Privacy notice

This document details how we will treat your personal data.

Seneca Partners Limited (“Seneca”) will hold any personal information provided to it in confidence and in accordance with The Data Protection Act 2018 (DPA 2018), The UK General Data Protection Regulation (UK GDPR) and other applicable data protection legislation.

Seneca is registered with the Information Commissioner as a Data Controller under registration number ZA046018.

What is personal data?

Personal data is any information relating to an identifiable person, who can be directly or indirectly identified by reference to such data. Such information includes, name, email address, mailing address.

Seneca will ensure the lawful processing of your personal data.

In this notice, we explain;

  • the types of information we collect about you;
  • how we collect and use this information;
  • who we might share this information with;
  • the steps we’ll take to make sure your personal data remains private and secure; and
  • your rights to access the information we hold about you.

More information

If you have any questions on this policy, you can call us on 01942 271746, email us at compliance@senecapartners.co.uk or write to us at the address below.

Who we are

Under DPA 2018, Seneca is the data controller and processor of personal data for the purposes of its respective business. The data controller is responsible for deciding how your information is used and ensuring it is private and secure.

The information we collect

We collect information about you from different places including:

  • directly from you;
  • from a third party acting on your behalf (e.g. an adviser, intermediary or broker);
  • from publicly available sources; and
  • from other organisations.

We will only collect your personal data in accordance with relevant regulations and law. This may relate to any of our products or services you apply for, currently hold or have held in the past.

You are responsible for making sure you give us accurate and up to date information.

If you provide another person’s information so that they can act on your behalf or access your account with us, please tell them how to find this Privacy Notice and make sure they agree to us using their information for the purposes set out in it.

How we will use your personal data

We will use your personal data to provide any products and services that you have requested. In addition, we may use if for other purposes, such as:

  • to confirm your identity and address;
  • to understand how you use your accounts;
  • to carry out your instructions;
  • to help us make fraud and money laundering checks;
  • to improve our products and services; and
  • to offer you other services we believe may benefit you unless you ask us not to.

We will only use your personal data where we are allowed to by law. This may include carrying out an agreement we have with you, fulfilling a legal obligation, where we have a legitimate business interest or where you explicitly agree to us doing so.

Who we can share your personal data with

We may share your personal with certain third parties who work for us but only where it is appropriate to do so. This may include a custodian, nominee, receiving agent, subcontractors, agents, or service providers. We may also share your information with other companies and agencies e.g. with other Seneca branded companies (but only where it is appropriate to do so), regulators, insurers, brokers and agents, as well as credit reference and fraud prevention agencies.

How long we’ll keep your information

We will keep your personal data for as long as you have a relationship with us. After the relationship ends, we will only keep it where we may need it for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons e.g. fighting fraud and financial crime, and responding to requests from regulators.

Transferring your information overseas

Your information may be transferred and stored in countries outside the European Economic Area (EEA), including some that may not have laws that provide the same level of protection for personal information. When we do this, we’ll ensure it has an appropriate level of protection.

Your rights

You have a number of rights relating to the personal data we hold. Should you wish to use any of these rights then please contact us using the contact details below. Please note that some of these rights are not strictly automatic and we do have the right to consider any request made. In ordinary circumstances we should respond to any request within 30 days of receipt of a request.

Your rights as per UK GDPR are as follows:

  • Right to be informed
    This privacy notice confirms how we collect and use data.

  • Right to access
    You can request a copy of the personal data that we hold about you via a ‘Data Subject Access Request’. If you do, we will respond within one month. Our response is normally free of charge.

  • Right to rectification
    We make every effort to hold accurate data about you. Should you be aware that the information we hold is incorrect, please inform us and we will correct our records, normally within one month.

  • Right to erasure
    You have the right to request that we erase your personal information. We will do so as long as we no longer have a lawful basis for processing your information.

  • Right to restrict
    You can request that we do not process your information in a certain way either in full or in part.

  • Right to object
    If you do not believe that we have a legitimate interest to process your personal data, you have the right to object to this processing. Any and all requests will be fully reviewed by our Data Protection Team and responded to with appropriate actions taken within one month of the objection.

  • Right to data portability
    In limited circumstances you have the right for us to provide you with your data in a format that can be moved to another computer this.  This right only applies to information that you have provided to us which we are processing with your consent or to deliver a contract.  It also only applies to information which is processed electronically.

  • Right in respect of automated processes
    If a decision is made as a consequence of an automated process then you have certain rights. Such rights would include the right to request the decision be reconsidered. At present Seneca does not use automated processes exclusively to make decisions and consequently such rights are not applicable.  However should you believe that we have made a decision based exclusively on an automated process then please contact us and we will review.

Please note we will only seek to obtain sufficient information to allow us to carry out some or all of the activities listed in the “How we will use your data” section. However, you are free to consider our use of your personal data and make a request to apply one or more of the rights specified in this section.

As stated above we can consider and refuse requests in certain circumstances. Please note that under UK GDPR we are not required to consider all potential consequences of processing a request. For example, your request to restrict the use of your information may result in us being unable to provide you with a service you have sought. Therefore we would suggest that you consider all consequences of asserting a right and we would be more than happy to discuss any concerns that you may have.

Nothing in this policy should be construed as seeking to limit or remove your statutory rights. Should you have any concerns in this regard please seek appropriate independent legal advice.

Changes to this Notice

This notice may be updated in light of any changes in legislation. If we change our privacy policy we will post the changes on this page and may place notices on other pages of the Website, so that you may be aware of the information we collect and how we use it at all times. Continued use of the service will signify that you agree to any such changes.

Any Concerns or requests

If you have any queries, wish to exert a right or alternatively wish to make a complaint, please contact the Data Protection Team at:

Address: Seneca Partners Limited, 9 The Parks, Newton-le-Willows, WA12 0JQ

Tel: 01942 271746

Email: compliance@senecapartners.co.uk

Right to escalate any complaint to the Information Commissioner

If you are dissatisfied with our use or management of your personal data, you have the right to complain to the Information Commissioner’s Office (ICO). You can contact them via their website: www.ico.org.uk.

Important notice

The products and services shown on this website place capital at risk. Investors may receive less in returns than they have invested. Investments may not allow for capital to be withdrawn on demand. If an investment provides tax relief then this relief is subject to change and is dependant on personal circumstances. Any reference to past performance or forecasted performance is not a reliable indicator of future performance.

Seneca Partners recommends that any investor seeks specialised financial and/or tax advice before investing. Seneca Partners does not provide advice and the information on this website, including but not limited to news, should not be construed as such.

Please confirm that you understand this warning and wish to proceed.

Risk summary

(Estimated reading time: 2 minutes)

Due to the potential for losses, the Financial Conduct Authority (FCA) considers this investment to be high risk.

What are the key risks?

  1. You could lose all the money you invest
    • If the business you invest in fails, you are likely to lose 100% of the money you invested. Most start-up businesses fail.
    • Advertised rates of return aren’t guaranteed. This is not a savings account. If the business doesn’t pay you back as agreed, you could earn less money than expected or nothing at all. In addition, if the tenant of the property being financed doesn’t pay the rent due as agreed or vacates the premises, you could earn less money than expected. A higher advertised rate of return means a higher risk of losing your money.
  2. You are unlikely to be protected if something goes wrong
    • Protection from the Financial Services Compensation Scheme (FSCS), in relation to claims against failed regulated firms, does not cover poor investment performance. Try the FSCS investment protection checker at https://www.fscs.org.uk/check/investment-protection-checker/.
    • Protection from the Financial Ombudsman Service (FOS) does not cover poor investment performance. If you have a complaint against an FCA-regulated firm, FOS may be able to consider it. Learn more about FOS protection at https://www.financial-ombudsman.org.uk/consumers.
  3. You won’t get your money back quickly
    • This type of business could face cash-flow problems that delay payments to investors. It could also fail altogether and be unable to repay any of the money owed to you.
    • Even if the business you invest in is successful, it may take several years to get your money back. You are unlikely to be able to sell your investment early.
    • Even if you are able to sell your investment early, you may have to pay exit fees or additional charges.
    • The most likely way to get your money back is if the business is bought by another business or is wound
      up following the sale of the underlying property. These events are not common.
    • If you are investing in a start-up business, you should not expect to get your money back through dividends. Start-up businesses rarely pay these. This investment aims to make quarterly repayments that comprise both a partial repayment of capital and interest, although this is not guaranteed. It could take over 14 years to receive back an amount equal to the amount you invested.
  4. This is a complex investment
    • This makes it difficult to predict how risky the investment is, but it will most likely be high.
    • You may wish to get financial advice before deciding to invest.
  5. Don’t put all your eggs in one basket
    • Putting all your money into a single business or type of investment for example, is risky. Spreading your money across different investments makes you less dependent on any one to do well.
    • A good rule of thumb is not to invest more than 10% of your money in high-risk investments. (See https://www.fca.org.uk/investsmart/5-questions-ask-you-invest).

If you are interested in learning more about how to protect yourself, visit the FCA’s website at www.fca.org.uk/investsmart

Application Form Request – Seneca IHT Service


Application Form Request – Seneca AIM EIS Fund


Application Form Request – Seneca EIS Portfolio Fund


Application Form Request – Seneca IHT Service


Application Form Request – Seneca AIM EIS Fund


Application Form Request – Seneca EIS Portfolio Fund


Risk summary

(Estimated reading time: 2 minutes)

Due to the potential for losses, the Financial Conduct Authority (FCA) considers this investment to be high risk.

What are the key risks?

  1. You could lose all the money you invest
    • If the business you invest in fails, you are likely to lose 100% of the money you invested.
    • Many of the loans ultimately financed by your investment are made to borrowers who can’t borrow money from traditional lenders such as banks. These borrowers have a higher risk of not paying back their loan.
    • Advertised rates of return aren’t guaranteed. If a borrower doesn’t pay back their loan as agreed, you could earn less money than expected. A higher advertised rate of return means a higher risk of losing your money.
  2. You are unlikely to be protected if something goes wrong
    • Protection from the Financial Services Compensation Scheme (FSCS), in relation to claims against failed regulated firms, does not cover poor investment performance. Try the FSCS investment protection checker at https://www.fscs.org.uk/check/investment-protection-checker/.
    • Protection from the Financial Ombudsman Service (FOS) does not cover poor investment performance. If you have a complaint against an FCA-regulated firm, FOS may be able to consider it. Learn more about FOS protection at https://www.financial-ombudsman.org.uk/consumers.
  3. You won’t get your money back quickly
    • Some of the loans financed by your investment will last for several years. You may need to wait for your money to be returned even if the borrower repays on time.
    • Some Managers may give you the opportunity to sell your investment early through a ‘secondary market’, but there is no guarantee you will be able to find someone willing to buy.
    • Even if your agreement is advertised as affording early access to your money, you will only get your money early if someone else wants to buy your shares or the company in which you are invested has sufficient available capital to buy them from you. If no one wants to buy, it could
      take longer to get your money back.
    • If you are investing for growth, you should not expect to get your money back through dividends as the Service is not designed to pay dividends to investors seeking growth. If you are investing for income, it will take at least 25 years to get your money back purely through dividends.
  4. Don’t put all your eggs in one basket
    • Putting all your money into a single business or type of investment for example, is risky. Spreading your money across different investments makes you less dependent on any one to do well.
    • A good rule of thumb is not to invest more than 10% of your money in high-risk investments. (See https://www.fca.org.uk/investsmart/5-questions-ask-you-invest).
  5. The value of your investment can be reduced
    • The percentage of the business that you own will decrease if the business issues more shares. This could mean that the value of your investment reduces, depending on the basis on which these new shares are issued.
    • If these new shares have additional rights that your shares don’t have, such as the right to receive a fixed dividend, this could further reduce your chances of getting a return on your investment.

If you are interested in learning more about how to protect yourself, visit the FCA’s website at www.fca.org.uk/investsmart

Risk summary

(Estimated reading time: 2 minutes)

Due to the potential for losses, the Financial Conduct Authority (“FCA”) considers this investment to be high risk.

What are the key risks?

  1. You could lose all the money you invest
    • If a business you invest in fails, you are likely to lose 100% of the money you invested in that business. Most start-up businesses fail. Please see page 14 of the Information Memorandum for an overview of the types of businesses this fund invests in.
  2. You are unlikely to be protected if something goes wrong
    • Protection from the Financial Services Compensation Scheme (FSCS), in relation to claims against failed regulated firms, does not cover poor investment performance. Try the FSCS investment protection checker at https://www.fscs.org.uk/check/investment-protection-checker/.
    • Protection from the Financial Ombudsman Service (FOS) does not cover poor investment performance. If you have a complaint against an FCA-regulated firm, FOS may be able to consider it. Learn more about FOS protection at https://www.financial-ombudsman.org.uk/consumers.
  3. You won’t get your money back quickly
    • Even if the business you invest in is successful, it may take several years to get your money back. You are unlikely to be able to sell your investment early.
    • The most likely way to get your money back is if the business is bought by another business or your shares are sold on the Alternative Investment Market. The latter can only occur if there is a willing buyer.
    • If you are investing in a start-up or EIS qualifying business, you should not expect to get your money back through dividends. Such businesses rarely pay these.
  4. Don’t put all your eggs in one basket
    • Putting all your money into a single business or type of investment for example, is risky. Spreading your money across different investments makes you less dependent on any one to do well.
    • A good rule of thumb is not to invest more than 10% of your money in high-risk investments. (See https://www.fca.org.uk/investsmart/5-questions-ask-you-invest).
  5. The value of your investment can be reduced
    • The percentage of the business that you own will decrease if the business issues more shares. This could mean that the value of your investment reduces, depending on how much the business grows. Most start-up businesses issue multiple rounds of shares.
    • These new shares could have additional rights that your shares don’t have, such as the right to receive a fixed dividend, which could further reduce your chances of getting a return on your investment.

If you are interested in learning more about how to protect yourself, visit the FCA’s website at www.fca.org.uk/investsmart

Risk summary

(Estimated reading time: 2 minutes)

Due to the potential for losses, the Financial Conduct Authority (“FCA”) considers this investment to be high risk.

What are the key risks?

  1. You could lose all the money you invest
    • If a business you invest in fails, you are likely to lose 100% of the money you invested in that business. Most start-up businesses fail. Please see page 14 of the Information Memorandum for an overview of the types of businesses this fund invests in.
  2. You are unlikely to be protected if something goes wrong
    • Protection from the Financial Services Compensation Scheme (FSCS), in relation to claims against failed regulated firms, does not cover poor investment performance. Try the FSCS investment protection checker at https://www.fscs.org.uk/check/investment-protection-checker/.
    • Protection from the Financial Ombudsman Service (FOS) does not cover poor investment performance. If you have a complaint against an FCA-regulated firm, FOS may be able to consider it. Learn more about FOS protection at https://www.financial-ombudsman.org.uk/consumers.
  3. You won’t get your money back quickly
    • Even if the business you invest in is successful, it may take several years to get your money back. You are unlikely to be able to sell your investment early.
    • For companies whose shares are not listed on any exchange (‘unquoted’ or ‘private’ companies), the most likely way to get your money back is if the business is bought by another business or lists its shares on an exchange such as the London Stock Exchange. These events are not common.
    • For companies whose shares are listed on an exchange (such as the AQSE or AIM), the most likely way to get your money back is if the business is bought by another business or your shares are sold on that exchange. The latter can only occur if there is a willing buyer.
    • If you are investing in a start-up or EIS qualifying business, you should not expect to get your money back through dividends. Such businesses rarely pay these.
  4. Don’t put all your eggs in one basket
    • Putting all your money into a single business or type of investment for example, is risky. Spreading your money across different investments makes you less dependent on any one to do well.
    • A good rule of thumb is not to invest more than 10% of your money in high-risk investments. (See https://www.fca.org.uk/investsmart/5-questions-ask-you-invest).
  5. The value of your investment can be reduced
    • The percentage of the business that you own will decrease if the business issues more shares. This could mean that the value of your investment reduces, depending on how much the business grows. Most start-up businesses issue multiple rounds of shares.
    • These new shares could have additional rights that your shares don’t have, such as the right to receive a fixed dividend, which could further reduce your chances of getting a return on your investment.

If you are interested in learning more about how to protect yourself, visit the FCA’s website at www.fca.org.uk/investsmart