GDPR Policy

Introduction

With effect from 25 May 2018, the EU General Data Protection Regulation (Regulation (EU) 2016/679) (together with applicable implementing laws, “GDPR”) will apply, to the extent relevant, to the processing of personal data by Aloxar Capital Ltd (“Aloxar”) in the course of their businesses, and certain other persons. This notice sets out information relating to those activities.

Aloxar

Aloxar are controllers of personal data for the purposes of the GDPR and will, in the course of Aloxar business, process personal data. Information regarding such processing is set out herein. Any person seeking information with respect to control or processing of personal data by Aloxar or seeking to exercise any rights afforded to them under GDPR should contact Aloxar Capital Ltd’s Chief Compliance Officer at info@aloxarcapital.com. Under GDPR, any person wishing to is entitled to make a complaint with respect to Aloxar control or processing of personal data directly to the relevant supervisory authority for data protection issues. In the UK this is the Information Commissioner’s Office (“ICO”). Contact details for the ICO may be found at www.ico.org.uk. The policies and procedures adopted by the Aloxar with respect to the control or processing of personal data may be amended from time to time. Similarly, the purposes for which Aloxar may control or process personal data may change from time to time. If any changes would require a material amendment to the information set out herein, details of such material changes will be made available in the current version of this document from time to time.

Summary of Personal Data

For the purposes of GDPR, personal data means any information about an individual from which that person can be identified. In the course of its business, Aloxar may collect, use, store and transfer personal information from individuals that are employees, directors, officers or other representatives or agents of market counterparties, professional services and other service providers, trade associations, public bodies and other entities or undertakings. Such personal data is typically limited in scope, and includes, for example, the name and contact details of such individuals, as well as some technical data (such as internet protocol addresses), usage data and information about marketing and communication preferences. In addition, Aloxar may also use, store and transfer personal information concerning former applicants for positions of employment at or membership of, or former employees or members of, Aloxar. Such personal data may include some or all of the following: name and contact details, information about employment and educational history, performance records, salary data, references, account details, identification data, tax information, social security numbers and information regarding immigration status. Aloxar will endeavour contact those former job applicants or former employees if the personal data processed in relation to the same is material in order to inform them of the continued processing of their personal data, the nature of that processing, the lawful basis upon which the processing is taking place, and their rights under the GDPR with respect to such processing. Collection of Personal Data Aloxar may collect personal data through a range of means. These may include direct interactions (where a person provides personal data to Aloxar through correspondence or other direct methods of communication), through third-party service providers (for example, recruitment agents) or publicly available sources (where Aloxar receives personal data through a publicly available source such as a website or publicly-available registry).

Use of Personal Data

Aloxar will only process personal data in circumstances where they have established a lawful basis under GDPR to do so. These circumstances include where the processing of the relevant data relates to a legitimate interest of Aloxar, further described below. In such circumstances Aloxar will have established that the processing is necessary for the relevant purpose, and not inconsistent with the interests, rights or freedoms of a relevant data subject. In accordance with the above, Aloxar has determined that the lawful bases for its processing of personal data are the legitimate interests of Aloxar to undertake activities necessary and ancillary to the carrying on of an investment management business, including where necessary for the purposes of Aloxar carrying out its activities relating to any fund, vehicle or account in respect of which Aloxar acts as manager, investment manager, sub-investment manager, make any representation as to the accuracy or completeness of such websites or information, has not and will not review or update such websites or information, and cautions browsers that any use made of such websites or information is at their own risk. Aloxar does not accept any liability arising out of the information contained on any linked website or Information provided by a third party and the use of such sites and information is at your own risk. This does not exclude or restrict any duty or liability that Aloxar has to its customers under the regulatory system in the United Kingdom.

Copyright, Trademarks and Other Rights

Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by Aloxar, its licensors or relevant third party providers. You may use the Information and reproduce it in hard copy for your personal reference only. The Information may not otherwise be reproduced, distributed, stored or transmitted without Aloxar's written consent. Nothing on this site should be considered as granting any licence or right under any trademark of Aloxar or any third party.

Governing Law

You agree that your use of this site and any dispute arising from the use of this site is subject to English law and you submit to the jurisdiction of the English courts.

Privacy, Data Protection & Cookies

Aloxar is committed to safeguarding the personal information which you may provide to Aloxar through this site and to the extent that Aloxar collects any personal information, Aloxar will hold it in confidence in accordance with the Data Protection Act 1998.

You may be asked to voluntarily provide certain personal information details about you such as your name, address, telephone number, email address details and other information in connection with Aloxar's customer registration procedures. Aloxar will use this information for the administration and servicing of your investments and other related activities and to ensure compliance with its obligations under the UK regulatory regime. Aloxar may disclose the information to its agents and service providers.

Please note that by submitting personal information you are consenting to such information being processed for the purposes referred to above. You agree that Aloxar has the right to use and store such data on its internal systems and to transfer it to its associated companies (if applicable), whether inside or outside the European Union, for the purpose of providing services to you. You should also be aware that the level of protection in relation to the processing of personal data may not be the same in countries outside the European Union as in the United Kingdom.

Aloxar also uses cookies. A "cookie" is a piece of information that is saved to your computer's hard disk by the web server. Confirmation of reading and accepting these terms and conditions will place a cookie on your computer's hard disk. This will ease your navigation around this website by not popping up these terms and conditions again during this browser session. This cookie is temporary and will be removed when you close your browser. The cookie is not used for any other reason.