Privacy Policy

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.

The details of our principal operating entities and ultimate parent company are as follows:

Group Contact Name: GDPR Panel Group Contact

• Postal Address: Foresight Group LLP, The Shard, 32 London Bridge Street, London SE1 9SG Group Contact
• Telephone Number: 0203 667 8100
• Group Contact Email Address: DProtection@foresightgroup.eu

Name of Legal Entity: Foresight Group LLP (No. OC300878: registered in England and Wales and authorised and regulated by the Financial Conduct Authority)

• Address: Foresight Group LLP, The Shard, 32 London Bridge Street, London SE1 9SG

Name of Legal Entity: Foresight Group CI Limited (No. 51471: registered in Guernsey and authorised and regulated by Guernsey Financial Services Commission); and

• Group parent, Foresight Group Holdings Limited (No. 51521: registered in Guernsey)
• Address: PO Box 650, 1st Floor, Royal Chambers, St Julian’s Avenue, St Peter Port, Guernsey, GY1 3JX

Name of Legal Entity: Foresight Group Australia PTY Ltd (No. 35050949) registered in Australia

• Address: Level 5, 20 Hunter Street, Sydney, NSW 2000

Name of Legal Entity: Foresight Group Italia S.R.L. (No. 18192571000: registered in Italy)

• Address: Piazza Barberini, 52, 00187 Rome, Italy

Name of Legal Entity: Foresight Group Investment Advisory Iberia S.L.U (No. B-22906267: registered in Spain)

• Address: C/ José Abascal 56, 28003, Madrid Spain

Name of Legal Entity: PiP Manager Limited (No. 09425434, registered in England and Wales and authorised and regulated by the Financial Conduct Authority)

• Address: c/o Foresight Group LLP, The Shard, 32 London Bridge Street, London, SE1 9SG

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 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 40 years. The Group operates from its offices across various countries that are listed on the Foresight website at https://www.foresight.group/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 (foresight.group)

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 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.

• Identity Data includes title, gender, forenames, surname, maiden name, user name or similar identifier, marital status, date of birth, nationality, tax number and national insurance number, passport, utility bills and similar information required under Anti Money Laundering legislation, and your image as may be recorded on CCTV when you visit certain of our offices.
• Contact Data includes correspondence and billing address, delivery address, post code, email address and telephone numbers.
• Financial Data includes bank account details including IBAN and SWIFT codes.
• Transaction Data includes details of products and services you have purchased from us, details about payments to and from you and details about parties related to you where relevant, including details about your Independent Financial Adviser, other advisers e.g. accountant or solicitor, your attorneys and trustees, your beneficiaries, your executors and HM Revenue & Customs and your authorisation to deal with the same.
• Technical Data includes internet protocol (IP) address (a string of numbers unique to your computer that is recorded by our web server when you use or request anything from our website which is used to monitor your usage of our website), your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and our services.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

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.

You or your advisers or your attorney or other representative may give us your personal data by filling in forms, giving us information in hard copy or electronically or by corresponding with us by post, telephone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• view our websites or LinkedIn or Facebook pages;
• seek information on our products and services;
• request marketing or our publications to be sent to you;
• attend our offices or events or promotions or complete a survey or enter competitions;
• give us some feedback;
• seek funding from Foresight for an investment opportunity; or
• seek employment with us.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy section below for further details.

Foresight does not utilise automated data scoring technologies when assessing investment opportunities.

We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties;

1. analytics providers such as Google based outside the United Kingdom, Guernsey, Jersey and the European Economic Area (EEA);
2. credit reference, criminal record background and anti-money laundering agencies such as Experia, Worldcheck and Veriphy;
3. search information providers based inside the UK, Guernsey, Jersey and the EEA, and where necessary and/ or relevant, outside those areas;

• Contact, Financial and Transaction Data from providers of technical, payment, delivery and other services based inside the UK, Guernsey, Jersey and the EEA, and where necessary and/ or relevant, outside those areas;
• Identity and Contact Data from publicly available sources such as providers of directories of independent financial advisers, Companies House, websites and the Electoral Register based inside the UK, Guernsey, Jersey and the EEA, and where necessary and/or relevant, outside those areas;
• Independent Financial Advisers and your other advisers, such as accountants and solicitors;
• When you are seeking finance from Foresight, we may receive personal data about you from third parties, such as corporate finance advisers, referees, due diligence providers and industry consultants and participants;
• Recruitment consultants seeking to fill vacancies notified to them by Foresight, which put you forward as a possible candidate for the particular role;
• Registrars and Receiving Agents, such as Computershare and Woodside.

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 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.

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.

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.

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.

AIB Foresight SME Fund LP

Foresight Accelerated Inheritance Tax Solutions

Foresight Energy Infrastructure Partners

Foresight Energy Infrastructure Partners II

Foresight Enhanced Inheritance Tax Fund

Foresight Enterprise VCT plc

Foresight Environmental Infrastructure Limited

Foresight Global Real Infrastructure (Lux) Fund

Foresight Inheritance Tax Solutions 

Foresight Natural Capital Partners II

Fund Foresight Nottingham Fund LP

Foresight Regional Investment LP

Foresight Regional Investment II LP

Foresight Regional Investment III LP

Foresight Regional Investment IV LP

Foresight Regional Investment V LP

Foresight Regional Investment VI LP

Foresight Regional Investment VII LP

Foresight Regional Investment VIII LP

Foresight Solar Fund Limited Foresight South Yorkshire Evergreen Fund

Foresight Technology EIS Fund

Foresight Technology VCT plc

Foresight VCT plc

Foresight Ventures VCT Plc

Foresight West Yorkshire Growth Fund

ForVei II

FP Foresight Global Real Infrastructure Fund

FP Foresight Sustainable Future Themes Fund

FP Foresight Sustainable Real Estate Securities Fund

FP Foresight UK Infrastructure Income Fund

FP WHEB Sustainability Impact Fund

Iberian Solar Group

IFW – Equity LP

Italian Green Bond Fund

Korean Australia SMA

Korean UK SMA

Korean German Wind SMA

Liontrust Diversified Real Assets Fund

MEIF ESEM Equity LPNI Opportunities Fund

NI Opportunities II Fund

Pengana Wheb Sustainable Impact Fund

PIP MSI

SEB Impact Fund

Scottish Growth Scheme – Foresight Group Equity Finance LP

Thames Ventures EIS Fund

UK LGPS Pension Fund SMA

WHEB Environmental Impact Fund

WHEB Sustainability Impact Fund 

Averon Park Limited (and its subsidiaries)