Privacy & Cookie Policy

Privacy Notice

The Company and its service providers may control or process personal data regarding individuals for the purposes of data protection law, such as the European Union’s General Data Protection Regulation. All such personal data will be processed in compliance with data protection law.

The Company’s service providers who may control or process personal data in connection with the Company include its administrator, Northern Trust International Fund Administration Services (Guernsey) Limited and its registrar, Computershare Investor Services (Guernsey) Limited.

Types of personal data

This personal data may include:

  1. Information provided by individual persons who are, or may be connected with, shareholders of the Company. This might include a person’s name and address (including proof of name and address), contact details, date of birth, nationality, signature, occupational history, job title, tax residency and tax identification information. Such information might be provided in an application form or in other documents (as part of an application process or at other times), face-to-face, by telephone, by email or otherwise.
  2. Information that the Company or its service providers collect or generate. This might include information relating to a shareholder’s investment, emails (and related data), call recordings and website usage data.
  3. Information obtained from other sources. This might include information obtained for the purpose of know-your-client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-person checks, sanctions checks, among other things), information from public websites and other public sources and information received from the applicant’s advisers or from intermediaries.

Use, and reasons for use, of personal data

Personal data may be stored and processed for the following purposes:

  1. Assessing and processing applications for shares in the Company, conversions of shares and other share dealings.
  2. Compliance with legal and regulatory obligations and industry standards, including know-your-client procedures, the automatic exchange of tax information and legal judgments.
  3. Investor relations and communication purposes.

The Company and its services providers are entitled to process personal data in these ways for the following reasons:

  1. The entry into an investment contract with the Company and the performance of that contract.
  2. To discharge a relevant legal or regulatory obligation.
  3. For the legitimate business interests of the Company, its manager, administrator, registrar or another person, such as:
    1. carrying out the ordinary or reasonable business activities of the Company, its manager, administrator, registrar or other persons, or other activities previously disclosed to the Company’s shareholders or referred to in this privacy notice;
    2. ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud;
    3. establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and
    4. ensuring the security of information systems.

Personal data will only be used by the Company and its service providers for the purposes for which it has been collected. No decisions will be made based on automated processing of personal data.

Disclosure of personal data to third parties

The Company and its service providers may from time to time, in accordance with the purposes described above, disclose personal data to other parties, including (a) the Company’s other service providers and their respective affiliates, (b) professional advisers such as law firms and accountancy firms and (c) courts and regulatory, tax and governmental authorities. Some of these persons may process personal data in accordance with the Company’s or its service providers’ instructions and others will themselves be responsible for their use of personal data. These persons may be permitted to further disclose the personal data to other parties.

Transfers of personal data outside the European Economic Area

Personal data may be transferred to and stored by persons outside Guernsey or the European Economic Area (the “EEA”), and in particular may be transferred to and stored by affiliates or service providers of the Company or its administrator outside Guernsey or the EEA.

Where personal data is transferred outside Guernsey or the EEA, the transfer will be subject to appropriate safeguards or otherwise permitted under applicable law. For example, the country to which the personal data is transferred may be approved by the European Commission, the recipient may have agreed to model contractual clauses approved by the European Commission that oblige them to protect the personal data, or the recipient may be located in the United States and be a certified member of the EU-US Privacy Shield scheme.

More details of the protection given to personal data when it is transferred outside Guernsey or the EEA, including a copy of any standard data protection clauses entered into with recipients of personal data, can be obtained by contacting the Company using the details set out under “Contacting the Company” below.

Necessity of personal data for an investment in the Company

The provision of certain personal data is necessary for shares in the Company to be issued or transferred to a proposed shareholder and for compliance by the Company and its service providers with certain legal and regulatory obligations. Accordingly, if certain personal data is not provided when requested, an application for or transfer or conversion of shares might not be accepted.

Retention of personal data

How long personal data may be held for will vary. The retention period will be determined by various criteria, including the purposes for which it is being used (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which the personal data has to be kept).

Your rights in respect of personal data

If you are an individual, you have a number of legal rights in relation to the personal data that the Company and its service providers may hold about you. These rights include the following:

  1. The right to obtain information regarding the processing of an individual’s personal data and access to the personal data that the Company and its service providers holds about an individual.
  2. In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and the right to request that the Company transmits that data to a third party where this is technically feasible. This right only applies to personal data which an individual has provided to the Company and its service providers.
  3. The right to request that the Company or its service providers rectifies personal data if it is inaccurate or incomplete.
  4. The right to request that the Company or its service providers erases personal data in certain circumstances. There may be circumstances where you ask the Company and its service providers to erase your personal data but the Company is legally entitled to retain it.
  5. The right to object to, and the right to request that the Company and its service providers restrict processing of personal data in certain circumstances. There may be circumstances where you object to, or ask the Company or its service providers to restrict, processing of personal data but the Company is legally entitled to continue processing your personal data or to refuse that request.
  6. The right to lodge a complaint with the Guernsey Data Protection Authority or other applicable data protection regulator if you think that any of your rights have been infringed by the Company or its service providers.

You can exercise your rights by contacting the Company using the details set out under “Contacting the Company” below. You can find out more information about your rights by contacting an EU data regulator such as the UK’s Information Commissioner’s Office, or by searching its website at ico.org.uk.

Contacting the Company

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions and requests to [email protected].

*since market close on the last business day on which the London Stock Exchange was open for trading.