from publicly available sources
Your personal information may be available to us from external publicly available sources. This may include information available on Companies House, the Charity Commission and other charity registers, reputable media articles, publications and company websites and professional networking sites such as LinkedIn. Depending on your privacy settings for social media services, we may access information from those accounts or services, including from Facebook, Instagram and Twitter.
- When we obtain it from third parties
For instance, we may obtain personal information about you from Independent Financial Advisers or other professional advisers.
In general, we may combine your personal information from these different sources for the purposes set out in this Notice.
2. What personal information do we process?
We may collect, store and otherwise process the following kinds of personal information:
- your name and contact details, including postal address, telephone number, email address and, where applicable, social media identity (“Identity Data”);
- information about your professional status and background in the context of understanding your potential interest in our services (“Profile Data”);
- information about your experience and education if you apply for a job with us or you apply for a management position in one of our portfolio companies (“Employment Data”);
- information about your computer/mobile device and your visits to and use of this website, including, for example, your IP address and geographical location (“Technical Data”);
- information about our services which you use/ which we consider may be of interest to you (“Usage Data”);
- information you provide through our management questionnaire in the context of a potential commercial acquisition or investment, including about your health or criminal convictions (“Questionnaire Data”).
2.2 Do we process special categories of personal information?
The General Data Protection Regulation (and the retained UK law version of the GDPR) (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and political opinions. We do not intentionally collect special categories of data through our website.
When we process special category data (on health) we will only do so where you have voluntarily provided this information to us and you have confirmed your explicit consent for our use, unless processing is necessary for compliance with our legal and regulatory obligations.
When we process data on criminal convictions we do so because it is necessary for compliance with our legal or regulatory obligations.
3. How and why will we use your personal information?
Your personal information, provided to us through our website, will be used for the purposes specified in this Notice. In particular, we may use your personal information:
- to provide information (or further information) about our work, services, activities or products (where necessary, only where you have provided your consent to receive such information)
- to answer your questions/requests and communicate with you in general;
- to analyse and improve our work, services, activities, products or information (including our website);
- to hold a list of contacts (such as placement agents) that we work with or would wish to work with;
- to report on the impact and effectiveness of our work;
- to run/administer our website, keep the website safe and secure and ensure that content is presented in the most effective manner for you and for your device;
- to register and administer your participation in events;
- to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering);
- to review your application for a job to work for us and to contact you about the position and any interview process;
- to review any applications for a management position where we are leading the recruitment process for one of our portfolio companies;
- to carry out appropriate due diligence on investors, shareholders and management team members in the context of money laundering checks, a commercial acquisition or investment;
- to carry out our business activity as an investment fund manager;
- for the prevention of fraud or misuse of our services; and/or
- for the establishment, defence and/or enforcement of legal claims.
4. Communications for marketing/ fundraising
We may use your contact details to provide you with information about our work, events, services and/ or products which we consider may be of interest to you (for example, about services you previously used). We will only contact you where we have informed you that we will and, where the law requires us to, we will obtain your prior consent.
Where you do not wish to be contacted by us about our projects and/ or services in the future, please let us know by email via comms@bridgesfundmanagement.com. You can opt out of receiving emails from Bridges at any time by contacting us at comms@bridgesfundmanagement.com.
5. How long do we keep your personal information?
In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see section 9 below), we will remove it from our records at the relevant time.
If you request to receive no further contact from us, we will keep some basic information about you in order to comply with your request and avoid sending you unwanted materials in the future.
6. Lawful bases
The GDPR requires us to rely on one or more lawful basis to process your personal information. We consider the grounds listed below to be relevant:
- Where you have provided your consent for us to use your personal information in a certain way (for example, we will ask for your consent to use your personal information to send you promotional or fundraising material by email, and we may ask for your explicit consent to collect special categories of your personal information).
- Where necessary so that we can comply with a legal obligation to which we are subject (for example, when we are required to carry out a Know Your Client check in the context of a commercial acquisition or where we are obliged to share your personal information with regulatory bodies which govern our work and services).
- Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, if you apply to work for/ volunteer with us).
- Where there is a “legitimate interest” in us doing so.
6.2 Legitimate interests
The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights).
In broad terms, our “legitimate interests” means the interests of running Bridges as a specialist fund manager enabling investors to invest in our funds; for example providing information about our services, responding to queries, administering events and advertising our services.
When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
6.3 We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Use | Type of data | Legal basis |
| to provide information (or further information) about our work, services, activities or products | (a) Identity Data
(b) Profile Data (c) Usage Data |
(a) Necessary for our legitimate interests (to carry out direct marketing, develop our services and grow our business)
OR (b) Consent, having obtained your prior consent to receiving direct marketing communications. |
| to answer your questions/requests and communicate with you in general | (a) Identity Data
(b) Profile Data (c) Usage Data (d) Employment Data |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to develop our business and provide our services) |
| to analyse and improve our work, services, activities, products or information (including our website) | (a) Technical Data
(b) Usage Data |
(a) Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| to hold a list of contacts (such as placement agents) that we work with or would wish to work with | (a) Identity Data
(b) Profile Data |
(a) Necessary for our legitimate interests (to develop our business and to inform our marketing strategy) |
| to report on the impact and effectiveness of our work | (a) Identity Data
(b) Profile Data (c) Usage Data |
(a) Necessary for our legitimate interests (to carry out direct marketing, develop our services and grow our business) |
| to run/administer our website, keep the website safe and secure and ensure that content is presented in the most effective manner for you and for your device | (a) Identity Data
(b) Technical Data (c) Usage Data |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
(b) Necessary to comply with a legal obligation |
| to register and administer your participation in events | (a) Identity Data | (a) Necessary for our legitimate interests (to administer our events) |
| to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering) | (a) Identity Data
(b) Employment Data (c) Questionnaire Data |
(a) Necessary to comply with a legal obligation |
| to review your application for a job to work for us and to contact you about the position and any interview process | (a) Identity Data
(b) Employment Data |
(a) Necessary for our legitimate interests (for recruitment purposes)
(b) Necessary to comply with a legal obligation |
| to review any applications for a management position where we are leading the recruitment process for one of our portfolio companies | (a) Identity Data
(b) Profile Data (c) Employment Data (d) Questionnaire Data |
(a) Necessary for our legitimate interests (for recruitment purposes)
(b) Necessary to comply with a legal obligation |
| to carry out appropriate due diligence on investors, shareholders and management team members in the context of money laundering checks, a commercial acquisition or investment | (a) Identity Data
(b) Profile Data (c) Employment Data (d) Questionnaire Data |
(a) Necessary for our legitimate interests (to carry out transactions)
(b) Necessary to comply with a legal obligation (c) Performance of a contract with you |
| to carry out our business activity as an investment fund manager | (a) Identity Data
|
(a) Necessary for our legitimate interests (to enable investors to invest in our funds and to carry out transactions) |
| for the prevention of fraud or misuse of our services | (a) Identity Data
(b) Questionnaire Data
|
(a) Necessary for our legitimate interests (to prevent fraud or misuse of our services)
(b) Necessary to comply with a legal obligation |
| for the establishment, defence and/or enforcement of legal claims | a) Identity
(b) Profile Data (c) Employment Data (d) Technical Data (e) Usage Data (f) Questionnaire Data |
(a) Necessary for our legitimate interests (to establish, defend or enforce legal claims)
(b) Necessary to comply with a legal obligation |
7. Will we share your personal information?
We may share your personal information with our third party suppliers when they are processing personal information on our behalf.
Please note that if you are a shareholder in a company in the context of a commercial acquisition or investment that we are involved in, we are required to carry out Know Your
Client checks. For this purpose, we use a third party – Smartsearch
(www.smartsearchuk.com). As part of using Smartsearch, your personal information may be disclosed to credit reference agencies and fraud prevention agencies (e.g. Experian, Equifax, Dow Jones) to verify your identity and to match your address, and there will be a record (soft footprint) on your credit file in relation to this. These agencies will use your personal information to prevent fraud and money laundering. Please see: (i) Smartsearch Privacy Policy; and (ii) the Credit Reference Agency Information Notice (“CRAIN”) (Credit Reference Agency Information Notice (CRAIN) | Experian) for more information.
We may need to disclose your personal information where legally required or upon request to regulatory and government bodies (such as HMRC) as well as law enforcement agencies. We may also merge or partner with other organisations and, in so doing, acquire or transfer personal information but your personal information would continue to be used for the purposes set out above.
We may also share your personal data with our US subsidiary, other affiliates of ours or financial institutions active in the field of impact investing so that they can contact you about opportunities we think you may be interested in.
8. Security/ storage of and access to your personal information
8.1 Bridges is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information. For example, your personal information is only accessible by appropriately trained staff and contractors, and stored on secure servers with features enacted to prevent unauthorised access.
8.2 In general, the personal information that we collect from you will be stored at a destination within the UK or European Economic Area (“EEA”). However, in the event we do transfer your personal data outside the UK or EEA, we will ensure a similar degree of protection is afforded to your data. We will do this by: (i) only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data; (ii) using specific standard contractual terms approved for use which give the transferred personal data the same protection as it has in the UK or EEA; or (iii) requiring all our group companies to follow the same set of rules when processing your personal data through the use of Binding Corporate Rules (or “BCRs”).
8.3 Please note that some countries outside of the EEA may have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. Where your personal information is transferred, stored and/or otherwise processed outside the EEA in a country that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into standard contractual clauses approved by the European Commission) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Notice.
8.4 Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure – however, once we have received your personal information, we will use strict procedures and security features to try and prevent unauthorised access.
9. Exercising your Rights
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing purposes via the contact details in section 12 below or to unsubscribe from our newsletter at any time. You also have the following rights:
- Right of access – you can write to us to ask for confirmation of what personal information we hold about you and to request a copy of that information. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.
- Right of erasure – at your request and where you are entitled to, we will delete your personal information from our records as far as we are required to do so. In many cases we will need to hold onto limited personal information about you in order to ensure we don’t send you further communications.
- Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate/ up to date.
- Right to restrict processing – you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.
- Right to object – you have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests ground, (ii) using your personal information for direct marketing or (iii) using your information for research or statistical purposes.
- Right to data portability – to the extent required by the GDPR, where we are processing your personal information by automated means and either (i) because we have obtained your consent, or (ii) because such processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contact, you may ask us to provide your personal information to you – or another service provider – in a machine-readable format.
- Rights related to automated decision-making – you have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal effects or similarly significant affects you, unless such a decision (i) is necessary to enter into/ perform a contract between you and us/ another organisation; (ii) is authorised by EU or UK (as long as that law offers you sufficient protection); or (iii) is based on your explicit consent.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information requested to you.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you contact us using the details in section 12 below.
You are further entitled to make a complaint about us or the way we have processed your personal information to the data protection supervisory authority in your home country. In the UK this is the Information Commissioner’s Office (www.ico.org.uk). For further information on how to exercise this right, please contact us using the details below.
10. Changes to this Notice
We may update this Notice from time to time so please check back periodically. We will notify you of significant changes by contacting you directly where we can reasonably do so and by placing a notice on our website. This Notice was last updated in March 2024.
11. Links and third parties
We link our website directly to other sites. This Notice does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy notices of any external websites you visit via links on our website.
12. How to contact us
Please let us know if you have any questions or concerns about this Notice or about the way in which Bridges processes your personal information by contacting us at the following channels:
Email: comms@bridgesfundmanagement.com
Telephone: + 44 (0) 20 3780 8000
Post: Bridges Fund Management Limited, 38 Seymour Street, London, W1H 7BP
Please mark the message for the attention of / ask for the Head of Communications.