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EXTERNAL PRIVACY NOTICE WORDING FOR VISTORS FROM THE EEA Last Updated 22/05/2018 Please note this wording applies to visitors to our website and users of Racepoint UK Limited Services from the EEA. We respect the privacy of every person who visits or registers with Racepoint UK Limited (the “Site”) and we are further committed to ensuring a safe online experience. We also respect the privacy of every person who uses the products and services that we make available from the Site or who engages with us to use the services that Racepoint UK Limited provides, namely Public Relations, Creative, Marketing and Media (our “Services”) or whose personal information we may process as a result of providing the Services to others or who applies to work at Racepoint UK Limited.

  1. Purpose of this Policy This privacy notice (“Privacy Notice”) explains to data subjects in the EEA our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information.This Privacy Notice will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it. This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services and/or to understand how your personal information may be processed by us as a result of providing the Services to others or when you apply to work at Racepoint UK Limited. Please take a moment to read and understand it. Please note that when using the Site it should be read in conjunction with our Website Terms of Use. Please also note that this Privacy Notice only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.
  2. Who are we and what do we do? The Site and our Services are operated by Racepoint UK Limited (“we”, “us” or “our”). For more information click here. Racepoint UK Limited is the data controller responsible for your personal information processed via the Site.Racepoint UK Limited is a UK company with registered company number (5968479) and whose registered office is at 2nd Floor Metro Building, 1 Butterwick, London, W6 8DL Please note that depending on with which Racepoint UK Limited you contract in relation to the Services other Racepoint UK Limited entities may also be data controllers responsible for your personal information processed in relation to the Services.
  3. How to contact us? If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please contact us by:
  4. What personal information do we collect and how do we use it? Our primary goal in collecting personal information from you may be to: (i) verify your identity; (ii) help us deliver our Services; (iii) improve, develop and market new Services; (iv) carry out requests made by you on the Site or in relation to our Services; (v) investigate or settle inquiries or disputes; (vi) comply with any applicable law, court order, other judicial process, or the requirements of any relevant regulator; (vii) enforce our agreements with you; (viii) protect the rights, property or safety of us or third parties, including our other customers and users of the Site or our Services; (ix) provide support for the provision of our Services; (x) recruitment purposes; and (xi) use as otherwise required or permitted by law.To undertake these goals we may process the following personal information: If you are a visitor to the Site:
    • Name and job title.
    • Contact information including email address.
    • Your interaction with the Site.
    • Demographic information such as postcode, preferences and interests.
    • Other information relevant to provision of Services.
    If you are an individual client, in receipt of our Services or prospective individual client:
    • Name and job title.
    • Contact information including email address.
    • Payment information.
    • Racepoint UK Limited account number.
    • Other information relevant to provision of Services.
    • Information that you provide to us as part of our providing the Services to you which depends on the nature of your agreement with Racepoint UK Limited
    • Relevant information as required by any regulatory Know Your Client and or Anti Money Laundering regulations (or similar). This may possibly include evidence of source of funds, at the outset of and possibly from time to time throughout our relationship with clients, Racepoint UK Limited etc., which we may request and/or obtain from third party sources. The sources for such verification may comprise documentation which we request from the prospective client or through the use of online sources or both.
    Primarily Racepoint UK Limited is engaged by corporate clients, and as such those clients, are not data subjects. However as part of such instructions personal information about other persons may be provided to us (e.g. personal information relating, without limitation, to any of our corporate clients, or prospective clients, workers, employees, partners, members, representatives or similar). If you are an individual whose personal information may be processed by us as a result of providing the Services to others (including individual and corporate clients) we will process a variety of different personal information depending on the Services provided in question. The following is a non-exhaustive list which is reflective of the varied nature of the personal information processed as part of our business. For instance, if we are providing services to a corporate client we may be provided with, and then process, personal information about the client’s representatives including but not limited to the representative’s name and contact details and any other information necessary to fulfil the Services (e.g. but without limitation including any regulatory Know Your Client and or Anti Money Laundering regulations (or similar) information)). We might also need to process personal information in relation to corporate clients’ workers who use a Racepoint UK Limited Service in the course of their work for our corporate client. Please note that below when we reference the processing of personal data related to any corporate clients, we also mean any individual whose personal information may be processed by us as a result of providing the Services to others (including individual and corporate clients, investors, shareholders or intermediaries). If you are a potential recruit to a Racepoint UK Limited office:
    • Name and job title.
    • Contact information including email address.
    • Curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us.
    • Other information relevant to potential recruitment to Racepoint UK Limited
    If you are a supplier (including subcontractors and individuals associated with our suppliers and subcontractors) to Racepoint UK Limited we collect and process personal data about our suppliers in order to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide professional services to our clients. If you are a visitor to any Racepoint UK Limited office in the EEA, we require visitors to our offices to sign in at reception and keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need to know basis (e.g. to look into an incident). In particular, we may use your personal information for the following purposes:
    • Fulfilment of Services. We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services to enable us to perform the Services that we provide to you. Please not also that our Master Services Agreement also apply when we provide the Service. These purposes include:
      • to ensure any clients, are aware of any fund or investment performance
      • to make necessary regulatory communications with clients
      • general clients, management to ensure Services are provided correctly; and
      • relationship management between Racepoint UK Limited and any clients,
      What is our legal basis? It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.
    • Your feedback about our Services. From time to we will contact you to invite you to provide feedback about our Services. We use this information to help us improve the quality of service provided by our staff. We also use your feedback to monitor the quality of our Services.
    • What is our legal basis? It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
    • Business administration and legal compliance. We use your personal information for the following business administration and legal compliance purposes:
      • to administer any funds that we manage and in which you may be an investor and/or a shareholder (please note further information will be provided in any specific fund or prospectus privacy notice);
      • to comply with our legal obligations[(including Know Your Client, Anti-Money Laundering or Anti-Bribery or similar obligations);
      • to enforce our legal rights;
      • to record any trades;
      • to make any necessary corporate filings;
      • protect rights of third parties; and
      • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
      What is our legal basis? Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.
    • RecruitmentWe use your personal information for the following recruitment purposes:
      • To assess your suitability for any position for which you may apply at Racepoint UK Limited including member level positions, employment or freelancer positions, summer placements or internships and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application; and
      • To review Racepoint UK Limited equal opportunity profile in accordance with applicable legislation, and Racepoint UK Limited does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit
      What is our legal basis? Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for Racepoint UK Limited. We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent. Please note if you want further information about how we process personal data in relation to Recruitment please let us know and we can provide you with our full Recruitment Privacy Notice. We analyse your contact details with other personal information that we observe about you from your interactions with our Site, and/or with our Services such as the Services you have viewed. Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:
      • an IP address to monitor Site traffic and volume;
      • a session ID to track usage statistics on our Site;
      • information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.
      Our web pages contain “cookies” "web beacons" or “pixel tags.” (“Tags”). Tags allow us to track you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Please see our Cookie Policy for further information. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our registered users like to see. We also use this information for marketing purposes (see the marketing section below for further details). What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients.
    • Marketing communications. We carry out the following marketing activities using your personal information:
      • Postal marketing. We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Client Insight and Analysis section above for more details of the information collected and how it is collected) and/or your address details, to send you marketing communications by post. What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. Where your personal information is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal information for postal marketing.
      • Email marketing.We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services (see the Client Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so. What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.
      • Online personalised advertising.We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Client Insight and Analysis section above for more details of the information collected and how it is collected) and our own proprietary tool FieldFacts to provide you with personalised online advertising. What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
      • Social media remarketing.We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Client Insight and Analysis section above for more details of the information collected and how it is collected) and our own proprietary tool FieldFacts to provide you with personalised advertising on social media channels operated by Facebook, Microsoft and/or Google where you are a registered user of such services. What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only engage in social media remarketing where you have consented to us [using your email address] [sharing your email address in an encrypted format with Facebook, Microsoft and/or Google respectively] for marketing purposes.
  5. How do we obtain your consent?Where our use of your personal information requires your consent, you can provide such consent:
    • at the time we collect your personal information following the instructions provided; or
    • by informing us by e-mail, post or phone using the contact details set out in this Privacy Notice.
  6. Our use of cookies and similar technologies Our Site uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.
  7. Sharing data We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards. For details of our Racepoint UK Limited office locations, please click here. We may share personal data with other Racepoint UK Limited entities where necessary for administrative purposes and to provide professional services to our clients, investors, shareholders and intermediaries. Third party organisations that provide applications/functionality, data processing or IT services to us We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. Third party organisations that otherwise assist us in providing Services or information (including but without limitation any administrator of any Racepoint UK Limited fund) Third party organisations that assist us with our marketing activities listing above Auditors, lawyers, accountants and other professional advisers Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
  8. Extra-EEA TransfersIf you are based within the EEA, please note that where necessary to deliver the Services we will transfer personal information to countries outside the EEA (including to Racepoint UK Limited US entities). When doing so we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.
  9. How long do we keep your personal information for?Regarding visitors to the Site, will retain relevant personal information for at least six years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world) (or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations). Regarding personal information we have processed as part of providing the Services to any clients, we will retain relevant personal information for at least six years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world) (or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations). We may then destroy such files without further notice or liability. If you request your files and documents we may charge you for the costs of copying a duplicate. If personal information is only useful for a short period e.g. for specific marketing campaigns we may delete it.
  10. Confidentiality and security of your personal informationWe take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
    • unauthorised access;
    • improper use or disclosure;
    • unauthorised modification; and
    • unlawful destruction or accidental loss.
    All of our members, employees, workers and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to the Site and all users of our Services.
  11. How to access your information and your other rights?You have the following rights in relation to the personal information we hold about you:
    • Your right of access. If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
    • Your right to rectification.If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
    • Your right to erasure. You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
    • Your right to restrict processing. You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
    • Your right to data portability. With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
    • Your right to object. You can ask us to stop processing your personal information, and we will do so, if we are:
      • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
      • processing your personal information for direct marketing.
    • Your rights in relation to automated decision-making and profiling.You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
    • Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
    • Your right to lodge a complaint with the supervisory authority.If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to your local data protection regulators using the following details - for instance but without limitation those regulators in the EU in which Racepoint UK Limites has offices are as follows: In the UK the data protection regulator is the Information Commissioner’s Office (ICO). You can contact the ICO using the following website https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113. In Ireland the data protection regulator is the Data Protection Commissioner- Ireland (DPC). You can contact the DPC using the following website https://www.dataprotection.ie/docs/Making-a-Complaint-to-the-Data-Protection-Commissioner/r/18.htm or by calling their offices on +353 57 8684800. In Italy the data protection regulator is the Italian Data Protection Authority-Garante per la protezione dei dati personali (Garante Privacy).   You can contact Garante Privacy using the following website http://www.garanteprivacy.it/web/guest/home_en or by calling their offices on +39-06-6967 71 ETC.
  12. Collection of information by third-party sites and sponsorsThe Site contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites' privacy notices as Racepoint UK Limited has no control over information that is submitted to, or collected by, these third parties
  13. Changes to this Privacy NoticeWe may make changes to this Privacy Notice from time to time. To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information. To view our US Privacy Policy, please click here.