PRIVACY POLICY OF ARBOUR PARTNERS LLP

ARBOUR PARTNERS LLP is a limited liability partnership incorporated under the Limited Liability Partnerships Act 2000 (registration number OC 352308) whose registered office is at Bingham House, 93 High Street, Biggleswade, Bedfordshire, SG18 0LD

The purpose of this policy is to describe the basis on which we process your personal information, for what purposes, your privacy rights under applicable privacy laws including, where applicable, under General Data Protection Regulation ("GDPR") and other UK and European data privacy laws and applicable US privacy laws (the "Privacy Laws") and how we protect your personal information (defined as "personal data" under the Privacy Laws. We are committed to protecting and respecting your privacy and this policy sets out how we will process any personal data collected from you. Please read this privacy policy carefully.

For the purposes of data protection legislation, we are the data controller of your personal data.

Information collected by us

In the conduct of our business, we may obtain personal information about you in connection with any client’s existing or proposed appointment or engagement of Arbour or any investment opportunity offered by Arbour on behalf of its clients, including, without limitation, your name, date of birth, address and other contact details, social security number, tax or other identification number, identity documents and information about your income, assets and other financial information. This information may come from sources such as application, subscription or other forms or material completed or supplied by clients or investors, other written, electronic or verbal correspondence which relate to transactions by or on behalf of our clients as well as financial information relating to any person’s investment in a client’s investment fund or any other investment vehicles. We may also collect personal information provided by you in calls which are recorded by us, as required by applicable laws. We may also collect special categories of personal data (as defined in the GDPR and including health, disability and religious or ethnicity information) where provided by you, with your consent, such as disability information or religious data for purposes required by you such as scheduling of meetings or access to Arbour’s premises.

How we use information that we collect

We collect your personal information to fulfil our contractual obligations, our statutory obligations and/or the legitimate interests of Arbour and for other purposes for which Arbour has a lawful basis under the Privacy Laws, including:
(i) for compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing or "Know your Customer" requirements, as well as to verify the status and / or eligibility of investors for funds or services offered by Arbour and for compliance with tax reporting requirements;
(ii) for purposes of reporting to, or communicating with investors and clients concerning investments in client investment funds or appointment or engagement of Arbour consistent with our obligations to such persons;
(iii) in connection with our advisory services, including investment due diligence or investment monitoring activities or in response to "Know your Customer" requirements of counterparties;
(iv) in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving Arbour, our clients and investors; and (v) for other legitimate business interests.

In addition, we may, and only with your consent, process your personal information in order to communicate with you for marketing purposes. In this event, we may provide additional information that we believe may be of interest, including about funds or services, news updates, research or market commentary, conferences, or events offered by or in conjunction with Arbour. You have the right to unsubscribe when you have provided your consent to receive these communications by emailing unsubscribe@arbourpartners.com or by following the instructions in any such communication, e.g. by clicking on the link to unsubscribe.

The Disclosure of your Information

We may share your personal information with non-affiliated third parties for any of the purposes set forth above. By way of example, we share your personal information with:

  • Service providers (e.g., lawyers, auditors, accountants, tax advisers, administrators, custodians, depositaries, distribution managers and brokerage firms, event organizers or other agent, adviser or service provider relating to Arbour or its clients). Non-affiliated third party companies may from time to time be used to provide certain services to the investment industry, such as administration services, tax compliance services, reporting, account statements and other information, organizing events and conducting research. These companies may have access to your personal information but are permitted to use the information solely to provide the specific service or as otherwise permitted by law.
  • Fund managers or their general partners or investment advisers or administrators, or any of their respective agents or representatives. For example, we may share personal information with a prospective fund in order to respond to its anti-money laundering enquiries.

Where your personal information is processed by third parties outside the UK and EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law, including the execution of standard contractual clauses if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission) or certified under the EU-US Privacy Shield framework.

Security

We take seriously the obligation to safeguard your non-public personal information. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way.

We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this Policy

This privacy policy was published on 25 May 2018.

Any changes we make to this policy will be posted on this page.

Updating your details

If any of the information that you have provided to us changes, for example if you change your email address, please let us know by sending an email to data@arbourpartners.com

Your rights

You have certain rights relating to the personal information we hold in accordance with and subject to the Privacy Laws to: (i) check whether we hold personal information about you and to access such data (in accordance with our policy); (ii) request the correction of personal information about you that is inaccurate; (iii) have a copy of the personal information we hold about you provided to you or another controller where technically feasible; (iv) request the erasure of your personal information; and (v) request the restriction of processing concerning you. To do so, please send your request to data@arbourpartners.com

You are required to ensure the personal information we hold about you is up-to-date and accurate and you must notify us of any changes to the personal data you provided to us. If you provided consent for us to use your personal information, including for marketing purposes, you have the right to withdraw consent and we will process this withdrawal promptly.

Data Retention

We retain your personal information for a period of at least five years from the date on which the relevant business relationship, for which purpose such personal data was provided, has ended (or if later the date on which the last transaction was completed or the last entry to the record was made). Thereafter, Arbour will delete (or otherwise erase, de-identify or pseudonymise or equivalent) any such personal data except as required or permitted by applicable law or regulation.

Complaints

We hope that we can resolve any query or concern you raise about our use of your information. If you are not happy with how we manage your personal data, you have the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.

Questions?

Please email data@arbourpartners.com if you have any questions about this privacy policy. You may also make a complaint, in accordance with applicable Privacy Laws to the Information Commissioner’s Office.