Privacy notice:
Shareholders and optionholders
Last updated: 2 December 2024
Who you are
This information is relevant to you if you’re a shareholder in Shieldpay, or you have been granted an option or warrant for, or any security that may be converted into, shares in Shieldpay.
Who we are
For the purposes of data protection law, the ‘controller’ of your personal data will be SPG Technologies Ltd, a company registered in England and Wales under number 13725579 and registered as a controller with the ICO under number ZB355802.
What personal data we collect about you
Where we get your personal data from
We will generally get your personal data directly from you; however, we may also be provided with your personal data from investment managers/syndicates that you are a member of.
What we use your personal data for
We'll use your personal data for the purposes listed below. Against each of these purposes, we've identified which categories of personal data listed above are required and the legal ground relied on by us in line with data protection law.
| Purpose | Categories of personal data | Legal ground |
|---|---|---|
| Verifying the identity of shareholders and running sanctions screening checks |   |
Complying with our legal obligations under immigration, anti-money laundering, terrorist financing, sanctions and other financial crime law |
|
Sending you information about the company’s development, shareholder meetings and resolutions |
  |
If the terms of our agreement with you requires us to provide updates, contractual necessity; but otherwise, our legitimate interests in fostering good relations with our shareholders and keeping them informed |
| Enabling you to exercise your legal and contractual rights |  |
In relation to rights and obligations under company law, our legal obligations; and otherwise, contractual necessity by reference to our Articles of Association, Shareholders’ Agreement, Option Agreements and other agreements |
| Receiving and paying subscription monies, dividends and distributions |  |
Contractual necessity by reference to our Articles of Association, Shareholders’ Agreement, Option Agreements and other agreements |
| Maintaining statutory registers and records of shareholder meetings, votes and resolutions | 
|
Complying with our legal obligations under company law and related laws and guidanceWe may also use your personal data for purposes that are compatible with the above purposes |
|
Complying with our legal and regulatory filing obligations |
|
Complying with our legal obligations under company law and related laws and guidance |
|
Fundraising, facilitating or implementing business reorganisation, or the sale or transfer of all or part of the company’s business, assets or shares |
|
Our legitimate interests in pursuing opportunities to raise additional investment, optimise our business structure and, ultimately, secure positive outcomes for our shareholders as a whole |
|
Bringing or defending any legal claims relating to equity ownership |
|
Our legitimate interests in protecting our business interests through bringing or defending legal claims |
We may also use your personal data for purposes that are compatible with the above purposes. In doing so, we'll take into account various factors including the link between the original purpose and the purposes of the intended further processing, the nature of our relationship, the nature of the personal data, the potential consequences for you and any additional safeguards that we can put in place.
Who we share your personal data with
Depending on which of the purposes listed above applies, we may share your personal data with:
- Banks and other payment service providers for the purpose of processing payments to and from shareholders and optionholders
- Companies House for the purpose of complying with our obligations under company law
- HMRC in connection with applying for tax reliefs, making employment-related securities returns and complying with income tax and capital gains rules
- Potential purchasers of our business, assets or shares, if there is a change or anticipated change in the company’s ownership
- Professional advisers including accountants, auditors, company secretarial providers, lawyers and tax advisors, to provide us with professional services
- Regulatory bodies such as the Financial Conduct Authority where necessary to comply with their rules on share ownership and control and the police and other law enforcement agencies, for the purpose of combatting financial crime
- Technical service providers as necessary for us to manage our share capital and our relationship with shareholders and optionholders
- Trustees in bankruptcy and other representatives if you become bankrupt or make any arrangement with the creditors and in the event of your death
How long we keep your personal data for
We’ll only keep your personal data for as long as necessary in connection with the purposes for which we collected it. We maintain a data retention schedule for each category of personal data we hold.
We will retain communications data for up to 3 years, contract data and financial data for 6 years from the date of the relevant contract or transaction, and statutory registers data for 10 years after you cease to be a shareholder or optionholder.