Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the Data Protection Bill/Act 2017 the General Data Protection Regulation 2016/679 (the “GDPR” and other legislation relating to personal data and rights such as the Human Rights Act 1998.
Who are we?
This Privacy Notice is provided to you by Pearl Diver Capital which is the data controller for your data.
Pearl Diver is made up of the following organisations:
The organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data.
This Privacy Notice is sent to you by Pearl Diver Capital on its own behalf and on behalf of each of these data controllers. In the rest of this Privacy Notice, we use the word “we” to refer to each data controller, as appropriate.
What data do the data controllers listed above process?
They will process some or all of the following where necessary to perform their tasks:
How do we process your personal data?
The data controllers will comply with their legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as a fund administrator). We will always take into account your interests, rights and freedoms.
Some of our processing is necessary for compliance with a legal obligation. For example, for due diligence and KYC procedures.
We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
Sharing your personal data
Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks or where you first give us your prior consent. It is likely that we will need to share your data with some or all of the following (but only where necessary):
Personal data about other people which you provide to us
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
Keeping personal data about you secure
We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data. Personal data may be kept on our personal data technology systems, those of our contractors or in paper files.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
1. The right to access information we hold on you
2. The right to correct and update the information we hold on you
3. The right to have your information erased
4. The right to object to processing of your data
5. The right to data portability
6. The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.
7. The right to object to the processing of personal data where applicable.
8. The right to lodge a complaint with the Information Commissioner’s Office.
Transfer of Data Abroad
Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website is also accessible from overseas so on occasion some personal data may be accessed from overseas.
Changes to this notice
This Privacy Notice was last updated in May 2018. We reserve the right to update and change this Privacy Notice from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the changed Privacy Notice on our website or publish it otherwise. The changes will take effect as soon as they are posted on this website.
If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
The Data Controller,
You can contact the Information Commissioners Office on 0303 123 1113 or via email
https://ico.org.uk/global/contact‐us/email/ or at the Information Commissioner’s Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire SK9 5AF.