At Brian Gale Holdings we respect your privacy, and we are committed to keeping your personal data secure. This notice (the “Privacy Notice”) explains how we use personal data that Brian Gale Holdings collects or is provided to Brian Gale Holdings. “Brian Gale Holdings”, “we” or “us” means Brian Gale Holdings Company LLP, its affiliates listed on Annex 1, and funds sponsored by any Brian Gale Holdings affiliate or subsidiary (“Brian Gale Holdings Affiliates”). For the purposes of applicable data protection law.

Brian Gale Holdings is a data controller in respect of your personal data.
1, About this Privacy Notice: This Privacy Notice governs and explains the handling and processing of personal data by Brian Gale Holdings while carrying out our investment management and related activities. Brian Gale Holdings is responsible for ensuring that we use your personal data in compliance with applicable data protection and privacy laws. 
2.  Personal data that we collect and process about you The nature of our relationship with you will determine the kind of personal data we might ask for from you directly or collect where permitted by law. In some cases, the collection and processing of certain of your personal data is obligatory and failure to collect that information (including where you fail to supply it) may result in us not being able to provide services or products to you. Information we may collect includes:
* information about you: your name, date of birth, contact details, personal email address, home address, professional information or employment related information, educational information or background, passport details, driver’s license details or other similar identification numbers and documents, to the extent permitted by law;
* information if you visit one of our offices: visual images collected via closed circuit television (CCTV);
* information that is automatically collected: details about your use of Brian Gale Holdings websites which may include internet browser history, IP addresses, and access to application forms;
* information about our contact with you and information we generate internally about our relationship with you:
3. Uses of your personal data Your personal data may be stored and processed by us in the following ways and for the following purposes: * to manage your relationship and/or account with Brian Gale Holdings;
* to assess clients’ and prospective clients’ applications or contracts for Brian Gale Holdings products and services;
* to keep our records up to date;
* for ongoing review and improvement of the information provided on Brian Gale Holdings websites to ensure they are user friendly and to prevent any potential disruptions or cyber-attacks;
* to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
* to communicate with clients and prospective clients in order to provide services or information about Brian Gale Holdings and other Brian Gale Holdings products and services;
* to effectively manage and strengthen client and prospective client relationships, understand client and prospective client needs and interests and learn more about our clients and prospective clients in order to develop, improve and manage the products and services we can offer;
* for the management and administration of Brian Gale Holdings business;
and * to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.


4, Legal Grounds We may use and/or disclose your personal data in these above described ways for a variety of reasons (subject to requirements under applicable local laws), namely:
• we are performing our contractual obligations with you;
• we have obtained your consent;
• we have legal and regulatory obligations that we have to discharge;
• we are permitted by law to do so;
• to protect your vital interests or those of another person;
• we need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
• the use and/or disclosure of your personal data as described is necessary for legitimate business interests;

5. Disclosure of your information to affiliates and third parties We may share your personal data amongst the Brian Gale Holdings Affiliates listed in Annex 1 for the purposes described above. We may also share your personal data outside of Brian Gale Holdings as further described below or as permitted by law:
• with our business partners (such as broker dealers and counterparties) who will be subject to appropriate data protection obligations;
• with representatives, agents, custodians, administrators, intermediaries and/or other third-party product providers appointed by the client, or prospective client or fund (such as accountants, auditors and professional advisors);
• with third party agents and contractors for the purposes of them providing services both to us and to clients, or prospective clients or funds (for example, Brian Gale Holdings accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies, printers). These third parties will be subject to appropriate data protection obligations; and
• to the extent required by law or regulation, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators or any commissioner of data protection, auditors or public authorities), or to establish, exercise or defend our legal rights.
6. Sale of personal data Brian Gale Holdings does not sell or disclose our clients’ personal information to other businesses or third parties for monetary or other valuable consideration. The information we provide to third parties are for the business purposes described in this Privacy Notice.
7. international transfers of personal data Brian Gale Holdings is a global business and as a result we or our external service providers collect and transfer personal data globally and may transfer your personal data to locations outside of your country or jurisdiction, including all countries of the Brian Gale Holdings Affiliates (see Annex 1), as well as the countries listed in Annex 2. Your personal data also may be processed by individuals operating outside of your country or jurisdiction who work for Brian Gale Holdings or for one of our external service providers. Brian Gale Holdings shall ensure that in case of transfer and processing of personal data outside the EEA, Switzerland, the UK and the Dubai International Financial Centre (in respect of which the laws of those jurisdictions apply), such processing is carried out only where allowed by an adequacy decision of the European Commission, Switzerland, the UK Information Commissioner’s Office (“ICO”) and/or the Dubai International Financial Centre (DIFC) and/or Brian Gale Holdings has provided for appropriate safeguards which provide you with enforceable data subject rights and effective legal remedies.

8. Security of personal data Brian Gale Holdings has extensive controls in place to maintain the security of personal data. As a condition of employment, Brian Gale Holdings employees are required to follow all applicable laws and regulations, including in relation to data protection laws. We limit access to personal data to authorized employees, representatives and service providers who require access for the purposes described in this Privacy Notice. Unauthorized use or disclosure of personal data or confidential client information by a Brian Gale Holdings employee is prohibited and may result in disciplinary measures. We also maintain a variety of physical, electronic, and procedural safeguards aimed at protecting personal data and confidential information.
9. Retention of personal data We hold Personal Data on our systems (or those of our service providers) for the duration needed or permitted in light of the purpose(s) for which it was obtained.

10, Rights under Relevant Data Protection Law * Where permitted by applicable law and regulation, you have a number of legal rights in relation to the personal data that we hold about you. These rights may include:
the right to access your personal data currently in our possession or which may have been used or disclosed by us within the last 12 months;
* the right to obtain information regarding the processing of your personal data and access to your personal data which we process at the time of your request;
* the right to request that we rectify your personal data if it is inaccurate or incomplete;