Privacy Policy

Alchemy respects the privacy of visitors to this website and the importance of protecting your personal information.

Alchemy takes privacy and its use of your personal information seriously and acknowledges the importance of protecting any personal information that it holds, i.e., data from which you can be identified (such as your name, address or IP address) ("Personal Information").

This Privacy Policy sets out how we will use data (including Personal Information) collected by us when you visit this website and any other personal information you may provide to Alchemy or which we acquire through our day-to-day business. We aim, as a business, to give information about our privacy commitments directly to all the people whose data we hold. However, we also acquire some Personal Information in an indirect or incidental way (for example, we may acquire Personal Information about individuals in connection with a transaction we are working on). Therefore, this Privacy Policy is also designed to provide privacy information to all the groups of people whose data we hold, but with whom we do not have a direct relationship.

We will ensure that your Personal Information is handled in accordance with applicable data protection legislation, including the UK Data Protection Act 2018, the UK General Data Protection Regulation, the General Data Protection Regulation (EU) 2016/679 (as relevant) and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

The "data controllers" in respect of your Personal Information will be Alchemy Special Opportunities LLP and Alchemy Partners LLP and references in this Privacy Policy to "Alchemy", "we" or "us" means one or both of those entities or, where the context requires, its associated investment funds, the manager thereof and all related entities including but not limited to investment holding companies (but excluding, for the avoidance of doubt, any investee companies of such investment funds).

1. Use of your Personal Information

   1. We may collect (and use for the purposes set out in this Privacy Policy) the following information about you: (i) information that you submit when you make use of this website, for example, when you register with us or respond to online surveys; (ii) information that you provide when you contact us (either online or by any other method); and (iii) details of your visit to our website, including your IP address and choice of web browser (please see section 6 ("Aggregated Data") below).

   2. What sort of Personal Information do we collect?

      1. General

         When contacting us online, via telephone, in writing or otherwise you may provide Personal Information about yourself to us including your name and contact details (e.g. your address, email address and telephone number).

      2. Information about individuals associated with our portfolio companies and assets (or potential portfolio companies and assets)

         When we acquire or invest in a business or asset (or are in a process of doing so) we may obtain some information about: (i) the employees and other staff who work in a business; (ii) the clients of that business; and/or (iii) individuals who may be associated with a relevant asset. We process this Personal Information to operate our business in the pursuit of our legitimate interest.

      3. Information about investors/potential investors/those who work for or are connected with investors

         If you (or an institutional investor or investment vehicle with which you are associated) consider investing with us, you may also provide us with your financial information and various other necessary Personal Information. This processing will be justified by the performance of a contract concluded with you, or for the purpose of corresponding with you for business purposes, providing any support you may require or to process an investment application in accordance with our legitimate interests. In certain circumstances, we may also process your Personal Information for the purpose of complying with our KYC or AML obligations.

      4. Information about those related or otherwise connected to our staff

         We sometimes ask members of our staff to provide details of their next of kin for the purposes of our emergency scenario planning or in case an incident occurs at work. We may also ask for details of their dependents, spouses and/or other people in relation to their employee benefits arrangements. We will only ever use this information for the benefit of our staff and only when justified by our legitimate interest to support our staff.

      5. Information about job applicants

         If you apply for or enquire about a job with us, we may also ask you to provide details of your previous job title, your employment history, a copy of your CV and references - and we may also seek references and carry out checks with third parties if appropriate for the role you have applied for.

      6. Information about individuals who are our suppliers or other business contacts (and individuals who are employed by our suppliers and business contacts)

         If you provide services to us or have a business dealing with us (or are employed or engaged by an entity which provides services or has a business dealing with us), we may acquire your name, contact details, some employment information and we may acquire copies of ID documents or similar information for the purpose of corresponding with you, carrying out and improving our business, analysing the use of our website and services in the pursuit of our legitimate interests.

   3. Grounds for processing

      Under the Data Protection Legislation, there are various grounds on which Alchemy can rely when processing your Personal Information. In some contexts, more than one ground applies. We have summarised these grounds as Contract, Legal Obligation, Legitimate Interests and Consent and outline what those terms mean in the following table:

      Ground for processing	Explanation
      Contract - processing necessary for performance of a contract with you or to take steps at your request to enter a contract	This covers carrying out our contractual duties and exercising our contractual rights.
      Legal Obligation - processing necessary to comply with our legal obligations	Ensuring we perform our legal and regulatory obligations.
      Legitimate Interests - processing necessary for our or a third party’s legitimate interests	We or a third party have legitimate interests in, for example, the day-to-day operation, management and planning of our business; effective recruiting and hiring of job applicants, including checking whether they are legally entitled to work in the UK; protecting our interests and legal rights; preventing fraud; managing the performance and security of our premises and equipment. Your Personal Information will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.
      Consent	You may have given specific consent to processing of your Personal Information.

2. How long do we keep your Personal Information?

   We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation and our own internal rules and policies allow.

3. Your rights and data accuracy

   1. You have certain rights in relation to your Personal Information - for example the right to request that we erase your Personal Information (or part of the information that we hold about you) at any time. We will comply with such requests unless we have a lawful reason to keep the information in question (for example, we need to retain the information to comply with our legal obligations). Please contact us at the email address set out below if you wish to request any changes.
   2. You also have the right, subject to certain exemptions, to: (a) see the Personal Information we hold about you and withdraw any consent you may have given to us; (b) ask us to make any changes to ensure that any Personal Information we hold about you is accurate and up to date; (c) ask us about the contracts that govern the transfer of your Personal Information to third parties outside the United Kingdom ("UK") and the European Economic Area ("EEA"); (d) restrict the processing of your Personal Information in certain circumstances; and (e) in some cases communicate any information we hold about you to a specified third party. If you wish to exercise any of these rights, please contact us at the email address set out below.
   3. Please note that these rights may be limited (e.g., if fulfilling your request for a copy of the Personal Information that we hold about you would reveal Personal Information about another person, where they would infringe on the rights of a third party (including our rights) or if you ask us to delete Personal Information which we are required by law to keep or have compelling legitimate interests in keeping). Where applicable, we will inform you of relevant exemptions we rely upon when responding to any request you make. Please also note that, in certain circumstances, if you exercise your rights in a certain way, this may impact our ability to process the relevant Personal Information for the purpose we originally obtained it (which may prevent us from performing, or otherwise impact, an action that you were expecting us to undertake or carry out).
   4. Please ensure that the Personal Information you provide via the website is accurate and complete and you notify us of any changes to your Personal Information as soon as possible so that we can update our records.
   5. Whilst we will take all reasonable steps to protect your Personal Information, we cannot guarantee the security of any Personal Information you disclose online. By submitting Personal Data to us via our website or by other online means, you accept the inherent security risks associated with the internet.

4. How and why we share your Personal Information

   1. Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your Personal Information with certain third parties who reasonably need it in order to perform a function for you or provide a service to us – such as group entities, our group fund(s), the funds' administrator and our respective advisers. By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information.
   2. In addition, it may be necessary to disclose your Personal Information in order to comply with any legal or regulatory obligation (such as anti-money laundering obligations), to carry out an internal investigation, enforce any agreement we have with you or with a related party, or protect the rights, property, or safety of Alchemy and/or our clients, directors / members (as applicable), employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention.
   3. We may also process and transfer your Personal Information to auditors, advisers, law enforcement bodies or to other entities for the purpose of establishing or defending our legal rights, complying with the law or carrying out an internal investigation.
   4. In processing your Personal Information, it will sometimes be necessary for us to transfer your Personal Information outside the UK and the EEA (e.g. to our suppliers). We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the UK and the EEA. Where any transfer takes place under a written contract, a copy of such contract will be available to you on written request (subject to certain redactions and/or an undertaking from you to respect the confidentiality of that contract).

5. Aggregated data

   1. From time to time, we may aggregate statistics, responses to any surveys and questionnaires, traffic patterns and related website information and disclose such aggregated data to third parties (such as Alchemy's suppliers) for Alchemy's own purposes. Please note that any such aggregated data will not include any Personal Information and we will never make it available to third parties to use for their own purposes.
   2. To enable us to monitor and improve this website, we may gather and record on our servers certain aggregated data about you when you use it, including without limitation, the URL that you came from and go to and the parts of our website that you visit. Such aggregated data is primarily used to provide you with an enhanced on-line experience and will not include any Personal Information.

6. Changes to our Privacy Policy

   Alchemy may amend this Policy at any time. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) this website. Any changes to this Privacy Policy will be posted on this website. Please also note that, in certain circumstances, if you do not agree to any changes to this Privacy Policy, this may impact our ability to process your Personal Information for the purpose we originally obtained it (which may prevent us from performing, or otherwise impact, an action that you were expecting us to undertake or carry out).

   This Privacy Policy was last updated in September 2023.

7. Contact us and complaints

   1. You can opt out of receiving communications from us at any time and/or enquire about or exercise your rights by sending an e-mail to info@alchemypartners.co.uk.
   2. If you have any questions or concerns about the way in which we have handled your Personal Information, please contact us at the email address above. Alternatively, you have the right to make a complaint to the Information Commissioner's Office, the supervisory body in the UK, or (as relevant) to one of the competent European supervisory authorities.