Privacy Policy

We are Nakirfa Ventures Investment Services Limited and we are the data controller responsible for your personal data. Our registered address is Suite XXX, 26 Cheering Lane East Village Stratford, London E20 1BD

If you are a current member we will hold personal data about you. We may also hold your details if you have been a member in the past or have applied for one of our services.

We are committed to keeping your data safe and being clear about how we use and process your personal data.

This statement explains our reasons for processing your personal data. This includes information that you have shared with us directly or data we have collected throughout your membership of the consultancy or your use of our website.

We also tell you about your rights under the laws that are designed to protect your privacy.

We have appointed a data privacy manager, Gideon Doh who is responsible for overseeing questions in relation to this privacy statement.

If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact the Gideon Doh using the details set out below:

Our full details are:

Full name of legal entity: Nakirfa Ventures Investment Services Limited
Data Privacy Manager: Gideon Doh
Email address: info@nvisinvestments.com
Postal address: Suite XXX, 26 Cheering Lane, East Village, London E20 1BD
Telephone number: 020 520 1833

It is important that you read this privacy statement 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 statement supplements the other notices and is not intended to override them.

Website privacy policy 

Why we collect your personal data:

NVIS may collect the following information about you:

What we use your personal information for

Providing your personal data to others

Fraud prevention agencies

Website privacy policy 

Nakirfa Ventures Investment Services Ltd (NViS) is a management consultancy operating in the UK.

This privacy policy sets out how NViS uses and protects any information that you provide to us when using our website and using our services.

NViS is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy policy.

NViS may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

This policy is effective from 03/04/2020

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Why we collect your personal data:

For people visiting our website, signing up to our mailing list or making enquiries about our services we may collect data that allows us to:

• Make our website more tailored for you
• Send out marketing or communications to you if you give your express consent
• Provide our products to you
• Manage any registered account(s) you hold with us
• Verify your identity
• Contact you for market research purposes so that we can provide a better service to you
• Manage delivery of our products to you.

NVIS may collect the following information about you:

We collect many different types of data. This includes information that is necessary for us to provide our products and services, to comply with our legal and regulatory obligations or to serve our legitimate business interests.

Below we list the key types of data we collect, hold, use and transfer. Not all of this information is collected from every member and the examples given for each category are intended to help explain their meaning, rather than being an exhaustive list.

• Data to help identify you – this includes your name, DOB, sex
• Contact details – your address, phone numbers, email address
• Socio-demographic – details of your employment, profession, nationality, education
• Transactional – details about payments to and from your accounts
• Financial – your financial position, status and history
• Contractual – details of products and service we provide to you
• Equalities and lifestyle data – this includes ethnic origin, religious belief
• Behavioural – data about how you use our products or services or interact with our website or our communication
• Consents – this includes things like how you prefer to be contacted and whether you wish to receive email statements
• Communication – data contained in letters, emails or details of phone calls or conversations
• Documentary data – details stored in documents, including ID and address verification like copies of passports, driving licenses or birth certificates.
• Other publicly available data 

The legal basis for this processing is our legitimate interests; monitoring and improving our website and services, complying with our duties and exercising our rights under a contract for the sale of goods to our customers and complying with any legal obligations for legal claims required by companies of the law.

Our website is not intended for children and we do not knowingly collect data relating to children.

What we use your personal information for

Under the EU General Data Protection Regulation, we can only process your personal data if we have a lawful basis for doing so. The reasons we process your personal data are:

• if you have given your consent to the processing of your data for one or more specific purposes
• if it is necessary to fulfil our contract with you
• if it is necessary to comply with a legal obligation
• if we believe it is in our legitimate interest as long as that interest is not overridden by the privacy rights of the individual whose data is being used

By ‘legitimate interest’ we mean the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

Our legitimate interests are balanced against your right to privacy and when we rely on a legitimate interest to process your data we will tell you.

You always have a right to object and you can do this by speaking to a member of staff or emailing info@nvisinvestments.com

Below we outline how we use your personal data, our reasons for doing so and the type of data we are referring to. 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.

Providing your personal data to others

We may share your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

We may also disclose data to our suppliers or subcontractors such as Mailchimp for email newsletters

We also use the payment providers Paypal, and Google pay, if customers select these options as a method of payment.

Fraud prevention agencies

We may need to confirm your identity before we provide you with membership or services to you or your business. Once you have become a member, we will also share your personal information as needed to help detect fraud and money laundering risks. We use Fraud Prevention Agencies to help us with this.

Both LCCU and the fraud prevention agency can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law or for a ‘legitimate interest’.

By ‘legitimate interest’ we mean the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. Our legitimate interests are balanced against your right to privacy.

We will use the information to:

• Confirm identities
• Help prevent fraud and money laundering
• Fulfil any contract you or your business has with us.

NViS or a FPA may allow law enforcement agencies to access your personal information.  This is to support their duty to detect, investigate, prevent and prosecute crime.

FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money laundering.

The information we use:

• Name
• Date of birth
• National Insurance Number
• Residential address
• History of where you have lived
• Contact details, such as email address and phone numbers
• Financial data
• Data relating to you or your business
• Employment details

We and FPAs may process your personal information in systems that look for fraud by studying patterns in the data. We may find that an account is being used in ways that fraudsters work, or we may notice that an account is being used in a way that is unusual for you or your business. Where we or the FPA decide there is a risk of fraud, we may stop activity on your account(s) or block access to them. FPA will also keep a record of any risk associated with you or your business. This may result in other organisations refusing to provide you with products or services or to employ you.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

International transfers of your personal data

We provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

The hosting facilities for our website are situated in the UK with the provider Wordpres.  There should not be any transfer of data outside of this country, if there is it will be the responsibility of WordPress. You can see their privacy policy on their website.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

• https://support.google.com/chrome/answer/95647?hl=en(Chrome);
• https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences(Firefox);
• http://www.opera.com/help/tutorials/security/cookies/(Opera);
• https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);
• https://support.apple.com/kb/PH21411(Safari); and
• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy(Edge).

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Retaining and deleting personal data

We will retain your information for as long as is needed to ensure we comply with our legal obligations in relation to the retention and deletion of personal data.

The data we hold would:

• Normally personal data which will be retained for a minimum period of 2 years and a maximum period of 7 years following the date it was collated.
• In some instances it is not possible for us to specify in advance the timeframe for when your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

On whether you are a customer or not.

• Customer data supplied at time engaging NViS will be retained for a maximum of 7 years.
• Enquiry data will be held for longer if it is deemed that the prospect/customer is still interested in hearing from us. Or if they have unsubscribed, this is so that we can ensure they are excluded from communications.
• We may retain your personal data where such retention is necessary to comply with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person.

Your rights and controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

• Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.
• If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at [business email] Or by managing your subscription from the emails we send you.
• If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.
• We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may ask us to provide you with any personal information we hold about you; it may be subject to:

• the payment of a fee (currently fixed at GBP 10); and
• the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport plus a copy of a utility bill showing your current address).