In accordance with the EU's General Data Protection Regulation ("GDPR"), which came into force on 25 May 2018, GSA hereby provides you with the following Privacy Notice, which describes how we collect and use personal information about you.
In this Privacy Notice:
- "GSA", "us" and "we" means each of GSA Capital Partners LLP, GSA Capital Services Limited, Green Park Research Limited, GSA Capital Partners (New York) LP, GSA Capital Partners (USA) LP, each series within that LP, GSA PEV LP, GSA NYGP Ltd and GSA Capital Partners (Hong Kong) Limited.
- "You" means the individual whose personal information is held and used by GSA.
- "Personal information" or "personal data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). More sensitive personal data, such as information about a person's health or sexual orientation, may require more protection and restrictions on its usage when in GSA's hands. Further explanation of the types of personal information, and the use that GSA may make of it, is set out below.
This Privacy Notice applies to all external parties who may provide GSA with their personal data, or the personal data of those individuals who represent them in the course of their interactions with GSA: contractors and service suppliers to GSA, GSA's clients, trading counterparties, investors and potential investors, and GSA's recruitment candidates. GSA will be a Data Controller, as defined under GDPR, for personal data it obtains in respect of such individuals. This Privacy Notice does not apply to GSA staff.
Reasons for collecting and processing your information
Depending on the nature of your relationship with GSA, GSA needs your personal information in order to provide you with services and to execute its legitimate interests, such as:
- performing its legal and regulatory obligations, including those which arise in connection with any contract or relationship with you;
- providing investment management services to our funds and managed account clients, including the execution and facilitation of trading in financial instruments;
- providing you with information, opportunities, services and/or products which you request from GSA or which GSA considers may interest you, and to determine your suitability to receive such materials from GSA;
- facilitating communication with you and your staff, including servicing our relationship with you effectively; and
- making decisions regarding the creation, maintenance and/or termination of a relationship with you, including a contractual, employment or professional services relationship.
Some of the above grounds for use will overlap. If you fail to provide certain information when requested, or we fail to use your personal information for these purposes, GSA may not be able to perform, administer or otherwise commit to any relationship with you, including any contractual relationship, and we, or our funds and managed accounts, may no longer be able to do business with you.
We will only use your personal data in compliance with all applicable laws, and where our legitimate interests do not override your fundamental rights. We will only use your personal information for the purposes for which we collected it, unless we need to use it for another reason compatible with its original purpose of collection. We may process your personal information without your knowledge or consent where such usage is required or permitted by law.
Personal information we collect about you, how we collect and store it, and how long we will use it
We collect your personal information either directly from you or from a third party who refers us to you. We may also collect personal information from third parties including credit reference, background check and recruitment agencies. Depending on the nature of our relationship with you, we may collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and email addresses (professional and/or personal).
- Details of concerning your current employment or workplace, including your CV, your professional history, your regulatory status, your investment history and experience, your educational, employment and residency qualifications.
- Personal details concerning you, including your date of birth, your gender, your marital status, dependants, next of kin and emergency contact details.
- CCTV footage in the event that you visit our offices.
- Information about your use of our investor portal and/or managed account portal.
- Publicly available personal information concerning you.
We will retain your personal information for as long as necessary to fulfil the purposes we have collected it for, including for the purposes of satisfying any legal requirements. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm to you from its unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
GSA is committed to protecting the privacy and security of your personal information. We safeguard your data through a series of electronic, physical and procedural controls, which restricts access to your personal information to those staff and third parties who need access to your information. In some circumstances we may anonymise your personal information so that it can no longer be associated with you. Given the laws and regulations applicable to GSA's business and the complex contractual arrangements that GSA's business has developed, we anticipate holding your personal data on an ongoing basis. Information held by GSA will also be archived over time and held securely at both GSA and third party locations.
Sharing your personal data with third parties
We will share your personal information with third parties where required by law, or to facilitate our legitimate interests explained above. "Third parties" includes service providers who carry out payment services and custodial work, perform background checking, AML & KYC checks, administration and recruitment services, and also perform several types of necessary IT services for GSA. We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information. We have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.
You have rights as an individual which you can exercise in relation to the information we hold about you. You can read more about these rights on the Information Commissioner’s Office website – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly. If you have any questions about this privacy notice or how we handle your personal information, please contact GSA's Data Protection Officer (firstname.lastname@example.org). This Privacy Notice does not form part of any agreement between you and GSA for the provisions of any services or goods between us. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical. We may also notify you in other ways from time to time about the processing of your personal information.