On 25 May 2018, the General Data Protection Regulation (EU) 2016/679, known as “GDPR,” came into effect. GDPR mandates that Personal Data and Sensitive Personal Data be treated in certain ways and only be collected for certain reasons.
Alinda Capital Partners LLC (together with its affiliated entities, including but not limited to Alinda Capital Partners LLP, “Alinda”) treats all Personal Data and Sensitive Personal Data in accordance with GDPR and other data protection laws.
What Are Personal Data and Sensitive Personal Data and Why Does Alinda Collect Them?
“Personal Data” means any information that could identify a living person. Personal Data may include names, postal addresses, email addresses, telephone numbers, copies of government-issued identification or any other information that might identify an individual.
“Sensitive Personal Data” means Personal Data that reveal a living person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership; data concerning health or sex life and sexual orientation; and genetic data or biometric data.
Alinda may collect Personal Data and Sensitive Personal Data for purposes including, but not limited to, verifying investors’ identities, verifying employees’ identities and maintaining its operations as a business. Alinda would collect Personal Data and Sensitive Personal Data on bases including, but not limited to, the performance of contracts, compliance with legal obligations and the pursuit of legitimate interests.
Alinda will retain Personal Data and Sensitive Personal Data in accordance with legal and regulatory requirements, as set out in this Privacy Notice and in Alinda’s Regulatory Compliance Manual and other policies and procedures.
Whom Alinda Shares Information With
Alinda will not share Personal Data or Sensitive Personal Data with third parties without the data subject’s consent, except where Alinda is required by law or by contract to do so.
Examples of a requirement by law include, but are not limited to, the transmission of the above-mentioned data to law enforcement agencies, financial regulators, and public authorities, courts and dispute-resolution bodies.
Examples of a requirement by contract include, but are not limited to, the transmission of the above-mentioned data to IT services, client relationship management platforms and service providers with a need to access such information.
Transferring Personal Data or Sensitive Personal Data Outside the EEA
Alinda will only transfer Personal Data or Sensitive Personal Data outside of the European Economic Area (“EEA”) when such a transfer complies with GDPR. Reasons for transferring Personal Data and Sensitive Personal Data outside the EEA include, but are not limited to, public interest, contractual obligations, the pursuit or defense of legal claims and, as permitted by law, Alinda’s legitimate interests.
In the event of such a transfer of Personal Data or Sensitive Personal Data outside the EEA, Alinda will ensure that any recipient(s) of Personal Data or Sensitive Personal Data maintain levels of data protection comparable with the protections afforded by GDPR.
Under GDPR, you, as a data subject, have certain rights, as explained below.
The right to be informed: to contact Alinda, and to be informed by Alinda how, why and for what time period Alinda will use your Personal Data and/or Sensitive Personal Data.
The right of access: to request a copy of your Personal Data or Sensitive Personal Data which are held by Alinda.
The right to rectification: to request that Alinda correct any of your Personal Data or Sensitive Personal Data if they are found to be inaccurate or out of date.
The right of erasure (also known as the right to be forgotten): to request that Alinda erase your Personal Data or Sensitive Personal Data where Alinda no longer has a basis to retain such data.
The right to restrict processing: to prevent Alinda from processing of your Personal Data or Sensitive Personal Data under certain circumstances as described in GDPR.
The right to data portability: to request that Alinda provide you with a copy of your Personal Data or Sensitive Personal Data in a commonly used and machine-readable format.
The right to object: to object to any further processing of your Personal Data or Sensitive Personal Data, where such processing, including profiling, is based on Article 6(1)(e) or (f) of GDPR.
The right not be subject to decisions based solely on automated processing, including profiling: to object to the automated making of decisions or the automated creation of profiles based on your Personal Data or Sensitive Personal Data. Alinda does not currently make decisions or create profiles automatically.
Data Protection Officer
Alinda has determined that the Chief Compliance Officer will take primary responsibility for ensuring Alinda’s compliance with GDPR, including the obligation to respond to any concerns raised by data subjects.
The Chief Compliance Officer is James McNamara, who can be reached on +1 917 751 3839 or firstname.lastname@example.org.
Changes to this Privacy Notice
Alinda may deem it necessary in future to make changes to this Privacy Notice and any related policies and other disclosures.