This Notice explains how we collect, use, share and protect your personal data. We are committed to protecting and respecting your privacy, and you have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Notice.
As used in this Notice:
“controller” shall mean an entity or person who determines the purposes and means of the processing of personal data;
“criminal convictions data” shall mean personal data relating to criminal convictions and offences or related security measures;
“DPL” shall mean the Data Protection (Bailiwick of Guernsey) Law, 2017;
“EEA” means the European Economic Area;
“EU GDPR” means the EU General Data Protection Regulation 2016/679;
“GDPR” shall mean, as applicable, the EU GDPR and/or the UK GDPR;
“personal data” shall mean information from which it is possible to identify a natural person (an individual) or information from which any individual is identifiable;
“processing” means anything that is done with personal data such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (and its cognates shall be interpreted accordingly);
“processor” shall mean a person or entity which processes personal data on behalf of the controller;
“sensitive personal data” shall mean special category data and criminal convictions data or any other information deemed to be sensitive under applicable law;
“special category data” shall mean personal data about an individual’s race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health, sexual life or sexual orientation;
“UK” means the United Kingdom; and
“UK GDPR” means the EU GDPR as it forms part of the law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018, and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (SI 2019/419).
1. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?
We are Hedosophia Services Limited (registered in the UK with Company No. 08975224) which has its registered office at 2 Soho Place, London W1D 3BG, and Hedosophia Services (Guernsey) Limited (registered in Guernsey with Company No. 68673) which has its registered office at Suite 4 (Second Floor), Weighbridge House, Lower Pollet, St Peter Port, Guernsey GY1 1WL. For the purposes of data privacy legislation, we will be acting as ‘joint controllers’.
Investors in Hedosophia funds should refer to the Privacy Notices provided in the relevant investor portal.
This Notice describes the processing of personal data collated by us and our agents about natural persons and explains the rights of such persons in relation to such personal data.
In this Notice, where our processing activities are described in respect of your personal data this also means the processing activities carried out in respect of such personal data by us or on our behalf by our agents, sub-contractors and authorised processors without limitation.
2. WHAT INFORMATION DO WE COLLECT?
We collect your personal information from a variety of sources, as set out in this Notice. Where necessary we collect information directly from you or indirectly from other sources, including third parties, and through your use of our website.
2.1. Information you provide to us
We may collect the following personal data about natural persons in connection with investments made in and by Hedosophia funds. If this information changes, please let us know at the earliest opportunity so that our records can be updated:
identity information such as title, full name, gender, citizenship, nationality, race, date of birth, photograph, passport or other unique ID number;
contact details such as home and work address, phone number(s) and email address(es);
personal and family details such as place of birth and marital status;
financial data, including banking details, tax/social security number, sources of wealth, information about net worth and current investments and assets;
records of electronic communications;
other information required under applicable law, rule or regulation or as otherwise required in connection with investments in or by Hedosophia funds, including data collected in relation to compliance with applicable anti-money laundering/know your customer regulations, the U.S. Foreign Account Tax Compliance Act, the UK’s Automatic Exchange of Information agreements commonly referred to as the Common Reporting Standard, or otherwise; and
employment and education history (where you send us this information as part of a job application process).
We may also, in certain circumstances, collect sensitive personal data in the context of checks we might be obligated to conduct under laws relating to proceeds of crime, anti-money-laundering and the financing of terrorism.
2.2. Information we collect from other sources
We collect the following information from third parties:
basic personal details including your name, address, email address, telephone number and other contact details;
data received from background checks related to the job application process. This may include criminal record checks and credit history or bankruptcy checks as required for regulatory purposes;
data received from due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks);
fraud enquiries (for example, information from police reports); and
employment and education history (where we are sent this information by a recruitment agent).
2.3. Information from your use of our website
With regard to each of your visits to our site we may automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
information about your visit, including: the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers); and methods used to browse away from the page.
3. HOW IS THE DATA COLLECTED?
We primarily collect your personal data from information which you or your authorised representative provide, including but not limited to:
information set out in any contractual agreements in respect of investments made in and by Hedosophia funds;
such other forms and documents as we may request that are completed in relation to the administration/management of investments made in and by Hedosophia funds;
client and customer due diligence documentation as part of our regulatory requirements; and
any personal data provided by you by way of correspondence with us by phone, video conference, e-mail or otherwise which may include recordings and transcriptions;
together with personal data received from you or any third-party sources which may include:
entities in which you or someone connected to you has an interest;
your legal and/or financial advisors;
other financial institutions who hold and process your personal data to satisfy their own regulatory requirements; and
credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements.
We may also collect and process your personal data in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act. We may also combine information that we have about you from various sources, including the information that you have provided to us.
We will also collect information from you via each visit to this website.
4. HOW IS THE DATA USED?
We may use the data, including any personal data, for the following purposes (those based wholly or partly on our legitimate interests are set out below):
communicating with you as necessary in connection with business affairs and in connection with activities relating to investments in and by Hedosophia funds;
conducting credit reference checks;
coordinating our IT systems, software and business applications;
supporting our IT and business applications support teams, accounting, legal, reporting, internal audit and risk management, document storage, record keeping and other related functions, including but not limited to processing personal data;
monitoring and recording telephone and electronic communications and transactions: (i) for quality, business analysis, training and related purposes in order to improve service delivery; (ii) for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act); and (iii) to enforce or defend our rights, or through third parties to whom we each may delegate such responsibilities or rights in order to comply with a legal or regulatory obligations imposed on us;
disclosing your personal data to any bank, financial institution or other third-party lender providing any form of facility, loan, finance or other form of credit or guarantee relating to investments in and by Hedosophia funds;
detecting and preventing crime such as fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions on an ongoing basis (“Regulatory Assessments“);
facilitating our internal administration and retaining your personal data as part of our Regulatory Assessments or future services entered into by you;
liaising with or reporting to any regulatory authority (including tax authorities) with whom we are either required to cooperate or report to, or with whom they decide or deem appropriate to cooperate, in relation to an investment, and which has jurisdiction over Hedosophia funds or its investments in a third country without the same or similar data protection laws as Guernsey, the UK or the EEA;
communicating with our professional advisers for the purposes of obtaining professional advice; and
conducting business analytics and diagnostics.
To the extent that such personal data contains sensitive personal data, then the processing of such data shall solely be for the purpose of complying with any duty imposed on us by an enactment including, but not limited to, legislation and regulatory obligations relating to anti-money laundering and combating the financing of terrorism and all other related legislation.
We do not make decisions about you based on automated processing of your personal data.
5. ON WHAT BASIS IS THE DATA USED?
We process your personal data on the following lawful grounds:
the processing is necessary for our legitimate interests or those of a third party (provided your interests and fundamental rights do not override those interests);
the processing is necessary to comply with our respective contractual duties with you in connection with activities related to investments in and by Hedosophia funds;
to comply with our legal and regulatory obligations;
(on exceptional occasions) where we have obtained your consent; and
(on rare occasions) where it is needed in the public interest.
Where we receive information about you from third-party recruitment agencies, we will use that information to assist our recruitment processes and inform our recruitment decisions. Our legal basis for the processing of that information is our legitimate business interests in the process of recruiting talented individuals to work for us, in respect of which third-party recruitment agencies play an important part and which requires the processing of data we are provided about candidates put forward by such agencies. In certain circumstances, particularly later in the recruitment process, we may rely instead on consent as our legal basis. Where applicable, you should refer to the privacy policy of the relevant recruitment agency in order to understand how they process your data directly and their legal basis for doing so.
Some of the grounds for processing described above will overlap and there may be several grounds which justify the use of your personal data.
6. IS IT NECESSARY TO PROVIDE PERSONAL DATA?
Unless otherwise indicated, you should assume that we require the personal data for statutory, regulatory or contractual requirements, or for our legitimate business interests or those of a third party (except where those interests are overridden by your interests, fundamental rights or freedoms).
To the extent you refuse to communicate personal data to us, we may not be able to comply with our legal, regulatory or compliance-related obligations or perform our contracts with you. The refusal to provide certain personal data to us may affect our ability to do business with you.
7. DISCLOSURE OF PERSONAL DATA AND TRANSFERS OVERSEAS
Personal data will, in certain circumstances, be disclosed to group companies and third parties, including:
fund administrators appointed in respect of Hedosophia funds;
custodians of the assets of Hedosophia funds;
banks, financial institutions or other third-party lenders;
service providers (including IT service providers and/or the other service providers’ affiliates and sub-contractors); and
advisors to us and our affiliates on tax, legal and other related matters, with external processing centres, the transfer or payment agents and other third parties as necessary and appropriate for the purposes we have described.
Where we are under an obligation to do so by law, we may disclose personal data to regulators, courts, the police or tax authorities, or in the course of litigation. In some cases, in accordance with applicable law, it may not be possible to provide notification in advance about the details of such disclosures. We will use reasonable efforts to disclose the minimum personal data necessary in such cases.
Where we transfer personal data outside of the Bailiwick of Guernsey, the UK or the EEA, such transfer shall be made pursuant to European Commission approved standard contractual clauses and/or such other transfer mechanisms or safeguards required under the GDPR, DPL or other data privacy law (in each case, as applicable) for such transfer.
8. RETENTION OF PERSONAL DATA
Your personal data will be retained for the longest of the following periods:
for us and/or any authorised third parties to carry out the purposes for which the data was collected (or as long as is set out in any relevant agreement you enter into with us);
in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or
any retention period that is required by data protection laws and any applicable laws or regulatory requirements.
We endeavour to store your personal data securely. We shall (or procure that persons processing data on our behalf shall) implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, damage or destruction.
Whilst we have taken every reasonable care to ensure the implementation of appropriate technical and security measures, we cannot guarantee the security of your personal data over the internet, via email or via their websites, we do not accept, to the fullest extent permitted by law, any liability for any errors in data transmission, machine, software or operating error or any other cause.
9. RIGHTS IN RELATION TO PERSONAL DATA HELD BY US
Natural persons have certain rights in relation to the personal data we hold about them. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we require natural persons to verify their identity before responding to any requests to exercise applicable rights.
Natural persons have the following rights in relation to their personal data:
Access: the right to access the personal data and certain information about how we use it and with whom we share it;
Portability: in certain circumstances, natural persons have the right to receive or ask us to provide their personal data to a third party in a structured, commonly used and machine-readable format, although we will not provide certain personal data if it would interfere with another’s individual’s rights or where another exemption applies; we are not responsible for the security of the personal data or its processing once received by the third party;
Correction: natural persons may request that we correct any personal data held about them that is inaccurate and have incomplete data completed (including by the provision of a supplementary statement). Please note that while we assess whether the personal data we hold about natural persons is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below;
Restriction: natural persons may request the right for us to restrict the use of their personal data in certain circumstances;
Erasure: in certain circumstances, natural persons may request that we erase the personal data that we hold about them where they believe that it is no longer necessary for us to hold the personal we hold or where the natural person believes the personal data we hold about them is being unlawfully processed; and
Objection: in certain circumstances, in particular where personal data has been provided voluntarily, or consent to use personal data has been otherwise granted, natural persons have the right to restrict or object to the processing of personal data or withdraw consent.
You also have the right to lodge a complaint to a supervisory authority in the UK or EEA member state of your usual residence or place of work or of the place of the alleged breach, and/or, in respect of personal data processed as part of our activities related to investments in and by the Hedosophia funds. A list of the EEA data protection authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en. In the UK, the relevant supervisory authority is the Information Commissioner’s Office: https://ico.org.uk/.
For more detail on when these rights apply, or in order to exercise the rights set out at above, or to enquire or make a complaint, please contact us per the following details.
10. SECURITY
We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
In addition, those employees, agents, contractors and other third parties who process your personal data will only do so on our instructions and they will be subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example by encrypting our outgoing email communications, we cannot guarantee the security of your data transmitted online. Any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.
This Notice may be amended from time to time at our discretion.
PRIVACY NOTICE (THIS “NOTICE”)
This Notice explains how we collect, use, share and protect your personal data. We are committed to protecting and respecting your privacy, and you have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Notice.
As used in this Notice:
“controller” shall mean an entity or person who determines the purposes and means of the processing of personal data;
“criminal convictions data” shall mean personal data relating to criminal convictions and offences or related security measures;
“DPL” shall mean the Data Protection (Bailiwick of Guernsey) Law, 2017;
“EEA” means the European Economic Area;
“EU GDPR” means the EU General Data Protection Regulation 2016/679;
“GDPR” shall mean, as applicable, the EU GDPR and/or the UK GDPR;
“personal data” shall mean information from which it is possible to identify a natural person (an individual) or information from which any individual is identifiable;
“processing” means anything that is done with personal data such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (and its cognates shall be interpreted accordingly);
“processor” shall mean a person or entity which processes personal data on behalf of the controller;
“sensitive personal data” shall mean special category data and criminal convictions data or any other information deemed to be sensitive under applicable law;
“special category data” shall mean personal data about an individual’s race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health, sexual life or sexual orientation;
“UK” means the United Kingdom; and
“UK GDPR” means the EU GDPR as it forms part of the law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018, and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (SI 2019/419).
1. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?
We are Hedosophia Services Limited (registered in the UK with Company No. 08975224) which has its registered office at 2 Soho Place, London W1D 3BG, and Hedosophia Services (Guernsey) Limited (registered in Guernsey with Company No. 68673) which has its registered office at Suite 4 (Second Floor), Weighbridge House, Lower Pollet, St Peter Port, Guernsey GY1 1WL. For the purposes of data privacy legislation, we will be acting as ‘joint controllers’.
Investors in Hedosophia funds should refer to the Privacy Notices provided in the relevant investor portal.
This Notice describes the processing of personal data collated by us and our agents about natural persons and explains the rights of such persons in relation to such personal data.
In this Notice, where our processing activities are described in respect of your personal data this also means the processing activities carried out in respect of such personal data by us or on our behalf by our agents, sub-contractors and authorised processors without limitation.
2. WHAT INFORMATION DO WE COLLECT?
We collect your personal information from a variety of sources, as set out in this Notice. Where necessary we collect information directly from you or indirectly from other sources, including third parties, and through your use of our website.
2.1. Information you provide to us
We may collect the following personal data about natural persons in connection with investments made in and by Hedosophia funds. If this information changes, please let us know at the earliest opportunity so that our records can be updated:
identity information such as title, full name, gender, citizenship, nationality, race, date of birth, photograph, passport or other unique ID number;
contact details such as home and work address, phone number(s) and email address(es);
personal and family details such as place of birth and marital status;
financial data, including banking details, tax/social security number, sources of wealth, information about net worth and current investments and assets;
records of electronic communications;
other information required under applicable law, rule or regulation or as otherwise required in connection with investments in or by Hedosophia funds, including data collected in relation to compliance with applicable anti-money laundering/know your customer regulations, the U.S. Foreign Account Tax Compliance Act, the UK’s Automatic Exchange of Information agreements commonly referred to as the Common Reporting Standard, or otherwise; and
employment and education history (where you send us this information as part of a job application process).
We may also, in certain circumstances, collect sensitive personal data in the context of checks we might be obligated to conduct under laws relating to proceeds of crime, anti-money-laundering and the financing of terrorism.
2.2. Information we collect from other sources
We collect the following information from third parties:
basic personal details including your name, address, email address, telephone number and other contact details;
data received from background checks related to the job application process. This may include criminal record checks and credit history or bankruptcy checks as required for regulatory purposes;
data received from due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks);
fraud enquiries (for example, information from police reports); and
employment and education history (where we are sent this information by a recruitment agent).
2.3. Information from your use of our website
With regard to each of your visits to our site we may automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
information about your visit, including: the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers); and methods used to browse away from the page.
3. HOW IS THE DATA COLLECTED?
We primarily collect your personal data from information which you or your authorised representative provide, including but not limited to:
information set out in any contractual agreements in respect of investments made in and by Hedosophia funds;
such other forms and documents as we may request that are completed in relation to the administration/management of investments made in and by Hedosophia funds;
client and customer due diligence documentation as part of our regulatory requirements; and
any personal data provided by you by way of correspondence with us by phone, video conference, e-mail or otherwise which may include recordings and transcriptions;
together with personal data received from you or any third-party sources which may include:
entities in which you or someone connected to you has an interest;
your legal and/or financial advisors;
other financial institutions who hold and process your personal data to satisfy their own regulatory requirements; and
credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements.
We may also collect and process your personal data in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act. We may also combine information that we have about you from various sources, including the information that you have provided to us.
We will also collect information from you via each visit to this website.
4. HOW IS THE DATA USED?
We may use the data, including any personal data, for the following purposes (those based wholly or partly on our legitimate interests are set out below):
communicating with you as necessary in connection with business affairs and in connection with activities relating to investments in and by Hedosophia funds;
conducting credit reference checks;
coordinating our IT systems, software and business applications;
supporting our IT and business applications support teams, accounting, legal, reporting, internal audit and risk management, document storage, record keeping and other related functions, including but not limited to processing personal data;
monitoring and recording telephone and electronic communications and transactions: (i) for quality, business analysis, training and related purposes in order to improve service delivery; (ii) for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act); and (iii) to enforce or defend our rights, or through third parties to whom we each may delegate such responsibilities or rights in order to comply with a legal or regulatory obligations imposed on us;
disclosing your personal data to any bank, financial institution or other third-party lender providing any form of facility, loan, finance or other form of credit or guarantee relating to investments in and by Hedosophia funds;
detecting and preventing crime such as fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions on an ongoing basis (“Regulatory Assessments“);
facilitating our internal administration and retaining your personal data as part of our Regulatory Assessments or future services entered into by you;
liaising with or reporting to any regulatory authority (including tax authorities) with whom we are either required to cooperate or report to, or with whom they decide or deem appropriate to cooperate, in relation to an investment, and which has jurisdiction over Hedosophia funds or its investments in a third country without the same or similar data protection laws as Guernsey, the UK or the EEA;
communicating with our professional advisers for the purposes of obtaining professional advice; and
conducting business analytics and diagnostics.
To the extent that such personal data contains sensitive personal data, then the processing of such data shall solely be for the purpose of complying with any duty imposed on us by an enactment including, but not limited to, legislation and regulatory obligations relating to anti-money laundering and combating the financing of terrorism and all other related legislation.
We do not make decisions about you based on automated processing of your personal data.
5. ON WHAT BASIS IS THE DATA USED?
We process your personal data on the following lawful grounds:
the processing is necessary for our legitimate interests or those of a third party (provided your interests and fundamental rights do not override those interests);
the processing is necessary to comply with our respective contractual duties with you in connection with activities related to investments in and by Hedosophia funds;
to comply with our legal and regulatory obligations;
(on exceptional occasions) where we have obtained your consent; and
(on rare occasions) where it is needed in the public interest.
Where we receive information about you from third-party recruitment agencies, we will use that information to assist our recruitment processes and inform our recruitment decisions. Our legal basis for the processing of that information is our legitimate business interests in the process of recruiting talented individuals to work for us, in respect of which third-party recruitment agencies play an important part and which requires the processing of data we are provided about candidates put forward by such agencies. In certain circumstances, particularly later in the recruitment process, we may rely instead on consent as our legal basis. Where applicable, you should refer to the privacy policy of the relevant recruitment agency in order to understand how they process your data directly and their legal basis for doing so.
Some of the grounds for processing described above will overlap and there may be several grounds which justify the use of your personal data.
6. IS IT NECESSARY TO PROVIDE PERSONAL DATA?
Unless otherwise indicated, you should assume that we require the personal data for statutory, regulatory or contractual requirements, or for our legitimate business interests or those of a third party (except where those interests are overridden by your interests, fundamental rights or freedoms).
To the extent you refuse to communicate personal data to us, we may not be able to comply with our legal, regulatory or compliance-related obligations or perform our contracts with you. The refusal to provide certain personal data to us may affect our ability to do business with you.
7. DISCLOSURE OF PERSONAL DATA AND TRANSFERS OVERSEAS
Personal data will, in certain circumstances, be disclosed to group companies and third parties, including:
fund administrators appointed in respect of Hedosophia funds;
custodians of the assets of Hedosophia funds;
banks, financial institutions or other third-party lenders;
service providers (including IT service providers and/or the other service providers’ affiliates and sub-contractors); and
advisors to us and our affiliates on tax, legal and other related matters, with external processing centres, the transfer or payment agents and other third parties as necessary and appropriate for the purposes we have described.
Where we are under an obligation to do so by law, we may disclose personal data to regulators, courts, the police or tax authorities, or in the course of litigation. In some cases, in accordance with applicable law, it may not be possible to provide notification in advance about the details of such disclosures. We will use reasonable efforts to disclose the minimum personal data necessary in such cases.
Where we transfer personal data outside of the Bailiwick of Guernsey, the UK or the EEA, such transfer shall be made pursuant to European Commission approved standard contractual clauses and/or such other transfer mechanisms or safeguards required under the GDPR, DPL or other data privacy law (in each case, as applicable) for such transfer.
8. RETENTION OF PERSONAL DATA
Your personal data will be retained for the longest of the following periods:
for us and/or any authorised third parties to carry out the purposes for which the data was collected (or as long as is set out in any relevant agreement you enter into with us);
in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or
any retention period that is required by data protection laws and any applicable laws or regulatory requirements.
We endeavour to store your personal data securely. We shall (or procure that persons processing data on our behalf shall) implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, damage or destruction.
Whilst we have taken every reasonable care to ensure the implementation of appropriate technical and security measures, we cannot guarantee the security of your personal data over the internet, via email or via their websites, we do not accept, to the fullest extent permitted by law, any liability for any errors in data transmission, machine, software or operating error or any other cause.
9. RIGHTS IN RELATION TO PERSONAL DATA HELD BY US
Natural persons have certain rights in relation to the personal data we hold about them. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we require natural persons to verify their identity before responding to any requests to exercise applicable rights.
Natural persons have the following rights in relation to their personal data:
Access: the right to access the personal data and certain information about how we use it and with whom we share it;
Portability: in certain circumstances, natural persons have the right to receive or ask us to provide their personal data to a third party in a structured, commonly used and machine-readable format, although we will not provide certain personal data if it would interfere with another’s individual’s rights or where another exemption applies; we are not responsible for the security of the personal data or its processing once received by the third party;
Correction: natural persons may request that we correct any personal data held about them that is inaccurate and have incomplete data completed (including by the provision of a supplementary statement). Please note that while we assess whether the personal data we hold about natural persons is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below;
Restriction: natural persons may request the right for us to restrict the use of their personal data in certain circumstances;
Erasure: in certain circumstances, natural persons may request that we erase the personal data that we hold about them where they believe that it is no longer necessary for us to hold the personal we hold or where the natural person believes the personal data we hold about them is being unlawfully processed; and
Objection: in certain circumstances, in particular where personal data has been provided voluntarily, or consent to use personal data has been otherwise granted, natural persons have the right to restrict or object to the processing of personal data or withdraw consent.
You also have the right to lodge a complaint to a supervisory authority in the UK or EEA member state of your usual residence or place of work or of the place of the alleged breach, and/or, in respect of personal data processed as part of our activities related to investments in and by the Hedosophia funds. A list of the EEA data protection authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en. In the UK, the relevant supervisory authority is the Information Commissioner’s Office: https://ico.org.uk/.
For more detail on when these rights apply, or in order to exercise the rights set out at above, or to enquire or make a complaint, please contact us per the following details.
10. SECURITY
We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
In addition, those employees, agents, contractors and other third parties who process your personal data will only do so on our instructions and they will be subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example by encrypting our outgoing email communications, we cannot guarantee the security of your data transmitted online. Any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.
This Notice may be amended from time to time at our discretion.
Registration
Hedosophia Services Limited (“HSL”) is registered in the UK (No. 08975224) and has its registered office at 2 Soho Place, London W1D 3BG.
HSL is authorised and regulated by the Financial Conduct Authority (FRN 831234).
Hedosophia Services (Guernsey) Limited (“HS(G)L”) is registered in Guernsey (No. 68673) and has its registered office at Suite 4 (Second Floor), Weighbridge House, Lower Pollet, St Peter Port, Guernsey GY1 1WL.
HS(G)L is regulated by the Guernsey Financial Services Commission (GFSC Ref 2749420).
Terms of Website Use
Please read these terms and conditions carefully before using this site
This page (together with the documents referred to on it) tells you the terms of use on which you may make use of our website www.hedosophia.com (our site) as a guest.
Please read these terms of use carefully before you start to use the site. By using our site, you indicate that you accept these terms of use and that you agree to abide by them.
If you do not agree to these terms of use, please refrain from using our site.
Information about us
www.hedosophia.com is a site operated by Hedosophia Services Limited (“we”, “us”, “our”).
We are a company registered in England and Wales under company registration number 098975224 and have our registered office at 2 Soho Place, London, England, W1D 3BG.
We are authorised and regulated by the Financial Conduct Authority.
Where appropriate, references to “we”, “us” and “our” in these terms of use shall include Hedosophia Services Limited, other members of our group of companies and third parties connected to us, including without limitation directors, officers, employees, partners, shareholders and agents of the foregoing.
Information about you and your visits to our site
We process information about you in accordance with our Privacy Policy as found on our website. By using our site, you consent to such processing.
Linking to our site
You are not permitted to establish a link to our site in any way.
Prohibited uses
You may use our site only for lawful purposes. You also agree:
not to reproduce, duplicate, copy or re-sell any part of our site in contravention of these terms.
not to attack our site via a denial-of-service attack or a distributed denial-of service attack.
not to access without authority, interfere with, damage or disrupt:
any part of our site.
any equipment, server or network on which our site is stored or any server, computer or database connected to our site.
any software used in the provision of our site.
any equipment or network or software owned or used by any third party.
By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990.
We may report any such breach to the relevant law enforcement authorities and will co-operate with those authorities by disclosing your identity to them.
In the event of such a breach, your right to use our site will cease immediately.
Intellectual property rights
We are the owner or the licensee of all intellectual property rights in our site, and in any material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.
You may print one copy, and may download extracts, of any page(s) from our site for your personal reference and you may draw the attention of others within your organisation to material posted on our site.
You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way.
Our status (and that of any identified contributors) as the authors of material on our site must always be acknowledged.
If you print, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.
Trade marks
Any trade marks shown on the site are the trade marks of ours unless expressly stated otherwise. No permission is given by us in respect of the use of any such trade marks, service marks, company names or logos or copyrights and such use may constitute an infringement of the holder’s rights.
Reliance on information posted
Any content on our site is provided on an “as is” basis, for general information only. It has not been audited or verified by any third party and is subject to change at any time, without notice. It is not intended to amount to advice on which you should rely.
Specifically, our site and any information contained herein is not, and must not be treated as, investment advice, investment recommendations, or investment research and no person must take (or refrain from taking) any investment decision on the basis of the information set out on our site.
Before making any investment decision, you should seek independent investment, legal, tax, accounting or other professional advice as appropriate.
Although we make reasonable efforts to update any information provided on our site, we make no representations, warranties or guarantees, whether express or implied, as to the condition, quality, accuracy, suitability, fitness for purpose, completeness, or freedom from viruses or bugs (you should use your own virus protection software) of the information contained on our site or that such content will be accurate, complete, up to date, uninterrupted or error-free.
We therefore disclaim all liability and responsibility arising from any use of or reliance placed on all content on our site by any visitor to our site, or by anyone who may be informed of any of its contents.
No offer
Any content on our site is not intended to and does not constitute an offer, invitation, solicitation or recommendation to invest in any fund, security or other product or service. Any information contained on our site should not be relied upon for any purpose.
Any offer or invitation, if made, would be made only by way of a confidential private placement memorandum (or other formal or informal offering document) and only in jurisdictions in which such an offer or invitation would be lawful.
The information on our site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution would be contrary to local law or regulation.
Our site changes regularly
We aim to update our site regularly and may change the content at any time. If the need arises, we may suspend access to our site or close it indefinitely.
Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.
We do not guarantee that our site, or any content on it, will be free from errors or omissions.
Our liability
Whether you are a consumer or business user, to the extent permitted by law, we, other members of our group of companies and third parties connected to us hereby expressly exclude:
all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity.
any liability for any direct, indirect or consequential loss, and any other loss, fines or damage whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, and any materials posted on it.
We will not be liable for any loss, fines or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any content on it, or on any website linked to it.
If you are a consumer user, please note that we only provide our site for domestic and private use. You agree not to use our site for any commercial or business purposes.
This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.
Suspension and termination
We will determine, in our sole discretion, whether there has been a breach of these terms through your use of our site. When a breach of these terms has occurred, we may take such action as we deem appropriate in our sole discretion.
We exclude liability for actions taken in response to breaches of these terms.
Indemnity
You hereby indemnify and hold us, other members of our group of companies and third parties connected to us and our, their directors, officers, employees, partners and agents harmless from and against all liabilities, damages, losses, fines, costs and other expenses (including, without limitation, legal fees and any amounts paid by us to a third party in settlement of a claim or dispute) incurred or suffered by us arising out of any breach by you of any provision of these terms or other liabilities arising out of your use of our site.
Severability
If any part of these terms of use is found by any court, tribunal, administrative body or authority of competent jurisdiction to be illegal, invalid or unenforceable, then that part shall, to the extent required, be severed from these terms of use and shall be ineffective without modifying any other part of these terms of use. This shall not affect any other provision of these terms of use, which shall remain in full force and effect.
Amendments
We may revise these terms of use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we may make, as they are legally binding on you.
Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our site.
Jurisdiction and applicable law
If you are an individual, please note that these terms of use, its subject matter and its formation, are governed by English law.
You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a resident of Scotland, you may also bring proceedings in Scotland.
If you are a business, these terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales.
We both agree that the English courts will have exclusive jurisdiction over any claim arising from, or related to, a visit to our site, although we retain the right to bring proceedings against you for breach of these terms in your country of residence or any other country.
Your concerns
If you have any concerns about material that appears on our site, please contact info@hedosophia.com.
