Updated: 30 October 2018
1. The Purpose of this Notice
This privacy notice describes how the personal data provided in respect of one or more of the Signal Capital Partners Limited Funds known as Signal Real Estate Opportunities Fund L.P and Signal Credit Opportunities Fund L.P (the Funds) are used, stored, transferred or otherwise processed, and other matters relating to it. This may relate to you if you are an individual or to your individual representatives if you are a body corporate. This notice also contains information about rights in relation to personal data.
Hannah Price (COO and General Counsel) is responsible for overseeing compliance with this privacy notice. Any questions about the contents of this privacy notice or how personal data will be used, stored, or transferred, should be sent to Hannah Price via email at Hannah.email@example.com or post at Signal Capital Partners Limited, 5th Floor, 10 Old Burlington Street, London, W1S 3AG.
2. Responsibility for personal data
This privacy notice is provided on behalf of: Signal Capital Partners Limited as the investment manager of Signal Credit Opportunities Fund L.P and as the investment adviser of Signal Real Estate Opportunities Fund L. and each of their respective group companies (together the Signal Capital Entities).
Where we use the terms we, us and our in this privacy notice, we are referring to the Funds in which you invest and the Signal Capital Entities.
When personal data is provided to us, the Funds (acting through their general partner) and certain Signal Capital Entities will, in relation to some or all of the personal data, be acting as a "data controller". The data controller determines how the personal data is used and for what purposes.
3. The data we COLLECT
The types of personal data we collect, and share depends on the nature of the contract. The types of information which we may collect include:
(a) Name, address and other contact information.
(b) Information about your date of birth, place of birth, passport details or other national identifier, national insurance or social security number and information about your family.
(c) Information regarding bank account details, assets, income, employment, source of funds, investment history and risk tolerance.
In order to provide services we collect information about you from a number of sources, including from you directly. Other sources from which we receive data include tax authorities, government and competent regulatory authorities to whom we have regulatory obligations, publicly available directories and sources, background check providers and credit, fraud and detection agencies and bankruptcy registers.
4. How we Use personal data
We require personal information for several reasons, including:
(a) For compliance with applicable legal or regulatory obligations to:
(b) In order to perform our contract with investors so that we can:
(c) For our legitimate interests or for those of a third party to enable us to:
In limited circumstances, Signal Capital Partners Limited may approach the relevant individual for written consent to allow us to process certain particularly sensitive data, known as special category data. If we do so, we will provide the individual with full details of the information that we would like and the reason we need it, so that the individual can carefully consider whether to give consent.
5. Consequences of not providing personal data
We require personal information in respect of the Funds to be able to comply with our legal and regulatory obligations and to operate the relevant Fund. Accordingly, if personal data required is not provided, an investor or prospective investor may not be able to invest in a Fund and we may not be able to manage your investment.
6. Disclosure to third parties
In relation to personal data processed in connection with a Fund, each Fund’s structure involves legal entities affiliated with Signal Capital Partners Limited to allow it to operate and fulfil its aims. Affiliated entities to which personal data may be transferred include:
Investment managers and advisers and Signal Capital Entities in order that we can manage our relationship with you.
Administrators and depositories in connection with the management of investments, the administration of investment related activities and to enable compliance with applicable laws and regulations.
Tax authorities to comply with applicable laws and regulations or where requested by such tax authority (including authorities outside of the European Economic Area (EEA)).
Service providers and our professional advisers to facilitate investments, provide investment related services and to provide us with legal advice in relation to the Funds and investments.
There may also be circumstances where Signal Capital Partners Limited is obliged by law to disclose personal data, including to law enforcement agencies and applicable regulators.
7. Location of personal data
It may be necessary for Signal Capital Partners Limited or associated third parties to effect cross-border transfers of personal data, including to the United States of America and]to countries outside the EEA. In some cases, personal data may be transferred to jurisdictions outside of Jersey and the EEA that are not deemed to have data protection frameworks that are equivalent to those of the EEA. Such transfers may be to other Signal Capital entities, to governmental, regulatory or judicial authorities, auditors, legal advisors or agents as well as to sub-contractors engaged by Signal Capital Partners Limited. In these situations we will seek to put appropriate safeguards in place to maintain the security of your data. Please contact us if you would like to know more about these arrangements.
8. Retention of your data
Signal Capital Partners Limited and those third parties to whom personal data is transferred will retain that data as long as is necessary for the purposes set out above. In particular, Signal Capital Partners Limited will hold certain personal data and other information regarding investors in Funds for at least as long as they remain investors. The retention period may extend beyond the investment term where necessary for the Funds’ legitimate interests, including to comply with legal or regulatory obligations or to facilitate the relevant Funds’ on-going administration and performance.
9. Individual rights
Individuals whose personal data is processed by us have certain legal rights in respect of the information. These include:
If an individual wishes to exercise any of these rights and Signal Capital Partners Limited has transferred that person’s data to a third party, Signal Capital Partners Limited will communicate that request to the relevant third party unless it would be impossible or involve disproportionate effort for Signal Capital Partners Limited to do so.
10. Right to withdraw consent
In the limited circumstances where the individual may have provided their consent to the collection, processing and transfer of personal information for a specific purpose, the individual has the right to withdraw consent for that specific processing at any time.
To withdraw consent, please contact Hannah Price. Once we have received notification that the individual has withdrawn consent, we will no longer process information for the purpose or purposes that the individual originally agreed to, unless we have another legitimate basis for doing so in law.
This notice is under regular review and may be updated periodically and without prior notice to reflect changes in Signal Capital Partners Limited's personal information practices.
12. Concerns or Queries
Any questions about the contents of this notice or Signal Capital Partners Limited’s use of personal data should be addressed to Hannah Price via email at Hannah.firstname.lastname@example.org or post at Signal Capital Partners Limited, 5th Floor, 10 Old Burlington Street, London, W1S 3AG.
Issues or concerns individuals have regarding their personal data can also be brought to the attention of the applicable supervisory authority in your country, where you live or work, or the location where the data protection issue arose.
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