About this notice

Kedge Capital is committed to processing Personal data in line with all applicable privacy and data protection laws.

This Privacy Statement sets out the purposes for which we collect, use and disclose (collectively “processing”) Personal data and how it is protected. It also sets outs individuals’ rights in relation to the processing of their Personal data.

“Personal data” means any information relating to you, but does not include data where you can no longer be identified from it such as anonymised aggregated data.

Kedge Capital is a trading name of B-FLEXION Fund Management (Jersey) Limited, part of the B-FLEXION Group. References to “we”, “us” or “our” are to Kedge Capital and other group entities also acting as data controllers as part of our group operations.

References to “you” or “your” are to individuals whose Personal data we process. References to "our website" or "the website" are to www.kedgecapital.com

If you have any questions about this Privacy Statement you can contact DPPC@bflexion.com

What information do we collect about you and what do we use it for?

Personal data held by us or on our behalf may include, but is not necessarily limited to, your name, address, place of business, email address, other contact details, corporate contact information, signature, regulatory status, correspondence records, IP address, details of the pages you visit on our website, and which browser you used to view our website, details relating to your investment activity or preferences. If you are a sole trader service provider or supplier to us we will also process your bank account details.  

The purposes and ‘lawful basis’ for processing your Personal data are set out in the table below. The law specifies certain ‘lawful bases’ for which we are allowed to use your Personal data.

Website Use

Suppliers and Services Providers

Clients, Prospective Clients, Investors and Prospective Investors

In addition to the uses above, please note that we may also process your information where we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Special categories of Personal data

There are more limited bases for processing special category Personal data. This is Personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation.

We do not intend to actively collect special category data about you.  Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally.  For example, where:

• you volunteer special category data to us or one of our processors, such as if you send us an email containing special category data;
• documents gathered for legal / regulatory purposes contain special category data, such as a due diligence search from public sources which includes special category data. 

Change of Purpose

We will only use your Personal data for the purposes for which we collected it (as identified above in the ‘Purpose’ column), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

How do we collect this information?

We typically collect Personal data about you when you provide information to us when communicating with us in writing, electronically, or by phone. For instance, when you request product documentation, forms of literature from us or otherwise correspond with us.

In addition, we may receive information about you from third parties, such as:

• public sources or information vendors;
• your legal, financial, tax or other professional advisers;

With whom will we share your information?

We may share your Personal data with a third party for the purposes described above where this is required by law, where it is necessary in order to take steps prior to the contract between you and us, or where we have another legitimate interest in doing so.

We may need to share your Personal data with:

• other entities within our group as part of our group operations,
• regulators;
• professional advisers including lawyers and auditors to the extent such information is relevant to the performance of their services; and
• any of our service providers where such information is relevant to their performance of such services.

We may share your Personal data with third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your Personal data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

International transfers of your Personal data

We store your data on protected servers within the European Economic Area (“EEA”).

Information we hold about you may be transferred to other countries (which may include countries outside the UK or the EEA) where our vendors conduct their activities. Where we transfer your Personal data to another country, we will ensure it is protected by the appropriate safeguards.

Please contact us at DPPC@bflexion.com for more information.

How long will we retain your information?

We will retain your Personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such Personal information in our records.

This will normally include any period during which we are dealing or expect to deal with you and what we consider to be a suitable period thereafter for our internal record-keeping purposes. In doing this we will have regard to the amount, nature, and sensitivity of the Personal data, the potential risk of harm from unauthorised use or disclosure of your Personal data, the purposes for which we process your Personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Subject to local record retention requirements, we generally will keep information relevant to our dealings with you for at least seven years following the last date of activity. 

Once we no longer require identified Personal data for the purposes for which it was collected, we will securely destroy such Personal data in accordance with applicable laws and regulations.

Accuracy of information

It is important that the Personal data we hold about you is accurate and current. Please let us know if your Personal data which we hold changes during your relationship with us.

Your rights in relation to your information

You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:

• request access to your Personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
• request rectification of your Personal data; 
• request the erasure of your Personal data;
• request the restriction of processing of your Personal data;
• object to the processing of your Personal data;
• request the transfer of your Personal data to another party.

If you want to exercise one of these rights please contact us at DPPC@bflexion.com

Subject to the jurisdiction in which we operate, you have the right to complain to a data protection authority about our collection and use of your personal information, for example – 
i)    B-FLEXION Jersey entities you can contact the Jersey Office of the Information Commissioner, or by searching their website at https://oicjersey.org.
ii)    B-FLEXION Irish entities, you can contact the Irish Data Protection Commission, or by searching their website at https://www.dataprotection.ie/

Fees

You will not usually have to pay a fee to access your Personal data (or to exercise any of the other rights). However, we may charge a reasonable fee should we deem your request for access to be manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal data is not disclosed to any person who has no right to receive it. 

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact DPPC@bflexion.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.

Cookies

Cookies are small data files stored on your computer’s hard drive by a website. Among other things, cookies make the Website work, and help us improve our Website and your experience. We use cookies to see which areas and features are popular, and to count visits to the Website. Like many Websites, we may automatically collect information using “cookies”.

Cookies in themselves do not identify you, just the computer or device you are using through your Internet Protocol address (IP address).

We may use the following types of cookies:

“Session based” cookie. This is essential for parts of the Website to operate and has already been set. It is used to maintain the state of a user’s actions so as not to constantly request the same information from them within a “session”. 
“Essential” cookie. This is essential for parts of the Website to operate – for example, it lets us know that you have clicked on a link to a new page and that we should now serve that new page to you. 
“Analytics” cookie. This is used to collect information about how you use our site, such as where you have come to the Website from and which Website pages you have visited. We use the information to help us improve the Website.

We do not collect other information, such as website usage activity and preferences (also known as demographic or profile data) via the Website, and do not have Advertising cookies.

With most Internet browsers, you can erase or block cookies or ask to receive a warning before a cookie is stored. The “Help” function within your browser should tell you how. Alternatively, you may wish to visit www.youronlinechoices.eu which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies.

Restricting cookies will not have an impact on the functionality of our website, but it will not remember any preferences (such as language) that you have chosen, and you will have to change the settings each time you visit our site.

Changes to this Privacy Statement

We reserve the right to update this Privacy Statement at any time, and we will make an updated copy of such Privacy Statement available to you and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal data.

Further information

This Privacy Statement was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of Personal data. If you require any further information, please do not hesitate to contact DPPC@bflexion.com.