PRIVACY POLICY

Applicable to Curlew Alternative Asset Management Ltd,

its subsidiaries and funds under its  management collectively referred to as ‘Curlew’.

We want to ensure you understand what information we collect about you, how we will use it and for  what purpose. We are also required by data protection legislation to explain certain matters to you.  This notice sets this out 

 

Any and all responses to the survey will in any event be treated confidentially and any data gathered  will not be shared with any third parties other than those directly involved with the conduct of the  survey. 

You are not obliged to enter any personal information. Any personal data entered will only be retained  for as long as is reasonably necessary for the purpose for which it is required. 

In the context of this Policy, ‘Data’ is personal information about an individual who can be directly or  indirectly identified from that information. This may include factual information or opinions. This  personal information is referred to as ‘Data’ in the remainder of this policy.  

Personal information that is necessarily collected, stored and processed during our business activities  will be treated in an appropriate and lawful manner in accordance with prevailing legislation.  

We have a commitment to ensuring that personal data is processed in line with General Data  Protection Regulations (GDPR) and relevant UK law and that all our employees conduct themselves in  line with this and other related policies.  

Where third parties process data on our behalf, we will ensure that the third party takes the necessary  measures to maintain our commitment to protecting personal data. 

The purpose of GDPR and UK data protection laws is to ensure that it is done fairly and without  adversely affecting the rights of the Data Subject. Data Processing must comply with the principles of  good practice which ensure that personal data must be:  

• Processed fairly, lawfully, and in a transparent manner.  

• Processed for specified, explicit and legitimate purposes and in an appropriate way.  • Adequate, relevant and limited to what is necessary for the stated purpose.  • Kept accurate and up to date  

• Not kept longer than necessary for the stated purpose.  

• Processed in a manner that ensures appropriate security of Data, including protection against  unauthorised or unlawful processing, accidental loss, destruction or damage, by using  appropriate technical or organisational measures.  

• Not transferred to another country without appropriate safeguards being in place.  • Processed in line with Data Subjects’ rights.

Curlew is responsible for and must comply with the data protection principles listed above.

 

GDPR allows processing of Data only for specific purposes, which are where it is needed;  

• for the performance of a contract, such as an employment  

• to comply with a legal obligation  

• in order to pursue our legitimate interests (or those of a third party) and where the interests  and fundamental rights of the Data Subject do not override those interests  

• to protect the Data Subject’s vital interests  

• in the public interest, or  

• in situations where the Data Subject has given explicit consent.  

Data will not be kept longer than is necessary to carry out the specified purposes. This means that  Data should be destroyed or erased from our systems when it is no longer required.  

Curlew acknowledges that Data Subjects have the following rights which apply in certain  circumstances:  

• The right to be informed about processing of Data  

• The right of access to their own Data  

• The right for any inaccuracies to be corrected 

• The right to have information deleted  

• The right to restrict the processing of Data  

• The right to portability  

• The right to object to the inclusion of Data  

• The right to withdraw consent when the only legal basis for processing Data is consent 

• The right to be notified of a Data Breach which is likely to result in high risk to their rights and  freedoms  

• The right to make a complaint to the Information Commissioner’s Office or other supervisory  authority.  

Curlew will continue to review the effectiveness of this policy to ensure it is achieving its stated  objectives. 

Director of Operations, Curlew Capital 

01.03.21