Who We Are
Investing Women Angels Ltd.
Investing Women Angels (‘IWA’) is a growing community of women angel investors; women entrepreneurs seeking growth and those who want to help both. We are more than an angel group; and are driven by more than the money.
We aim to facilitate a substantial improvement in female angel investment activity and female-led companies in Scotland by helping to raise the knowledge, skills and networks of those involved. Investing Women Angels Ltd supports our Members (the ‘Angels’), and entrepreneurs/founders that are seeking investment from our IWA members, and our existing investee companies.
We make use of personal information, which members and entrepreneurs provide us with. In this notice you can read how we collect and use personal information, as well as your rights in relation to this. If you have any questions, please don’t hesitate to contact us.
Importantly, any personal data collected and held by Investing Women Angels Ltd and our associates is treated in line with the principles of the General Data Protection Regulation 2016.
Financial and personal data regarding entrepreneurs seeking investment and individual deals are stored on Dealum. All IWA members who have access to Dealum have access to personal data submitted consensually by entrepreneurs seeking, or in receipt of investment from IWA as part of a contract between the (potential) investee and the Angel members.
Please note, business information submitted to IWA by entrepreneurs and investee companies is governed by the Confidentiality Agreement (IWA Membership Documentation, 9.1).
Processing and Use of Personal Information
GDPR Art 6 (1) (a) Consent: the individual has given consent to the processing of his or her personal data for one or more specific purposes.
(b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
Where users have previously bought or solicited products or services from Investing Women Angels, legitimate interests (GDPR Art 6 (1) (f)) may also act as a basis for legal processing and communication.
It is the responsibility of the Joint Controllers to observe these rights and act upon requests in relation to these rights from individuals whose personal data is held by Investing Women Angels.
Information we hold about you will often come from you directly.
That information will include the following:
We will also hold information about you should you contribute or appear within the content of blogs and videos
Purposes of Data Processing and Storage
To inform about news, events, projects, investments and other initiatives related to the work of Investing Women Angels Ltd.
To inform our members of information regarding meetings, investment opportunities and updates from investee companies and the annual member renewal process.
To hold and process invoices from Investing Women Angels Ltd for membership, event booking payments, or investments in investee companies.
We also hold financial information (including details of funds invested in). Sensitive information regarding potential and current investee companies are held on password protected files. Bank account details may be held on Xero or by the data controllers for the purposes of live investment deals.
Communication from Investing Women Angels Ltd. may take the form of direct email correspondence, direct and newsletter communication from Dealum telephone calls or bulletins sent via our Mailchimp account. Notices may also include information about the activities of other syndicate organisations, for example, when they are providing information or leading a new syndication deal.
Where IWA shares personal data with a third party for it to use for its own or joint purposes, each organisation is a separate 'data controller'. The sharing might be one-off, long-term or ongoing. The third party will be closely 'related to' IWA (such as key partners or sponsors of a specific project). Sharing data with third parties will only occur when the data subject opt in and they have a right to rectification, to restrict processing and the right to erasure. This can include business support and mentoring requests and to enable the use of our or our Partner services and facilities securely and for us to deliver the services you have requested.
Data Retention and Rights of the Data Subject
Investing Women Angels will keep personal information as long as it is necessary for the purpose for which it was obtained, in compliance with existing regulations and unless asked to delete it at an earlier time. Data subjects have the following rights, including the right to erasure (the ‘right to be forgotten’) as set out in GDPR Articles 12-23.
We will take all reasonable steps to destroy, or erase from our systems, all personal data which is no longer required.
Please note that you may contact us at any time at firstname.lastname@example.org and ask for your details to be removed (please refer to the section headed “Access and other rights” above). We may not be able to continue to provide you with our services in the event you request that your details are removed.
It is the responsibility of the Joint Controllers to observe these rights and act upon requests in relation to these rights from individuals whose personal data is held by IWA.
Data Controllers and Processers
The Joint Controllers and Processers of personal data on behalf of IWA are IW associates, comprising: Elaine Bone, Caroline Mitchell, Hollie Bruce, Alison Jones, and Elizabeth Pirrie. These persons can view the data specified in our Data Audit.
Furthermore, members of the Investing Women Angels Ltd Board and screening committee will have access to basic personal information of IWA members, entrepreneurs and investee companies in the function of the company.
All IWA members who have access to our Investment platform Dealum have access to personal data submitted by entrepreneurs seeking, or in receipt of investment from IWA as part of a contract between the (potential) investee and Angel members. Members can also see data submitted by fellow members on the platform. Business information submitted to IWA by entrepreneurs and investee companies is governed by the Confidentiality Agreement (IWA Membership Documentation, 9.1).
Our appointed lawyer, Aberdein Considine, also hold information as stated on our members register. For anti-money laundering (AML) regulations, all members are requested to provide Aberdein Considine with a copy of their Passport or Driving License, and either a Council Tax bill, Credit or Bank Statement or Utility Bill linking the member to their present residential address. Please note, IWA Joint Controllers do not have access to AML documentation, and users are encouraged to read the Aberdein Considine Privacy Notice.
Data Storage and Protection
Personal information may be stored in one of the following locations: Outlook (Investing Women Email host), Dealum, Zoom, Microsoft (including Forms and OneDrive), Mailchimp, Eventbrite, Zoom, Wordpress, Aberdein Considine, YouTube, associate’s hard-disk, Google Drive, Xero and Dropbox.
IWA hard-drives are password protected. Under GDPR regulations, Investing Women staff, Data Controllers and Data Processors have a duty to report any data breach to the UK Information Commissioner’s Office.
Investing Women Ltd. retains an audit of the type of personal information held, where this data is held, and the purpose and legal basis for processing this data. This can be provided upon request.
Information Sharing and Third Parties
Moreover, although we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our web site.
Further, select data relating to the third parties where individuals have consented to data to be processed by named third parties will be shared for own and joint purposes. Sharing data with third parties will only occur when the data subject opt in and they have a right to rectification, to restrict processing and the right to erasure. This can include business support and mentoring requests and to enable the use of our or our Partner services and facilities securely and for us to deliver the services you have requested.
Information We Collect
We hold personal data about you which you provide to us in the course of meetings or correspondence between you and us, or (where you are a member or potential member) via our membership forms via Dealum. We may, on occasion, be provided with information by you or our solicitor or by an existing member or board member. We will promptly notify anyone whose data we receive that we are holding that data.
Member (or Potential) User-Provided Information
You can provide us with information about yourself, such as your name and e-mail address, by registering with https://www.investingwomen.co.uk/join/ or by submitting a webform enquiry, which are redirected to our email@example.com email address.
If you correspond with us by email, we may retain the content of your email messages, your email address and our responses. We may also retain any messages you send through www.investingwomen.co.uk.
We hold the following information on members and potential members:
Our lawyers, Aberdein Considine, hold our Members Register and have access to the following details:
For anti-money laundering regulation all members are requested to provide us with the following:-
Please note, IWA Joint Controllers do not have access to AML documentation, and users are encouraged to read the Aberdein Considine Privacy Notice.
Entrepreneurs and Investee Companies
When entrepreneurs are invited to the IWA screening or pitch meetings, they will be asked to submit basic personal data via Dealum, comprising:
Users have the option to include:
If you are invited to participate in our Pitch meeting events, your pitch will be recorded and distributed to IWA Ltd members only as part of the fundraising process. The videos will be uploaded to a third party site (YouTube) and listed under YouTube’s unlisted privacy setting. This allows us to issue the link to our members but it will not be shown in any search engine results.
Please note, GDPR does not apply to business information, and all business information submitted to IWA by entrepreneurs and investee companies is governed by the Confidentiality Agreement (IWA Membership Documentation, 9.1).
Newsletter and Website Registration
A user does not have to register to use Investing Women Angels’ website, but a user must register if they wish to receive information and updates via email. IWA Members receive newsletter updates from the Dealum platform.
We use a third-party provider, Mailchimp, to deliver our newsletter with Investing Women Ltd. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see Mailchimp’s privacy notice.
The registration information we require to allow a user to register is the full name and email address of the user if they wish to receive email updates. This information is stored securely on our database until such time as a user chooses to unsubscribe from receiving news stories. Users who no longer wish to receive our newsletters and other updates may opt-out of receiving these communications by clicking unsubscribe option on any email communication received or by contacting the Joint Controllers or Investing Women via the ‘contact us’ form on our website.
Event Ticketing and Membership Subscriptions
Event bookings and event ticketing are routed through Investing Women’s Eventbrite account. Those wishing to book for an event must complete the ticket order form detailing first name, last name and email address. Optional information may be provided by the user as displayed. To “pay by invoice”, users will also need to enter either an email address for an email invoice, or a postal address for a hard copy invoice.
We typically provide an attendee list of names and organisational affiliation at our events to aid delegates with networking. Furthermore, we take photographs of proceedings in order to highlight or showcase Investing Women activities. You will be asked to provide consent for this use of your data in this way when signing up for events, and are freely able to refuse to provide this.
From time-to-time, we may requests information from users via surveys. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and email address), feedback for potential investee companies and an estimation of investment interest. Contact information will not be shared with any third parties unless we give prior notice and choice. Though we may use an intermediary to conduct these surveys, they may not use users' personally identifiable information for any secondary purposes.
Information Sharing - Legal Disclaimer
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our web site.
We may disclose personal data to third parties for the purposes of finance, IT, professional advice, portal development/support, or for any other purposes specifically permitted by the Data Protection Laws or for any other purpose which you may authorise.
We may also disclose personal data we hold to third parties:
a) in the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets; and/or
b) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
To the extent we transfer any personal data to any third party, we will only do so if that third party agrees to put in place appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, the personal data.
Website and Third Parties
The website seeks to ensure that the information published on its website is up to date and accurate. However, the information on the website does not constitute legal or professional advice and Investing Women cannot accept any liability for actions arising from its use. Investing Women cannot be held responsible for the contents of any pages referenced by an external link.
Any personal data collected through this website and held by Investing Women, Brightstar Scotland or fellow Investing Women associates will be treated in line with the principles of the General Data Protection Regulation 2016.
When you visit www.investingwomen.co.uk, the website may send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser and lets the website help you log in faster and enhance your navigation through www.investingwomen.co.uk. A cookie does not collect personal information about you. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of www.edas.org.uk may not function properly if the ability to accept cookies is disabled.
Cookies and Website Traffic Analysis
When users enter the Investing Women website, their device will automatically be issued with 'cookies'. Cookies are text files which identify users' computers to the Investing Women server. The website then creates "session" cookies to store some of the preferences of users moving around the website, e.g. retaining a text-only preference. Cookies in themselves do not identify individual users but identify only the device used and they are deleted on departure from the website. Many websites do this to track traffic flows, whenever users visit those websites.
The Investing Women website uses third-party cookies to measure use of the website including number of visitors, how frequently pages are viewed, and the city and country of origin of users. This helps to determine what is popular and can influence future content and development. For this purpose, the Investing Women website uses Real-time Analytics to measure and analyse usage of the website. The information collected by Investing Women will include IP Address, pages visited, browser type and operating system. The data will not be used to identify any user personally.
Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these means that certain personalised services cannot then be provided to that user.
This Website contains links to other sites. Please be aware that Investing Women Ltd. is not responsible for the privacy practices of such other sites, and additionally cannot verify the accuracy of the information contained on external sites - by linking to them, we are not endorsing them. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Website that collects personally identifiable information. This privacy statement does not apply to information collected by other websites.
Changes and Notifications
Access and Changes to Your Personal Information
You have the right to request, change, or delete personal information we hold about you (such as postal code, phone, email or postal address). This can be done by sending a request to firstname.lastname@example.org or contacting Investing Women via its website.
Under the General Data Protection Regulation, individuals whose personal data is held by Investing Women Angels have the right make a subject access request for their personal data processed by IWA for stated purposes. As stated earlier in this notice, data subjects have the following rights, including the right to erasure (the ‘right to be forgotten’) as set out in GDPR Articles 12-23.
Notification of Changes
Policy last updated: August 2021