This privacy notice explains how University of Cambridge Investment Management Limited (“UCIM”, “we”, “our”, or “us”) collects, uses and shares the personal data of external business contacts, including other investment managers who provide investment management services to UCIM, and visitors to and the users of the UCIM website hosted at www.ucim.co.uk (the “Site”) (“Users”, “you”, or “your”).
We may amend this privacy notice from time to time. UCIM will notify you of any material changes in this privacy notice by posting an updated copy on the Site. Please check the Site periodically for updates. This page was last updated on 27 June 2023.
If you are a director, officer, employee, authorised signatory, trustee and/or the ultimate controller of organisations which invest in the CUEF, or those which apply to invest in the CUEF (“Investors”), please refer to the Privacy Notice for Investors which is set out as an appendix to the Information Memorandum.
UCIM is the investment manager of the Cambridge University Endowment Fund (the “CUEF”). UCIM is authorised and regulated by the Financial Conduct Authority in the UK with reference number 515843. UCIM is a private limited company incorporated in England and Wales with company number 06907395 and having its registered address at The Old Schools, Trinity Lane, Cambridge, England, CB2 1TN. ICO Registration number: ZA576004.
UCIM is the ‘data controller’ of your personal data and is subject to the UK General Data Protection Regulation (the “UK GDPR”), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 and any successor legislation or regulations governing data protection and privacy in the UK.
Please note that in circumstances where your details are provided to UCIM in connection with your investment in the CUEF or your business relationship with UCIM, then UCIM (or the University of Cambridge (the “University”), which provides administration services) may process your personal data or that of your directors, officers, employees and/or beneficial owners. For more information about this, please see the Privacy Notice for Investors which is set out as an appendix to the CUEF Information Memorandum.
When you use the Site, we may collect your personal data in a number of ways, for example:
We may collect the following types of personal data about Users:
Under the UK GDPR, certain categories of personal information are recognised as sensitive, including health information and information regarding race, religious beliefs and political opinions. We do not seek to collect such “sensitive personal data” but we may obtain it – for example, information concerning health and medical conditions – where Users volunteer this information in communications with us.
We may process your personal data because it is necessary for the performance of a contract with your organisation or in order to take steps at your request prior to entering into such a contract.
We may also process your personal data because it is necessary for our or a third party's legitimate interests. Our "legitimate interests" include our interests in operating the Site in a focused, efficient and sustainable manner. In this respect, we may use your personal data for the following:
We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data for the following:
We may also process your personal data for additional reasons where:
For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may share your personal data with certain third parties. We may disclose limited personal data to a variety of recipients, including:
Your personal data may be transferred to and processed outside of the UK and/or the European Economic Area ("EEA") in countries or territories that do not provide the same level of protection for personal data as the UK and the EEA does. Where this happens, we will put in place appropriate measures to ensure the adequate protection of your personal data when it is transferred outside of the UK and/or the EEA, as required by the EU GDPR and/or the UK GDPR (as applicable). UCIM has put in place Standard Contractual Clauses with relevant parties to whom personal data will be transferred.
UCIM collects standard internet log information and details of individual User behaviour patterns on the Site through the use of tracking tools, such as browser cookies, using the third party service provided by Google Analytics. We do this to analyse the performance of the Site, such as the number of visitors and interactions Users have with the various parts of the Site. Further information regarding how Google Analytics use your personal data can be found here: http://www.google.com/intl/en/policies/privacy/ and https://support.google.com/analytics/answer/6004245.
We will retain your personal data for as long as we are interacting with you via the Site (and subsequently, where we continue to interact with you offline), and for as long as permitted or required for legal and regulatory purposes after the last such interaction between you and us.
Under the UK GDPR, you have the following rights in relation to our processing of your personal data:
Please note that the above rights are not absolute, and we may be entitled (or required) to refuse requests where exceptions apply. For example, if we have reason to believe the personal data we hold is accurate or we can show our processing is necessary for a lawful purpose set out in this privacy notice.
If you have any questions about this privacy notice or how we process personal data, or if wish to exercise any of your rights under applicable law, please contact UCIM’s Data Protection Officer (firstname.lastname@example.org). You may also wish to consult the University’s data protection webpages at https://www.information-compliance.admin.cam.ac.uk/data-protection for further information.