Data Protection & Privacy Statement

Propcure is a trading name of Sturgeon Ventures LLP (company number: OC319614), Linstead House, 2nd Floor, 9 Disraeli Road, London, SW15 2DR, United Kingdom. Sturgeon Ventures (us or we) is committed to ensuring that your privacy is protected, and all data collected by us will be processed in accordance with this Data Protection Privacy & Cookies Policy. Please read this statement carefully to ensure you understand our views and practices regarding your personal data and how we will treat it.

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR), the data controller is Sturgeon Ventures LLP of Linstead House, 2nd Floor, 9 Disraeli Road, London, SW15 2DR. We can be contacted at hello@sturgeonventures.com or on 020 3167 4652.

By visiting our Site or by providing us with information you are accepting the practices described in this Data Protection Privacy Statement.

Personal information (or ‘personal data’) means any information that can identify a living person, whether directly or indirectly. We collect and process personal demographics such as your title name, address, phone number and email address.

We will process personal information about you that we have collected from the website https://www.propcure.com/ (the Website). We collect information when you submit information to us directly using the contact form on the Website. We also collect information automatically when you use the Website. This includes technical information including the internet protocol (IP) address used to connect to the internet, information about your visit including the full uniform resource locators (URL) clickstream and your search history on the Website.

When you provide us with your information in making an enquiry, we will use it for the purpose of administering your enquiry and responding to you. We have legitimate interests in processing your personal data in this way, since if we do not process your data, we will be unable to do this.

When we collect information from you (or the entity you work for), we use it in order to consider your application for an investment in MTR004 Limited (“the Fund”). We have legitimate interests in processing your personal data in this way, namely, to assure ourselves of your status as a Professional or Certified High Net Worth or Sophisticated Investor.

Should you choose to invest in the Fund, your personal data will be used for all investor communication. Your personal data will also allow us to provide a secure reporting space for updates of the Special Purpose Vehicles (SPV) in which you have invested.

We may also process your personal information collected on our Website on the basis of our legitimate interests in providing you with the best possible service:

  • to ensure that the content from the Website is presented in the most effective manner for you and your computer;
  • as part of our efforts to keep the Website safe and secure; and
  • for internal analytical and statistical purposes.

We will only supply your personal information to a third party:

  • where we need to share the information to provide a product or a service requested by you;
  • where we need to send the information to persons or organisations who work on our behalf to provide a product or service to you, in which case such persons or organisations may only use this information in order to provide such product or service and not for any other purpose;
  • companies which perform marketing services on our behalf or with whom we have joint marketing agreements, where we have your consent to share the information;
  • if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets; or
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of our company, our clients or others, including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The data that we collect from you is stored in the UK in a recognised CRM system with 256-bit Advanced Encryption Standard (AES) encryption. We will retain your information for six years, after which time it will be destroyed.

When you use the Website, we may obtain information about your computer and general internet usage, including your IP address, operating system and browser type, for system administration purposes.

Cookies contain information that is transferred to your computer’s hard drive. Cookies allow us to tailor our Website to your needs by gathering and remembering information about your usage and preferences.

In particular, cookies enable us:

5.3.1 to gather information on IP addresses and pages visited;

5.3.2 to analyse trends;

5.3.3 to administer the website;

5.3.4 to track users’ movements on the website; and

5.3.5 to undertake statistical analysis.

Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Website or accessing certain parts. Our system will issue cookies when you access our Website unless you have adjusted your browser settings so that it will refuse cookies.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

The table below provides more information about the cookies we use and why:

Name of cookie

Owner

Purpose for the cookie

Google Analytics

This is a web analytics service provided by Google Inc which uses cookies to show us how visitors found and explore our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (eg how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had.

DoubleClick.net


YouTube has inbuilt advertising and uses DoubleClick.net to display relevant ads. As such this gets embedded at the same time.

Option



Link out to YouTube

Session Cookies



To allow access to the Investment Enquiry Forms

Windows 10 uses the Microsoft edge

Chrome, Firefox etc

Windows 10 uses the Microsoft edge browser by default unless you install Chrome, Firefox etc

Most browsers allow you to refuse to accept cookies; for example:
in Firefox (version 51) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; in Chrome (version 55), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading; and in Internet Explorer (11) you can turn “Cookies” off by opening Internet Explorer, click Internet options and select the “Privacy” tab. Under “Settings” move the slider to the top or bottom to decline or allow “Cookies” by selecting high or low and then press “apply”.

You can delete cookies already stored on your computer; for example:

  • in Firefox (version 51), you can delete all cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”;
  • in Chrome (version 55), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”; and
  • In Internet Explorer (11) you can select the safety button and then select Delete Browsing History. Then select the check box next to “Cookies”. Select the “preserve favourites” website data check box if you don’t want to delete the “Cookies” associated with website in their favourites list. Select delete.

The Website does not contain links to and from other websites.

The GDPR gives you a number of rights in respect of your personal data, including:

7.1 Right to access
7.1.1 You have the right to access the information we hold about you. We may request proof of your identity before sharing such information.

7.2 Right to rectify your personal data 7.2.1 If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information.

7.3 Right to be forgotten 7.3.1 You may ask us to delete information we hold about you in certain circumstances. It may not be possible for us to delete all of the information we hold about you where we have an ongoing relationship, however please contact us and we will do our best to assist with your request.

7.4 Other rights
7.4.1 In addition to the above, you may also ask us to stop or restrict processing of the information we have about you. You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any other information on these aspect of your rights or would like to exercise them, please contact us using.

8.1 If you have any questions, want to exercise any of your rights or make a complaint, please contact us using the details at the beginning of this statement.

8.2 If we are unable to resolve your complaint you may contact the Information Commissioner’s Office at the Exchange Tower, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tele: 0303 123 1113.

This statement may be reviewed and amended from time to time. As a result of improvements we make to our services, changes in the law or developments in technology, we may change the information we hold about you, the method and purposes for which we process such information. If we make any substantial change in the way in which we use your personal information we will notify you by email.

Your use of the Website is subject to the laws of England and Wales and the exclusive jurisdiction of the English courts regarding any disputes that may arise under it.

RISK WARNING

MTR 004 Limited (the "Fund") invests in assets that may at times be hard to sell. This means that there may be occasions when you experience a delay or receive less than you might otherwise expect when selling your investment. For more information on risks, see the Private Placement Memorandum (PPM) and Key Information Document (KID).