EUROPEAN GENERAL DATA PROTECTION REGULATION

In light of the new EU General Data Protection Regulation 2016/679 (“GDPR”), which will take effect on 25th May 2018, we set out below certain information about the data we process in order to communicate with you.

Commander Asset Management Limited (“Commander”), whose registered office is at 2 St Andrew’s Hill, London, EC4V 5BY, is the controller of your data which means that we are responsible for how your data are collected and used. We respect your privacy and will protect any of your personal data that we process. All personal data are processed in accordance with applicable data protection laws.

 

THE TYPES OF DATA WE COLLECT

We collect certain personal data about you. “Personal data” are data that can be used to identify you or that we can otherwise link to you using information we may already hold.

We collect personal data that you voluntarily provide to us, for example when you communicate with us via email or other channels. The data we collect includes your name, company name, company address, contact phone numbers, e-mail address and job title. We may monitor and/or record any communications between the firm and third parties including telephone calls and emails to ensure compliance with our legal and regulatory obligations, rules, and policies.

 

HOW WE USE THE DATA WE COLLECT AND STORE

We use the personal data we collect for communication purposes as requested by yourself, including:

• To send you information relating to our business;

• To send you invitations to events or meetings;

• To communicate with you as part of our contract (in the case of intermediaries and business suppliers);

• To maintain our list of business contacts.

We do not sell, hire out, distribute or otherwise make your personal data available to any third party. However, we may share information with our suppliers for the purposes listed below.

 

OUR BASIS FOR USING YOUR PERSONAL DATA

When processing personal data for the purposes explained in this notice, we do so for the purposes of delivering our contracted services to you or for maintaining our business relationship with you. In addition, where we may provide you with details of our other services which we believe may be of interest to you, we rely on our legitimate interests in maintaining business relationships and/or communicating with you as an existing client for similar services, about our service offerings. We consider that our legitimate interests abide by the law and the legal rights and freedoms of our client and business contacts.

 

INTERNATIONAL TRANSFER OF DATA

Commander currently does not transfer personal data outside of the European Economic Area (EEA). If Commander does transfer personal data outside of the EEA at any time in the future, any such transfers are made in accordance with the requirements of Articles 44 to 49 of the GDPR.

 

SECURITY MEASURES TO KEEP YOUR PERSONAL DATA SAFE

Commander acknowledges that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with its normal procedures and all applicable laws.

Only the people who need to process personal data for the purposes mentioned above have access to your personal data.

We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We regularly review our security policies and procedures to ensure our systems are secure and protected.

 

HOW LONG WE WILL KEEP YOUR PERSONAL DATA

Your personal data will be saved for the specified purposes mentioned above for as long as you are a business contact of ours and as required on a legal and regulatory basis. We will give you the opportunity to unsubscribe if you no longer wish to receive communications and invitations from us. If you choose to unsubscribe, we will cease to send you such communication and invitations as mentioned above.

 

YOUR CHOICES AND RIGHTS

We welcome your inquiries and comments. You have the right to know what personal data we process about you and may request a copy. You are also entitled to have incorrect personal data about you corrected and you may in some cases ask us to delete your personal data. You can also object to certain personal data about you being processed and request that processing of your personal data be limited. Please note that the limitation or deletion of your personal data may mean we will be unable to provide the communications and invitations described above.

 

CHANGES TO THIS PRIVACY NOTICE AND POLICIES

This Privacy Notice is dated 25 May 2018.

This Privacy Notice and our Policies may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post the updated version on our website and indicate when it was most recently updated.

 

CONTACT US

If you have any questions regarding this Privacy Notice or our Policies you can contact us via email james.rolfe@commanderfund.co.uk or in writing to Compliance, Commander Asset Management Limited, 2 St Andrew’s Hill, London, EC4V 5BY.

 

HOW TO COMPLAIN

If you are not satisfied in the way we have dealt with your concerns, you have the right to complain to the Information Commissioner’s Office. Please go to https://ico.org.uk/concerns/ to find out more or write to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Tel: 0303 123 1113.