Investor Fair Processing Notice
We are required under data protection law to let individuals who are or may become investors know how their personal information is used. Please review this notice so that you understand how we will use your personal information.
This notice sets out how we will collect and use the personal information of:
- individuals under the fund documents to which you (the “Investor”) are a party in relation to the relevant fund (the “Partnership”) managed by Bridges Fund Management Limited;
- potential investors who have not yet entered into fund documents;
- other individuals we consider may be potential investors; and
- other individuals who choose to contact us through our website.
The controller in respect of personal information collected in relation to the categories of individuals specified above is Bridges Fund Management Limited, 38 Seymour Street, London W1H 7BP (the “Manager”)
The point of contact for any data protection queries in relation to this notice is: Maggie Loo, 38 Seymour Street, London W1H 7BP, +44 (0) 20 3780 8000 and firstname.lastname@example.org.
- Purposes for processing personal information
- Legal basis
- What personal information is processes
- Sharing personal information
- International data transfers
- How long will personal information be kept
- Rights to your personal information
- Changes to this notice
1. Purposes for processing personal information
Personal information may be processed for the following purposes:
(a) to allow the Investor to become a limited partner in the Partnership;
(b) to comply with legal obligations imposed by any statutory, judicial or regulatory requirements (for example, reporting to tax authorities and money laundering checks);
(c) for the performance of obligations under the fund documents;
(d) to conduct any credit scoring or analysis of the Investor;
(e) to verify the source of funds from the Investor;
(f) to enable the administration of any payment to or from the Investor;
(g) to provide the Investor with information about the performance and operation of the Partnership;
(h) to contact you to see if you are interested in becoming an investor; and
(i) to respond to any enquiries you make to us or through our website.
As noted above, certain personal information must be collected and processed by the Partnership and the Manager in order to comply with legal statutory and regulatory requirements and for the performance of obligations under the fund documents, or may be processed for the Manager’s legitimate interests (e.g. to provide information about other funds managed by the Manager) provided that the Investor’s interests and fundamental rights do not override those interests.
We may obtain your personal information from public sources (such as Companies House), professional advisers (in the context of fundraising) or investors’ databases.
2. Legal basis
The legal bases for the processing of your personal information for the purposes set out in section 3 below are that (i) it is necessary for the performance of the contracts to which you are a party or in order to take steps at your request prior to entering into a contract; (ii) for the purpose of complying with legal and regulatory requirements; and (iii) it is necessary for the controller’s legitimate interests provided that your interests and fundamental rights do not override those interests. For instance, we will process your personal data for our legitimate interests where you are a potential investor who has approached us or who we wish to approach.
Specific details of the legal bases are set out below.
3. What personal information is processed?
The following personal information may be collected and processed:
(a) information to be completed in the fund documents (such as contact details);
(b) information regarding identity, citizenship, residency, or tax status;
(c) copies of passport, proof of address and information regarding source of funds (as may be required to fulfil anti-money laundering obligations);
(d) information about your status as a potential Investor; and
(e) Information about you when you contact us to make an enquiry;
The processing of the personal information under (i) to (iii) above is required to fulfil the requirements of the fund documents. It is in the Partnership’s and the Manager’s interests to process this personal information to ensure the correct and proper operation of the Partnership, and it is in the Investor’s interests for this personal information to be used in order for the Investor to exercise its rights as a limited partner in the Partnership.
4. Sharing personal information
Personal information may be shared with and disclosed to:
(a) other limited partners in the Partnership;
(b) professional advisers of the Partnership, the Manager and other limited partners;
(c) other third parties, such as service providers, that help with the operation, management and administration of the Partnership; or the third party that we use to carry out Know Your Client checks, i.e. Smartsearch (smartsearchuk.com). As part of using Smartsearch, your personal information may be disclosed to a credit reference agency which may keep a record of your personal information and may disclose the personal information, and the fact that a search was made, to other customers for purposes of assessing credit risk and occasionally to prevent fraud, for money laundering and debtor tracing;
(d) regulators, law enforcement and government bodies (such as HMRC) where we are required by law to disclose your personal information.
International data transfers
Personal information may be transferred outside of the UK and the European Economic Area (EEA) in the following circumstances:
(a) where a limited partner is based outside of the EEA;
(b) where a service provider is based outside of the EEA;
(c) where a professional adviser is based outside of the EEA;
(d) where any of the transactions entered into by the Partnership involve parties based outside of the EEA; or
(e) information may be required to be shared with regulatory authorities based outside of the EEA.
The Partnership and the Manager will ensure that transfers will only take place where such transfers are lawful, are based on appropriate safeguards (such as the European Commission approved standard contractual clauses or Privacy Shield (for US transfers)) wherever possible and are strictly necessary in order to fulfil the requirements of the fund documents.
We may also transfer your personal data to our US subsidiary where necessary and we will do so in reliance on standard contractual clauses to ensure adequate protection. We may also transfer personal data to our affiliate funds in countries that have adequacy status according to the European Commission and so are considered safe countries for data transfers.
If you have any questions about the transfer of your personal information please contact us using the details in the “About Us” section above.
5. How long will personal information be kept?
Where an individual is an Investor, personal information will be kept for as long as the Investor is a limited partner in the Partnership, plus a period of time as determined by the Manager in accordance with any applicable laws and regulations after the Investor ceases to be a limited partner in the Partnership (as necessary for compliance with legal and regulatory requirements).
If you are not an Investor, we will retain your personal information in accordance with any statutory obligations we are required to comply with but will otherwise securely delete your personal information 6 years after the date it was collected unless before that time (i) your personal information is no longer required in connection with our purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see section 7 below).
6. Rights to your personal information
Any individual whose personal information is held or processed by the Partnership or the Manager has the right to:
- ask for information about how their personal information is used
- ask for a copy of their personal information held;
- ask for any inaccuracies to be corrected or for their personal information to be erased;
- object to any of the ways in which their information is used, and ask for their information to stop being used; and
- ask for their personal information to be sent to them under the data portability right.
These rights do not apply in all circumstances and we may be able to rely on exemptions. We may also need further information from you in order to respond to your request to exercise your rights. If you would like to exercise these rights please contact the point of contact noted in the “About Us” section of this notice.
Individuals also have the right to complain to the UK Information Commissioner’s Office (www.ico.org.uk) about how their personal information has been handled.
7. Changes to this notice
We may update this notice from time to time. We will notify you of significant changes by contacting you directly. This notice was last updated on 9th May 2018.