This Privacy Policy explains what we do with your personal data. It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations. This Privacy Policy applies to the personal data of investors, directors (or, to the extent relevant, employees, officers or similar), agents, service providers, website users, and other people whose personal data we may process.
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), the GDPR as it forms part of the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018 ("UK GDPR") and the Data Protection Act 2018), the company responsible for the personal data you provide to us is US Solar Fund PLC of The Scalpel, 18th Floor, 52 Lime Street, London, England, EC3M 7AF ("USF", "we", "us" or "our").
It is important to point out that we may amend this Privacy Policy from time to time. Please visit this page if you want to stay up to date, as we will post any changes here. If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights. We have described these in the document as well where relevant.
How do we collect personal data?
We collect personal data in a number of ways. This will usually be collected by service providers to USF, such as the registrar or receiving agent, for example when you become a shareholder in USF or where you provide personal data on request from us. We may also receive personal data when you contact us or the company secretary, registrar or administrator (or other service provider) directly by phone, email or by other means. Personal data may also be provided to us by service providers for the purposes of marketing to prospective investors.
We also collect personal data through the use of cookies and other tracking technologies. Please see the "Cookies" section below for more information about how we use these cookies and tracking technologies and how to refuse or restrict the cookies we use.
Personal data is also collected from you by USF when you submit or send personal data through online forms, "contact us" messages, including chat transcripts, emails to us or email newsletter subscription information.
What personal data do we collect?
We process the following types of data:
| Identification data | Your name, address, e-mail address, phone number, job title and identification documents, or any other information which you provide to us. |
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| Device and web data | Information about your device, online identifiers (such as your IP Address) and information about your visit to our website, including information collected through the use of cookies and other tracking technologies. |
| Communications data | Information collected from you when you contact us through online forms, “contact us” messages, including chat transcripts, emails to us or email newsletter subscription information. |
How do we use personal data?
We, or service providers acting on our behalf, use personal data for the following purposes and under the following lawful bases of processing that we rely on:
| Individuals affected | Category of personal data processed | Purpose of processing | Lawful basis for processing |
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| Keeping records of conversations and correspondence |
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| Improving and enhancing online your experience and communicating effectively with you and similar audiences |
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| Contacting you in relation to your shareholding or directorship, employment or other role with us |
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| Complying with our legal and/or regulatory requirements |
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| To carry out anti-money laundering and "Know Your Customer" checks in accordance with our legal and regulatory obligations |
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| Contacting you by email or telephone to offer you shares in USF or send you literature relating to USF* |
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| Storing your details (and updating them when necessary) on the shareholder register |
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| Storing (and updating when necessary) details, either ourselves or at another service provider, so that we can contact individuals in relation to our agreements with service providers. |
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| Obtaining support and services from the service providers. | |||
| Facilitating our invoicing processes. |
*You have the right to opt out of receiving marketing materials from us at any time.
How do we share your personal data with others?
We, or our service providers on our behalf, may provide personal data to our other service providers, provided that the data is used for the purposes described above. We may also share personal data with our group companies, but again, only for the purposes described above.
How do we store and transfer your data internationally?
In order to carry out the activities described in this Privacy Policy, your data may be transferred between and within entities within our corporate group, to third parties (such as regulatory authorities, advisers or other service providers to USF (or their group companies)) and to a cloud-based storage provider, as referred to here.
We want to make sure that your data are stored and transferred in a way that is secure. We will therefore only transfer data outside of the United Kingdom and/or the European Economic Area ("EEA") (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
- by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws alongside (the "EUSCCs"), where applicable, the UK Addendum to the EU SSCs or the UK's International Data Transfer Agreement; or
- in the case of transfer to the US, the transfer is made to an entity certified under the EU – US Data Privacy Framework and/or the UK Extension to the EU – US Data Privacy Framework, as applicable; or
- transferring your data to a country where there has been a finding of adequacy by the European Commission and/or the UK Government, as applicable, in respect of that country's levels of data protection via its legislation; or
- where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests; or
- where you have consented to the data transfer.
To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
How do we keep personal data secure?
We are committed to taking all reasonable and appropriate steps to protect the personal data that we (or third parties on our behalf) hold from misuse, loss, or unauthorised access. We do this by having in place a range of contractual standards (relating to, amongst other matters, appropriate technical and organisational measures) in agreements with our service providers. These include measures to deal with any suspected data breach. If you suspect any misuse or loss of or unauthorised access to your personal data please let us know immediately. Details of how to contact us can be found below.
How long do we keep personal data?
We, or our service providers on our behalf, will ordinarily process your data throughout the course of our interactions and will then generally retain it for an appropriate period afterwards. The precise length of time will depend on the type of data, our legitimate business needs and other legal or regulatory rules that may require us to retain it for certain minimum periods. In other instances, there may be legal, regulatory or risk-management reasons for retaining data, including where certain data might be relevant to any potential litigation (bearing in mind relevant limitation periods).
In determining the appropriate retention period for different types of personal data, we always consider the amount, nature and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition to ensuring that we comply with our legal, regulatory and risk-management obligations, as described above).
Once we have determined that we no longer need to hold your personal data, we will delete it from our systems.
Internet privacy
You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy standards, policies and procedures.
Your legal rights in respect of your personal data
You have the right to ask for a copy of the personal data which we, or service providers on our behalf, hold about you, subject to certain exceptions. If any of the personal data which we hold about you is incorrect or out of date, please let us know and we will correct it.
You have the right to object to the processing of your personal data if it is being used because we deem it necessary for our legitimate interests. Where we have obtained your consent to process personal data for certain activities, such as in relation to direct marketing activities, you may withdraw this consent at any time and we will cease to carry out that particular activity unless we consider there to be an alternative reason to justify our continuing to do so, in which case we will inform you of the reason.
You also have the right to erasure of any personal data we hold about you and/or request that it be transferred to another data controller (again, subject to certain exceptions).
Please note that if you exercise any of the rights listed above, we may no longer have the personal data (e.g. contact details, financial information, etc.) necessary to comply with our obligations to you following such request.
If you would like to exercise any of your rights, or learn more about your rights, please contact us using the details set out in the "Contacting us" section below.
Automated decision-making
We do not carry out any automated decision-making or profiling involving or using your personal data.
Cookies
We set and use cookies and similar technology on your device to obtain information about how you access and use the USF website. We use the word "cookie" in this Privacy Policy to refer to all technologies that collect information in this way.
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website during your browsing session or on each subsequent visit, or to another website that recognises that cookie.
Cookies generally do not identify you, but rather allow us to track use of our online services so that we can understand user habits. We do this so that we can improve your experience and communicate effectively with you and similar customer audiences. In some instances, you may receive cookies which collect personal information in order to enhance your online experience (e.g. where you request for your browser to remember your username when logging into our website). If you prefer not to receive cookies, you can configure your browser to reject them or to notify you when they are being used.
What cookies do we use?
We use the following types of cookies on the USF website:
- Strictly necessary cookies - enable core functionality such as security, network management, and accessibility. They also make our website easier to use by accelerating its display through load balancing. You can disable these by changing your browser settings, but this may affect how the website functions.
- Performance cookies - these cookies are set to provide enhanced functionality and make our website easier to use, by remembering your preferences.
- Functionality cookies - these cookies allow our website to remember the choices a user makes, such as a user name or language preference.
- Targeting or advertising cookies - these cookies collect information about a user's browsing habits and are usually placed by advertising networks with the website operator’s permission.
Cookies can also be categorised in accordance with how long they are saved on your device: "session cookies" are short-term cookies that are only saved on the device's memory for the duration of a user's visit to the website, whereas "persistent cookies" remain saved in the device's memory for a set period of time, even after the browser session has ended.
Specifically, we use and set the following cookies when you visit the USF website:
| Cookie | Type of Cookie | Duration | Description |
|---|---|---|---|
| Session Cookie | Necessary Cookies | Session | A session cookie is a simple text file that a website installs on its visitor's device for temporary use and last for a session. It helps track real-time changes in a user's activity while on a website. This cookie stores information such as the user's input and tracks the movements of the user within the website. There is no other information stored in the session cookie. |
| _ga | Analytical/Performance Cookies | 1 year | This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assigns a randomly generated number to identify unique visitors. |
| _gid | Analytical/Performance Cookies | 1 year | This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected includes the number of visitors, the source where they have come from, and the pages visited in an anonymous form. |
| Webform Cookie | Functionality Cookies | 24 hrs | Provides a Webform submission handler that sets an arbitrary cookie after submission. |
| ussolar_cookie | Functionality Cookies | 3 months | This cookie is used by the website a user's state regarding their cookie choices. |
How do I refuse or restrict cookies?
You may refuse to accept, or withdraw your previous consent to, cookies in your browser settings:
The "Help" or "Internet Settings" functions within your browser should tell you how. For information on how to manage cookies on popular browsers please see the following links:
Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
To opt out of being tracked by Google Analytics across all websites, you may be able to use the tool provided by Google available at: http://tools.google.com/dlpage/gaoptout.
Please be aware that if you select to refuse or restrict cookies, the full functionality of the USF website may no longer be available.
Contacting us
If you would like to contact us regarding this Privacy Policy, to exercise any of your rights, or to make a complaint to us relating to how we process your personal data, please contact:
Address:
Company Secretary
US Solar Fund Plc
The Scalpel, 18th Floor, 52 Lime Street
London EC3M 7AF
Email:
USUsolarFund-CompanySecretary@jtcgroup.com
You also have the right to lodge a complaint with a data protection supervisory authority, including in the UK or the EU member state of your residence, your place of work or the place of the alleged infringement. The UK regulator for data protection is the Information Commissioner and the contact details are: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF; telephone: 0303 123 1113; email: casework@ico.org.uk.