2.1. We process your personal data for the following purposes
2.1.1. to verify the identity of prospective investors, to ensure we comply with statutory and regulatory requirements in relation to anti-money laundering, anti-terrorist financing procedures, credit reference checks, and to verify that prospective investors meet our requirements for investment;
2.1.2. to contact prospective investors with information about other products and services provided by the Investment Manager, or its affiliates, which may be of interest to the prospective investor, with the consent of that investor where required by law;
2.1.3. to process investments and provide you with services under any contract we have with you or that you request, including contacting you about your investments where necessary;
2.1.4. to monitor and record telephone and electronic communications and transactions:
(a) for quality, business analysis, training and related purposes in order to improve service delivery;
(b) for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act); and
(c) to enforce or defend the Company’s rights, or through third parties to whom we may delegate such responsibilities or rights in order to comply with a legal or regulatory obligations imposed on us;
2.1.5. to detect and prevent 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 sanction on an ongoing basis (“Regulatory Assessments“). In discharging our anti-money laundering obligations we may, in certain circumstances, collect, store and process special categories of data such as information regarding criminal convictions;
2.1.6. to facilitate the internal administration of the Company and any third parties with which we share personal data and retaining your personal data as part of our Regulatory Assessments or providing services to you;
2.1.7. to liaise with or report to any regulatory authority (including tax authorities) with whom the Company is either required to cooperate or report to, or with whom it decides or deems appropriate to cooperate, in relation to an investment, and which has jurisdiction over the Company or its investments in a third country without the same or similar data protection laws as the UK or any EU member state;
2.1.8. to disclose 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 to the Company;
2.1.9. to communicate with our professional advisers for the purposes of obtaining professional advice; and
2.1.10. to conduct business analytics and diagnostics.
2.2. We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we process your personal information without your knowledge or consent, in compliance with the above rules, where required or permitted by law.
2.3. To the extent that such personal data contains special category data such as, for example: data relating to racial or ethnic origin, political opinion, religious or philosophical belief, trade union membership or criminal data then the processing of such data shall solely be for the purpose of complying with any duty imposed on the Company by an enactment including, but not limited to, legislation and regulatory obligations relating to Anti-Money Laundering and Combatting the Financing of Terrorism and all other related legislation.
2.4. The Company will not make decisions about you based on automated processing of your personal data.
2.5. We are required to have a lawful ground for our processing of your personal data. We process your personal data for the purposes described above on the basis of one of the following lawful grounds:
2.5.1. the processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override those interests. Where we rely on this lawful basis you have the right to object to such processing using the contact details set out below;
2.5.2. the processing is necessary for us to comply with our contractual duties to you under the terms of any contract which we have with you;
2.5.3. to comply with our legal and regulatory obligations;
2.5.4. where we have obtained your consent, which we will request in compliance with applicable data protection laws; and
2.5.5. (on rare occasions) where it is needed in the public interest.
