Capricorn Fund Managers Limited (“Capricorn”)
Your privacy is very important to us. This Privacy Notice sets forth our policies with respect to non-public personal information of current, prospective and former investors and clients (collectively, “Investors”). These policies apply to investors in our Funds, other managed account clients and internet users of the Capricorn Fund Managers Limited website (the “Site”) and may be changed at any time. Changes will be effective immediately upon posting onto our Site for internet users or provided to you if visiting our offices.
Capricorn Fund Managers Limited (“CFMUK” or the “Firm”) is required to comply with the Data Protection Act 2018 (“DPA”), the United Kingdom General Data Protection Regulation as defined in section 3(10) and 205(4) of the UK’s DPA, the Privacy and Electronic Communications (EC Directive) Regulations 2003, and (to the extent applicable) the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“GDPR”) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. The Firm’s supervisory authority with respect to the GDPR is the Information Commissioners Office (“ICO”). In addition, the Financial Conduct Authority has indicated that firms should ensure compliance with GDPR as part of their obligations under the FCA Handbook.
If you would like a copy of the Firm’s Data Protection Policy, please send an email to [email protected]
Your information is the information which we obtain about you. This information includes your name, address, telephone number, email address, and any other contact details. It includes information which you give to Capricorn Fund Managers Limited (“Capricorn”) or which we obtain about you, through your use of this Site and/or in connection with any products Capricorn provide to you and in correspondence, including emails and conversations with Capricorn.
How we use Your Information
We will use your information to improve the calibre of online information and services offered.
Capricorn does not disclose your non-public personal information to anyone other than to our affiliates, and as permitted by law or as necessary in connection with the provision of Capricorn ‘s services to you, such as to Capricorn’s accountants, attorney’s, auditors, brokers and regulators and certain service providers and only as necessary to facilitate the acceptance and management of Capricorn’s relationship with you. Thus, it may be necessary under anti- money laundering regulations and similar laws, to disclose information about you in order to accept subscriptions for example to fraud prevention agencies or registers who will use your information to search their database when considering your application. These agencies may retain a record of the search and share your information with other organisations. We will only share your information on condition that these entities keep your information strictly confidential.
We may share your information with any governmental or regulatory body, if required to do so by law. Otherwise, we will not use your information for any other purposes.
Personal Data retention period
We will keep your personal data for such period as is required for us to provide our services to you, or such longer period as we may be required to process the data to ensure our compliance with all relevant laws and regulatory obligations to which we are subject.
Commitment to Online Privacy
At Capricorn, we understand the specific concerns of Internet users about what type of information is gathered and tracked on websites, how that information is used, and with whom it is shared.
A cookie is a small piece of information that an Internet site sends to a website visitor’s computer. In some cases, it is stored on the visitor’s computer’s hard drive. Cookies can save the visitor’s name, password, username, screen preferences and the pages of the site viewed by the visitor. Visitors may decline the Internet cookie by using the appropriate feature of their Web software, if available. Declining the Internet cookie may, however, interfere with a visitor’s ability to view certain content is this web site.
We work hard to ensure that our systems are secure and that they meet industry standards. Where appropriate, we employ firewalls, encryption technology, user authentications systems (e.g. passwords and personal identification numbers) and access control mechanisms to control access to systems and data. We will continue to assess new technology to evaluate its ability to provide additional protection for your personal information.
Right to Change Internet Privacy Statement
Under the GDPR, you have the following rights:
It is important to us at Capricorn to hear what visitors have to say about our Site. If you have any questions and/or concerns, or want to let us know what you think, please contact us by email at: [email protected]