Legal

Privacy Policy

Last updated: June 1, 2021

This Privacy Policy addresses natural persons and refers to how Hedge Capital LTD (“The Fund”) collects and processes your personal data and informs you of your rights in accordance with relevant national laws and the General Data Protection Regulation of the EU 2016/679 known as GDPR. This privacy policy will explain how the Fund uses the personal data we collect from you when you use www.hedge.capital (“the Website”) and our fund investment services (“the Services”). Your personal data includes information that may lead, either directly or in combination with others, to your identification as a natural person.

General Principles

The Fund is bound, inter alia, by the following principles when processing personal data:

  • Lawfulness, fairness and transparency
  • Purpose limitation
  • Data minimisation
  • Accuracy
  • Storage limitation
  • Integrity and confidentiality
  • Accountability

Data Controller

The Fund is the data controller, i.e. the person who collects data and is responsible for them. Contact information for purposes of data protection may be found on the Website.

Purposes of Processing

The Fund processes personal information primarily for the following purposes:

  • For orderly provision of services to its clients
  • To be compliant with legal obligations
  • For performance of contracts
  • To prevent money laundering and terrorist financing
  • To run a functional and secure Website

Legal Grounds for Collection

Collection of personal data by the Fund is required particularly by relevant laws on investment companies and investment funds and its implementing acts, on measures to combat money laundering and terrorist financing, and public interest to prevent money laundering and terrorist financing. Consent is required to process personal data to run a functional and secure Website.

What Data Do We Collect?

Personal identification information

As required by relevant KYC/AML regulations when you become a client of the Fund. We may collect, inter alia, your name, date of birth, personal ID or passport, address, phone, email, tax or corporate identification number, company legal status and company beneficial owners identification information.

Information from third parties

Information about you or your company representatives or beneficial owners from third party sources as permitted by applicable law, such as public databases, ID verification partners or sanction lists.

Automatically collected data

The Fund or its service providers may receive and store certain types of information automatically whenever you interact with the Website or use the Services. This may include information about the specific devices you are using, such as the hardware model, operating system version, web-browser software, your Internet Protocol (IP) address/MAC address/device identifier, broad geographic location and other technical data collected through cookies, pixel tags, and other similar technologies.

How Do We Collect Your Data?

You directly provide the Fund with most of the data we collect. We collect and process data:

  • Directly during the process of contracting with the Fund for using the Services.
  • Indirectly during the processes of verification of submitted personal or company data at third party databases such as OFAC list, UN and EU sanction lists or identification document registers.
  • Directly or indirectly during your use or view of the Website via your web browser.

How Will We Use Your Data?

The Fund collects your data to be able:

  • To comply with a legal or regulatory obligations. Especially to verify your identity by comparing your personal information against third-party databases in order to stay compliant with relevant KYC/AML regulations.
  • To prevent and investigate potentially prohibited or illegal activities, and/or violations of relevant laws and regulations.
  • To contact you with regards to any actions or duties arising from the contractual relationship, such as regular investment updates or important notices.
  • To provide you with information on a functional and secure Website and to enhance security, prevent fraud and combat spam or other malware or security risks.
  • To enforce agreements with third parties as needed to maintain the Website or provide you the Services.

What Happens When You Reject Providing Data?

For contracting purposes: The Fund is not allowed to contract with a person who rejects to provide its personal data in the range set by applicable laws. If you reject to provide such data, the Fund must not enter into an agreement with you and/or must terminate an existing agreement.

For Website use: If you reject to provide your data, the Website will continue to work. However, your experience from the Website and its functions may be worsened.

How Do We Store Your Data and For How Long?

The Fund maintains appropriate physical, technical, and administrative safeguards to protect the security and confidentiality of your personal information. The Fund will keep your data for not longer than mandated by relevant laws or regulations or than necessary. Once this time period has expired, we will delete or discard your data.

Marketing

The Fund will not use your personal data for marketing purposes.

Can Data Be Provided to Third Parties?

To comply with applicable laws, the Fund may make your data available to persons and bodies who are obliged or entitled to be provided such data. This concerns primarily state bodies or auditors.

Will My Data Be Transferred to Third Countries?

The Fund does not plan to transfer your data to countries outside the European Union. In case a transfer of data to a third country takes place, the Fund shall use binding corporate rules approved by the European Commission and follow the rules set out in GDPR.

Your Data Protection Rights

Every user is entitled to the following rights:

  • Right to access — You have the right to request copies of your personal data.
  • Right to rectification — You have the right to request correction of inaccurate or incomplete information.
  • Right to erasure — You have the right to request erasure of your personal data, under certain conditions.
  • Right to restrict processing — You have the right to request that the Fund restricts the processing of your personal data, under certain conditions.
  • Right to object to processing — You have the right to object to the Fund's processing of your personal data, under certain conditions.
  • Right to data portability — You have the right to request that the Fund transfers your data to another organization, or directly to you, under certain conditions.
  • Right to lodge a complaint — The competent supervisory authority in the Czech Republic is Úřad pro ochranu osobních údajů, Pplk. Sochora 27, 170 00 Praha 7, www.uoou.cz.

If you make a request, we have 1 month to respond. Contact: fundinvestors@ramparts.gi

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit the Website, we may collect information from you automatically through cookies or similar technology.

Types of cookies we use

  • First-party / Strictly necessary: Session cookies enabling browsing and website security.
  • Functional: Cookies that remember visitors in order to improve user experience.
  • Third-party functional: Session security cookies.

You can set your browser to not accept cookies. For more information visit www.allaboutcookies.org.

Changes to Our Privacy Policy

The Fund keeps its Privacy Policy under regular review and places any updates on this Website. The Fund reserves the right to modify this Privacy Policy at any time.

How to Contact Us

If you have any questions or would like to exercise any of your data protection rights, please contact us at fundinvestors@ramparts.gi.

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