Welcome to Foresight Group’s privacy notice, which also covers cookies.
Foresight Group respects your privacy and is committed to protecting your personal data. This privacy notice informs you about how we use and look after your personal data when you visit our website (regardless of where you visit from), when we provide our products and services to you and when information is provided to us relating to our investment business and also informs you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas listed below.
For the purposes of this document, references to “Foresight” or “Foresight Group” shall mean Foresight Group LLP together with any entity in which Foresight Group Holdings Limited directly or indirectly owns at least a 50% controlling interest/ shareholding, except where such entity is subject to more onerous GDPR legislation in its own jurisdiction.
Additionally, references to “ICO” shall mean the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk) or the equivalent authority in non-UK jurisdictions.
This privacy notice aims to give you information on how Foresight collects and processes your personal data through your use of this website, including any data you may provide through this website, or when you request information about other products or services from Foresight or otherwise communicate with us, when we provide our products and services to you, when information and personal data is provided to us relating to our investment business and when you seek employment with Foresight, including submitting a CV or job application. This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements these other notices and is not intended to override them.
Foresight Group LLP or another member of the Foresight Group is the controller and responsible for your personal data (collectively referred to as “Foresight”, “we”, “us” or “our” in this privacy notice).
The Foresight Group (also referred to as Foresight or Group) is made up of different legal entities, including our holding companies and ultimate holding company, partnerships, subsidiaries and affiliates, with the principal entities being Foresight Group LLP, Foresight Promoter LLP and Foresight Group CI Limited, together with the Funds and Foresight related entities listed in the Appendix at the end of this document. This privacy notice is issued on behalf of the Foresight Group so when we mention "Foresight", "we", "us" or "our" in this privacy notice, we are referring to the relevant company within the Foresight Group responsible for processing your data. In some cases, a member of the Foresight Group acts as a processor of personal data relating to investments in separate legal entities, such as venture capital trusts and Foresight related entities, established by the Foresight Group as vehicles for investment products and investee companies. In such cases the venture capital trust or other legal entity will be the controller of the personal data relating to its investors. This privacy notice applies to such data and the relevant Foresight Group company processes such data on behalf of the controller in accordance with this privacy notice. Foresight Group LLP is responsible for this website. We may share your personal data with any of the entities in the Foresight Group, some of which are located outside the United Kingdom and the European Economic Area, as further described in section 6 below.
Our GDPR Panel is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (including any opt-out mentioned in this privacy notice), please contact them using the details set out below.
Our full details are:
The details of our principal operating entities and ultimate parent company are as follows:
If you have a complaint relating to such data, please contact the GDPR Panel by email, telephone or post at the above address. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or the equivalent authorities in non-UK jurisdictions. Data protection authorities for the EU are listed at: https://edpb.europa.eu/about-edpb/about-edpb/members_en. For any data protection matter concerning a member of the Foresight Group or a Foresight managed fund entity, we would, however, prefer to deal with your concerns before you approach the ICO or other competent authority and so please contact our GDPR Panel in the first instance.
This version was last updated on 5 June 2023 and previous versions can be obtained by contacting us. We may modify this privacy notice at any time but will provide advance notice of any material changes by either posting a notice to you or via our websites or by email to provide you with the opportunity to review these changes and choose whether or not to continue using our products or services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Foresight Group is a leading independent infrastructure and private equity investment manager, which has been managing investment funds on behalf of institutional and retail investors for more than 30 years. The Group operates from its offices across various countries that are listed on the Foresight website at https://www.foresightgroup.eu/contact..
Foresight has large and growing networks of relationships with investors and their advisers, including institutional investors and Family Offices Worldwide and many High Net Worth and retail investors and their independent financial advisers, predominantly in the UK. In order to generate potential deal flow and identify suitable investment opportunities in the above-mentioned sectors, Foresight has similarly developed large and growing networks with a variety of parties including corporate financiers, accounting firms, lawyers, banks, brokers, non-executive directors, consultancies and infrastructure and private equity industry participants, principally in the UK, mainland Europe, Australia and the USA.
Foresight’s AUM (assets under management) span a number of Foresight fund entities, including Stock Exchange Listed Vehicles, OEICs, Limited Partnerships, Inheritance Tax Schemes (ITSs), Enterprise Investment Schemes (EISs) and Venture Capital Trusts (VCTs). Further information about Foresight’s AUM can be found on the Foresight Group website at About us (foresightgroup.eu)
The Group parent, Foresight Group Holdings Limited, was listed on the Main Market of the London Stock Exchange on 4 February 2021. Its principal operating entity, Foresight Group LLP, is authorised and regulated by the Financial Conduct Authority (“FCA”), ref no. 198020 and headquartered in The Shard, 32 London Bridge Street, London SE1 9SG. Foresight Group LLP is also a Registered Investment Adviser with the U.S. Securities and Exchange Commission, registration code 311974.
Foresight Group Luxembourg S.A, is registered in Luxembourg and authorised and regulated by Commission de Surveillance du Secteur Financier, Luxembourg, ref no A00002875 (AIFM) and S00001082 (AIFMD) and head quartered in 55, Allée Scheffer, L-2520, Luxembourg.
Foresight Group CI Limited is authorised and regulated by the Guernsey Financial Services Commission, ref no. 2006518 and headquartered at PO Box 650, 1st Floor, Royal Chambers, St Julian’s Avenue, St Peter Port, Guernsey GY1 3JX.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data which does not relate to an identified or identifiable person (anonymous data).
Your personal data will be held securely in Foresight’s systems and archives so that we and any other entities in our Group that you have dealings with, either now or in the future, can manage your relationship with us. This will include personal data you provide to us, and any additional personal information provided by you or others in various ways, including:
We may collect, process, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
When applying to Foresight for potential funding, companies and their various advisers provide a wide range of information to Foresight about their business, products, markets, plans and prospects which includes personal data relating to their past, existing and prospective directors, officers, shareholders, employees, agents and contractors as well as principal customers and suppliers etc. When assessing such opportunities, Foresight treats all such information in confidence, whether obtained under the terms of non-disclosure agreements or not.
In assessing such potential investment opportunities in more detail, Foresight may seek references from third parties and also may require third parties to carry out detailed due diligence (e.g. on the senior management team, the company’s financial affairs and prospects, customers and suppliers) which will generate further personal data. Similarly, once invested in a company, further additional personal data will arise over time. Even after an investment has been realised, Foresight will hold and be obliged to hold data about the investment including such personal data under FCA rules and the Companies Act 2006, and other applicable non-UK legislation and regulations.
In the course of assessing and making investments, we may collect, process, use, store and transfer different kinds of personal data about you as grouped above, which may include data expressing opinions about you.
When recruiting, Foresight often uses the services of recruitment consultants who nominate potential candidates for each particular vacancy by forwarding CVs and their views on the merits of each candidate to us. Similarly, Foresight often receives unsolicited CVs, emails and letters from individuals enquiring about possible vacancies. Please click here to view current vacancies. Data on candidates not selected may be retained for a short period (normally up to twelve months, unless the candidate specifically allows it to be kept for longer) before being destroyed to see if other suitable vacancies arise in the meantime.
We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to enable us to decide how to improve the usefulness and efficiency of our websites. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Special Categories of Personal Data
Occasionally, in order to carry out our business, it may be necessary for us to process special category data about you (for example because you have asked about inheritance tax solutions where your health is relevant, or because we need health information from principal parties when we are considering investing in their companies). Special category data includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We also collect information about criminal convictions and offences of principal parties when we are considering investing in their companies, as well as conducting background and criminal checks on prospective candidates for employment and on existing employees for regulatory purposes.
We will only ever process such data in a manner that is allowed by data protection laws. This means that in some circumstances we may need your explicit consent to process this data, which we will request when required. You may withdraw such consent at any time.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Foresight does not utilise automated data scoring technologies when assessing investment opportunities.
We will only use your personal data when allowed by law. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message if you are a private individual, sole trader or partnership. You have the right to withdraw consent to marketing at any time. Please see the “Opting out” section below.
We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To establish you as a new customer, investor or employee | (a) Identity (b) Contact (c) Anti-financial crime and criminal background checks (d) For investment related business only, credit reference checks | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation |
To process your application and manage your investment including: (a) Receive payments, fees and charges and make payments to you including distributions from funds or investments or the proceeds from the realisations of investments (b) Collect and recover any money owed to us (c) Carry out or update identity and similar checks for anti-money laundering and anti-financial crime purposes. | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate Interests Necessary to comply with a legal obligation |
To manage our relationship with customers including: (a) Notifying you about changes to our terms or privacy policy (b) Notifying you about the performance of your investment by sending you updates, newsletters and reports (c) Where relevant seeking your decision on whether or not you wish to remain invested in a particular fund or, as a shareholder in a specific fund agree or not with a particular proposed course of action (b) Asking you to leave a review or complete a survey | (a) Identity (b) Contact (c) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to participate in a competition or to complete a survey | (a) Identity (b) Contact (c) Usage (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To manage the efficient operation of our business and the provision of products and services and also protect our business and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for managing the efficient operation of our business, the provision of products and services to you, the provision of administration, IT services and network security and the prevention of fraud) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and marketing to you and measure or understand the effectiveness of our marketing | (a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical | Necessary for our legitimate interests (to study how customers use our products/services, our websites, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy) |
| To inform independent financial advisers about new or existing products or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Foresight will process your data only to the extent necessary to comply with the above purposes and activities, in particular in providing the products and services to which you have agreed. Data will be processed for as long as is necessary either under the terms of the contract between us or required by law. The processing of the data will include collection, recording, organisation, structuring, storage, adaptation, amending or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Data may be processed electronically or manually, including being stored electronically or as a paper copy. We do not take decisions about you using automated decision-making software.
We will always give the opportunity to manage your marketing preferences, including the ability to opt out of our marketing. We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you might want or what might be of interest to you. Please see the “Opting Out” section below.
You may receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for an event or a promotion and, in each case, you have not opted out of receiving that marketing.
We may monitor or record phone calls with you in case we need to check we have carried out your instructions correctly and to resolve queries or issues. Our lawful basis for doing this is the performance of our contract with you. We may also monitor or record phone calls with you for regulatory purposes (the lawful basis on which we do this is so as to comply with our legal obligations), to help improve our quality of service, to help detect or prevent fraud or other crimes, and for staff training purposes (the lawful basis for these activities being our and your legitimate interests).
As part of our ongoing commitment to understanding our customers better, we may research comments and opinions made public without restriction on websites and social networking sites such as Twitter, Facebook and LinkedIn. The lawful basis on which we do this is our and your legitimate interests.
Foresight will not share your data with third parties for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. The unsubscribe email address is: unsubscribe@foresightgroup.eu.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of investing in a Foresight product or service or other transaction with Foresight.
We also collect information from you when you visit our website. Our website automatically collects information from your computer using “cookies” which provides us with limited personal information. Cookies are small text files that are placed on your computer or other device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the website owners. For further information please read our Cookie Policy.
You can set your browser not to accept cookies and our Cookie Policy tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
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.
Please note that we may process your personal data without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.
| PURPOSE / ACTIVITY | LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST |
Providing you or your business with products and services and notifying you about important changes or developments to the operation of those products and services. | Performance of a contract with you. |
Responding to your enquiries and complaints. | Performance of a contract with you. |
Undertaking financial reviews. | Necessary to comply with a legal obligation. |
Updating, consolidating, and improving the accuracy of our records. | Necessary to comply with a legal obligation. |
Undertaking transactional analysis. | Necessary for our legitimate interests. |
Arrears and debt recovery activities. | Necessary for our legitimate interests. |
Testing new systems and checking upgrades to existing systems. | Necessary for our legitimate interests. |
Crime detection, prevention and prosecution. | Necessary for our legitimate interests. |
Evaluating the effectiveness of marketing, and for market research and training. | Necessary for our legitimate interests. |
Statistical analysis with the aim of developing and improving products and services. | Pursuing our legitimate interests. |
Assessing risks across the Foresight Group. | Pursuing our legitimate interests. |
Managing your relationship with Foresight Group companies. | Pursuing our legitimate interests. |
By sharing this information, it enables us to better understand you and your business' needs and manage our relationship efficiently. Your personal information may also be used for other purposes for which you give your specific permission, or, in very limited circumstances, when permitted by Data Protection legislation.
We may have to share your personal data with the parties set out below for the purposes and on the lawful basis set out in the table in section 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share the personal data we hold about you across the Foresight Group and our agents for the following activities: (a) providing you or your business with products and services and notifying you about important changes or developments to the operation of those products and services; (b) responding to your enquiries and complaints; (c) administering offers, competitions and promotions; (d) undertaking financial reviews; and also for the following data sharing activities: (e) updating, consolidating, and improving the accuracy of our records; (f) undertaking transactional analysis; (g) arrears and debt recovery activities; (h) testing new systems and checking upgrades to existing systems; (i) crime detection, prevention and prosecution; (j) evaluating the effectiveness of marketing, and for market research and training; (k) statistical analysis with the aim of developing and improving products and services; (l) assessing risks across the Foresight Group; (m) managing your relationship with Foresight Group companies. By sharing this information, it enables us to better understand you and your business’ needs and manage our relationship efficiently. Your personal information may also be used for other purposes for which you give your specific permission, or, in very limited circumstances, when permitted by Data Protection legislation.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Specific third parties listed in the table in section 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
From time to time we may need to share your personal data with organisations which may be based outside the United Kingdom, Guernsey, Jersey and the European Economic Area (EEA). We take steps to ensure that any international transfer of information is managed carefully and in accordance with data protection law to protect your rights and interests.
These measures include:
You have the right to ask us for more information about our safeguards. Please contact the GDPR Panel whose contact details are set out above.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see below for further information.
We may sometimes anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We may also retain your personal data where necessary to pursue our legitimate interests (for instance, to be able to defend a Foresight company against alleged or actual claims or legal actions).
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
You have certain rights regarding your personal data. These include the rights to:
Where we rely on our legitimate interests to obtain and use your personal data then you have the right to object if you believe your fundamental rights and freedoms outweigh our legitimate interests. Where processing is carried out based upon your consent, you have the right to withdraw that consent.
Your ability to exercise these rights will depend on a number of factors and in some instances, we will not be able to comply with your request e.g. because we have legitimate grounds for not doing so or where the right does not apply to the particular data we hold on you.
You should note that if you exercise certain of these rights we may be unable to continue to provide some or all of our services to you (e.g. where the personal data is required by us to comply with a statutory requirement or is necessary in order for us to perform our contract with you).
Please contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate.
You may also exercise a right to complain to your Supervisory Authority (see https://edpb.europa.eu/about-edpb/board/members_en for a list of national supervisory authorities). Please contact the GDPR Panel if you wish to exercise any of your rights.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Please note there may be some latency in deleting your personal data from all our systems and those of any third parties which process such data on our behalf.
