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We do not collect any personal identification data, such as names or contact details, about you unless it is voluntarily provided and/or we require this information to comply with a legal requirement e.g. the keeping of a statutory register of members..
The information we may collect and process about you includes:
- information that you provide in emails and letters you send to us, including keeping a record of that correspondence;
- information related to identification (including full name, signature, nationality, place and full date of birth, passport number, residential/registered address, and other contact details such as telephone number, e-mail address) where you have provided this to us;
- where necessary, information regarding your investment activity and in order to maintain investor records;
- shareholdings in a company or companies; anddetails of your visits to our website (including, but not limited to, traffic data, location data, weblogs and other communication data), and the resources that you access.
We use information held about you in the following ways:
- to provide you with information or services that you request from us;
- to communicate with you (including the mailing, in physical or electronic format, of periodical reports, notices or other communications that are necessary for the functioning of our relationship);
- to ensure that content from our website is presented in the most effective manner for you and for your device;
- to enable us to improve our services;
- to keep a record of the services you have subscribed to;
- to facilitate the internal administration of Gulf Investment Fund plc;
- to comply with our legal and regulatory obligations; and
- for any other purpose which you have specifically consented to when providing the information.
If you have provided us with your contact details, we may contact you using any of the contact details provided. We will not contact you for direct marketing purposes.
Why we collect your personal data
We will process your personal data on the following lawful grounds:
- the processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override those interests;
- 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 (including where you acquire shares in Gulf Investment Fund plc);
- to comply with our legal and regulatory obligations; and
- where we have obtained your consent.
Some of the grounds for processing described above will overlap and there may be several grounds which justify our use of your personal data.
We will share certain limited personal data with the following related parties:
- our administrators and registrar;
- professional advisors, such as accountants, lawyers, proxy advisers or other consultants (but only so far as necessary); and
- our board members.
During the usual course of business, we do not transfer data outside of the European Economic Area (EEA). However, from time to time, personal data may be made available to our board members located temporarily or otherwise outside the EEA for management/internal administration purposes. Where personal data is provided to a board member who is located outside of the EEA, we will take every reasonable step to ensure that your personal data are processed with at least the same standards of data protection as those provided under Isle of Man data protection legislation, including by imposing specific obligations and requirements on the recipient. This transfer of personal data is necessary: (i) in order to allow us to continue providing the information or services to you which you have requested; or (ii) pursuant to a contract between us. Such transfers will not include special category data (i.e. more sensitive personal data). If you would like further information, please contact us.
We do not share, sell or distribute your personal data with or to unrelated third parties except in order to provide you with the information or services which you have requested, or as provided in the following limited circumstance:
- to third parties who support our administration, information technology or handle mailings or events on our behalf (our service providers);
- to comply with a legal or regulatory requirement, or for the administration of justice;
- where such disclosure is necessary in relation to a potential sale or merger of our business.
The information we collect about you is stored under our control and with our selected archive and data backup service providers.
We have put in place security procedures plus technical and organisational measures that we consider appropriate to safeguard your personal information and which are intended to guard against unauthorised or unlawful access to, alteration, disclosure or destruction of personal data and against accidental loss or destruction of or damage to personal data. Access to internal data servers is limited to specialist personnel and is controlled using defined policies.
We will only retain the information gathered for as long as is necessary, having regard to relevant laws and regulations and our data retention procedures. Such information may be retained after our client relationship has ceased, and for client identification purposes in accordance with our data retention procedures. You may ask us for further information on these.
You may advise us at any time that you no longer wish to receive communications and information from us. We will then remove your details to the extent that we are able to (for example we may need to retain a record of those people who have advised us that they no longer want to receive communications from us and entries in statutory registers so long as still accurate).
You also have the right to access some or all of the personal information we hold about you and to have any inaccurate information about you corrected, your personal information removed or to ask us to cease processing your personal information in certain circumstances. If you agree we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone. We may ask for certain personal information when you contact us in order to confirm your identity.
If you have any questions, comments, requests or complaints in relation to the information that we hold about you, please email David Humbles, a director of Gulf Investment Fund Plc at: email@example.com
Gulf Investment Fund Plc
46 Athol Street
Isle of Man
You also have the right to lodge a complaint with the Isle of Man’s Information Commissioner, whose contact information can be found at: www.inforights.im.