This Privacy Policy is issued by Vita Nova Hedge Fund (the "Company", "we", "us", and "our") in relation to www.vitanovahedgefund.com (the "Website") and the Website is administered by the Company.
The Company is committed to protecting your personal information and we take the privacy and security of your personal information seriously. We want to assure you that your information is properly managed and protected when it is in our hands. This Privacy Policy relates to our use of any personal information that we collect from you via the following online services:
- any group website that links to this policy; or,
- social media or group content on other websites.
The Privacy Policy also relates to personal information that we collect from other means, such as email, in person, or other third-party sources.
Collection of Personal Data
The Company will only use personal data in accordance with the provisions set out in this Privacy Policy. This Privacy Policy sets out the basis on which any personal data you provide to us, by any means whatsoever, will be collected and processed, the purposes of such processing and how we safeguard your personal data.
When you visit the Website or telephone or email the Company, we may collect and process personal information about you for the purpose of sales, administration, and marketing.
We may receive personal information about you, for example, when you contact the Company by doing any of the following:
- when you register, log in or complete other online forms, including the related mobile application (if any); or,
- when you respond to requests to submit personal information about yourself (if any); or,
- when you otherwise contact us by phone, in writing, or by post, and we may keep a record of that correspondence; or,
- based on any other information we receive about your transactions from our files, our affiliates or another source whether involved in your transactions or otherwise.
The information that we collect may include:
- personal identification number and contact details such as your full name, date of birth, Tax Reference Number (or equivalent), email address, home address, and telephone number;
- your marketing preferences;
- user names, passwords; and/or,
- sensitive personal information (although we will always explain clearly when and why we need this information and the purpose for which we will use it).
Use of Personal Data
Managing Partners Fund Management Limited (the "Manager") may collect and use information about visitors to the Website to conduct its business, including identifying your requirements, delivering services and information which you have requested, promoting other services which may be of interest to you and collating web user statistics.
We may also use it to contact you for your views on our services and events and to notify you occasionally about important changes or developments to the Website or our services, unless you have opted out of receiving such services as set out in the Managing your preferences section below.
Data Transfer and Consent
The personal information that we collect from you may be transferred by the Company to MPFM to and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us, a service provider, or business partner. The purposes and processing associated with any such transfer will comply with all applicable data protection regulations, including the EU General Data Protection Regulations, and with our obligation to protect your personal information and keep it secure. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it has in the EEA.
By submitting your personal information, you agree to us transferring, processing, and storing your personal information as described above. In certain circumstances, we may ask for your explicit consent to make an international transfer of your information.
Disclosure of Information
We take all reasonable care to prevent any unauthorised access to your personal information. We may disclose your personal information to:
- any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
- our affiliates or professional advisers; or,
- where we need to send the information to persons or organisations who work on our behalf to provide a product or services to you, but such persons or organisations may only use this information in order to provide such product or service and not for any other purpose.
We may also share or sell, as permitted by law, information to other companies who we believe may have products and services of interest to you. If you do not wish to receive information from us or from other sources, or you wish to review your settings, please follow the instructions under the Managing your preferences section below.
We may also share this information about our visitors, customers, or former customers to companies that perform marketing services on our behalf or with whom we have joint marketing agreements.
How we Protect your Data
We are committed to protecting the confidentiality and security of the information that you provide to us and we put in place appropriate technical, physical, and organisational security measures to protect against any unauthorised access or damage to, or disclosure or accidental loss of, your information.
We will not share your information other than as provided for in this Privacy Policy, however, your information may also be disclosed when we believe in good faith that the disclosure is:
- required by law; or,
- to protect the safety of our employees, the public or group property; or,
- required to comply with a judicial proceeding, court order, or legal process; or,
- in the event of a merger, asset sale, or other related transaction; or,
- for the prevention or detection of crime (including fraud).
You should be aware that communications over the internet, such as emails, are not secure unless they have been encrypted. Wherever possible, the Company uses encryption, however, we cannot guarantee the security of your information absolutely and you acknowledge that we may be subject to breaches of security through no fault of our own.
Fraud Prevention and Detection
We may, as a matter of law, and without requiring notice or consent, obtain information about you from our third-party suppliers and other third-party databases to detect and prevent fraudulent activity within the group and to monitor and/or enforce the Company’s compliance with any regulatory rules and codes. We may also share your information with regulatory bodies in the United Kingdom or, if applicable, overseas, as well as with other companies (directly or via shared databases) to prevent and detect fraud.
In order to prevent and detect fraud we may at any time:
- share information about you with other organisations and public bodies including the police;
- undertake additional fraud searches; or,
- check and/or file your details with fraud prevention agencies and databases, and if you give us false or inaccurate information and we suspect fraud, we will record this to prevent fraud and money laundering.
We can supply on request further details of the agencies and databases we access or contribute to and how this information may be used. If you require further details write to us at the correspondence address below or by sending us an email to info@mpfundmanagement.com.
We and other organisations may also search these agencies and databases to:
- help make decisions about the provision and administration of investment services;
- trace debtors or beneficiaries, recover debt, prevent fraud and to manage your investment;
- check your identity to prevent money laundering, unless you furnish us with other satisfactory proof of identity; or,
- check details of job applicants and employees.
Cookies
We may track and process information and data in relation to your use of our Website using "cookies". A cookie is a small file which is sent to your browser and stored on your computer’s hard disc and helps us understand and track your use of the Website and where we can improve the information and services provided.
We use cookies solely to gather information on IP addresses and pages visited, to analyse trends, administer the Website, track users’ movements on the Website and gather broad demographic information for aggregate use. For example, we may record your device information including hardware and software used, general location, when and how you interact with our Website and your registration and log-in activity when you use the Website and related online platforms. IP addresses are not linked to other personally identifiable information and will not be used to deliver targeted marketing messages.
We only share this information with the Company's officers, employees, and third-party contractors. When we use or share information from or with third-parties, we will respect any permissions that you have set about how you would like your information to be used.
Most internet browsers allow you to stop receiving cookies via options/settings. You may enable these options/settings. However, this will mean that our system may not recognise your computer when you log in and so you may not be able to use or access certain parts of the Website. For information about cookies generally, please visit www.allaboutcookies.org.
Links to Other Websites
This Website may contain links to other websites within the group and other third-party websites. This Privacy Policy extends only to this Website and does not cover your use of, provision of data to, and collection of data on any website not connected to us which you may link to by using hypertext links within the Website.
We recommend that you check the policy of each website that you visit and contact the owner or operator of that website if you have any concerns.
Changes to the Privacy Policy
We may edit or amend this Privacy Policy from time to time. If we make any substantial changes to this policy, we will notify you by using a prominent notice on the home page of the Website.
From time to time we may make improvements or changes to our services, or there may be amendments to laws or regulation or developments in the technology or processes we use. If we intend to make any significant changes to the use of your personal information in a manner different to that stated at the time of collection, we will notify you by posting a notice on our Website.
Updates to your Personal Information
Please let us know if there are any changes to your personal information as it is important that the information that we hold about you is accurate and up to date.
You can ask us to update or correct your personal information by writing to us at the correspondence address below or by sending us an email to info@mpfundmanagement.com.
How Long we Store Information About you
We will keep your personal information for as long as it is considered necessary, for the purpose for which it was collected, and to comply with our legal and regulatory requirements. This will involve keeping your information for a reasonable period of time after your relationship with us has ended.
How to Find out What Information we Hold About you
You have the right to request a copy of the personal information we hold about you free of charge in a ‘Subject Access Request.’ To do this, you may write to us at the correspondence address below or by sending us an email to info@mpfundmanagement.com.
Before providing any personal information to you that we hold about you we will take all reasonable steps to confirm your identity. We do this to protect your personal information and to ensure that it is only sent to the person to whom the information relates.
Managing your Preferences
From time to time, MPFM or third-parties who we think have products or services of interest to you may use your personal information to send you e‐mails, e‐mail newsletters, or news updates alerting you to new features, products, promotions, or services pertaining to the Website.
We will always give you the option to ‘opt‐out’ when you receive communications or other marketing materials from us and/or from such third-parties, you may opt-out of receiving these communications at any time by writing to us at the Company's correspondence address below or by emailing us your request to ‘unsubscribe’ at info@mpfundmanagement.com.
Questions and comments regarding this Privacy Policy are welcomed and should be addressed to info@mpfundmanagement.com.
Correspondence address:
6th Floor, Waters Edge, Building 1, Wickham’s Cay 1, Road Town, Tortola, British Virgen Islands
Disclaimer Date: 10th August 2022
Disclaimer Version Number: VNHF/WS/PP/V3