Cookie Policy

1. Cookies

Our site uses cookies to obtain information about the way you use and access the site. This information helps us to improve the site and deliver a better and more personalised service when you browse the site.

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website during your browsing session or on each subsequent visit. You can find more information about cookies at

By continuing to browse the site, you are agreeing to our use of cookies.

The following cookies are set on our site:

Cookie Name Purpose Type and Duration
Typo3 Management System These cookies are functionality cookies which assist the user experience relating to use of forms on the site. If, for example, a user forgets to fill in parts of a form when submitting it, we can auto-fill the values for those fields that have not been filled in, thereby reducing the amount of fields a user needs to amend. Session
Google Analytics These cookies are performance cookies which help us to understand how visitors use our site. The cookies collect information in an anonymous form on numbers of visitors to the site, where visitors to the site have arrived from and which pages of the site they visit. Persistent up to 2 years. To opt-out of Google Analytics: <a href=""></a>

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. The Help or Internet Settings function within your browser should tell you how to do this.  Please be aware that if you select to restrict cookies you may be unable to access or use certain parts or features of the site.

2. Privacy

We, Gulf Investment Fund plc, are committed to protecting and respecting your privacy and we ensure that we comply with the Data Protection Act 2018, the Data Protection (Application of GDPR) Order 2018, the GDPR and LED Implementing Regulations 2016 (as these may be amended and applied in the Isle of Man) and any successor legislation. This policy explains how we use and protect the information given to us by users of our site. We are the controller of your personal information. If you have any questions or comments regarding this privacy policy please contact David Humbles, a director of Gulf Investment Fund plc, at

(References in the privacy policy to the “GDPR” are to the European General Data Protection Regulation 2016/679)

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 data we collect from you may be transferred to, and stored at, a destination outside the Isle of Man or EEA. By submitting your personal data, you understand that your personal data may be transferred, stored or processed in the manner described in this privacy policy.
We will take all steps reasonably necessary to ensure that your data are treated securely and in accordance with this privacy policy as well as the requirement under applicable legislation. Unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data by implementing appropriate technical and organisational measures, we cannot guarantee the security of your data transmitted to us electronically.

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:


David Humbles


Gulf Investment Fund Plc

Millennium House

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: