Privacy Policy

Updated: May 2024

1. The Purpose of this Notice

This privacy notice is provided by Signal Capital Partners Limited (“we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information used, stored, transferred or otherwise processed, and other matters relating to it in the context of the funds to which we provide investment management or advisory services (together, the “Funds”). 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.

Our compliance officer 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 compliance@signalcapital.com or post at Signal Capital Partners Limited, 4th Floor, 25 Golden Square, London W1F 9LU.

2. Responsibility for personal data

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:

Verify the identity and addresses of our investors, directors, employees and contractors and, if applicable, any beneficial owners and individual representatives.
Undertake our due diligence and on-boarding checks.
Carry out verification, know your customer, terrorist financing and anti-money-laundering checks and to ensure compliance with sanctions.
Comply with requests from regulatory, governmental, tax and law enforcement authorities [including, without limitation, with respect to compliance with the US Foreign Account Tax Compliance Act (“FATCA”) and the OECD common reporting standard (“CRS”) or any legislation, regulations or guidance enacted in any jurisdiction that seeks to implement a similar tax reporting or withholding tax regime].
Undertake investigation, surveillance and audit checks and to prevent and detect fraud.
Maintain statutory registers.

(b) In order to perform our contract with investors so that we can:

Establish, administer and manage investments.
Meet our contractual obligations.
Facilitate the relationship between them and the Fund.

Administer and manage investments in the Fund including corresponding with investors in connection with investments.
Review, analyse and process requests or applications.
Address or investigate any complaints, claims, proceedings or disputes and to seek professional advice, including legal advice.
Meeting our obligations and requirements including regulatory, accounting, tax reporting and audit.
Ensure appropriate management and governance, management of risk and operations (including protecting our business against fraud and other risks) and to maintain our internal records and act in accordance with our policies and procedures.
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

As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications

We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us. A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

6. Disclosure to third parties

We may, to the extent necessary to the purpose for which we collect your personal information, disclose your personal data with third parties, including:

investment managers and advisers and other entities within Signal Capital’s group to enable us to manage our relationship with you;
any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies including tax authorities (including those located outside of the EEA);
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;
service providers, trading counterparties to our clients, professional advisers, placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate service providers, and other providers to facilitate investments, provide investment related services and to provide us with advice in relation to the Funds and investments;
internet, IT, telecommunications and other service providers, including accountants, payroll administrators, HR services, insurance and employee benefits providers and administrators;
credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence; or
any person, as directed by you or agreed with you in writing.

7. Location of personal data

Due to the international nature of our business, it may be necessary for Signal Capital Partners Limited or associated third parties to transfer your personal data to countries outside of the EEA, including to the United States of America. 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 take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.

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 for which the information was collected or any longer period as required by law or for our legitimate interest. 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 (as such period represents the duration of our business relationship with you). As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.

9. Individual rights

Individuals whose personal data is processed by us have certain legal rights in respect of the information. These include:

The right to request access to personal data.
The right to obtain information about the use of personal data.
The right to require rectification (correction) of errors in personal data without undue delay.
The right to have personal data erased without undue delay in certain circumstances (known as a “right to be forgotten”).
The right to restrict the processing of personal data in certain situations.
The right to object to our use of your information such as where we have considered such use to be necessary for our legitimate interests.
The right to receive personal data in a structured, commonly used and machine-readable format and transmit that data to a third party.
The right to request the portability of your personal data.
The right, where you have given consent to processing of your personal data, to withdraw such consent.
The right to lodge a complaint with a competent supervisory authority.

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. Updates

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.

11. 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 the firm’s Compliance Officer via email at compliance@signalcapital.com or post at Signal Capital Partners Limited, 4^th Floor, 25 Golden Square, London W1F 9LU.

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. You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO's website.

Use of cookies on Our website[1]

What is a cookie?

Cookies are small data files that many internet sites automatically download to a user’s computer, phone or tablet’s hard disk. They are primarily used to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of a website, improve the functionality of a website and to compile statistical reports on website activity.

What cookies will this website use and for what purpose?

This website uses cookies to store information on your computer phone and/or tablet. By storing information such as location and web pages visited, Signal Capital Partners Limited ("we", "us", "our") can improve your browsing experience and the quality of the services we provide you. These cookies are set when you submit a form or interact with this website by doing something that goes beyond clicking on simple links. We also use some non-essential cookies to anonymously track visitors or enhance your experience of this website. The cookies that this website uses include:

Single session cookies. These enable this website to keep track of your movement from page to page in order to ensure that you will not be asked for the same information you have previously given during your visit to this website. These cookies allow you to proceed through this website quickly and easily without having to authenticate or reprocess each new area you visit. We may use such cookies to analyse user behaviour, such as which pages have been visited during the session, in order to improve your overall experience, for example by enabling us to determine and display more relevant content.

Persistent cookies. These cookies enable us to collect information such as the number of visitors to this website and the pages visited (in aggregate) in order to analyse user behaviour. This information is collected in an anonymous form and will be collated with similar information received from other users to enable us to compile reports in order to develop and improve user experience by displaying more tailored and relevant content.

Information tracking

We may use third party technology, such as Google Analytics, to provide us with information about how you use this website. This may include the use of cookies to collect anonymous information, including the number of visitors to this website, where they have come to this website from, the pages they visit and the length of time they have spent on this website. We may use this information to compile statistics and to help us to improve our website and the services we offer. Google’s privacy policy is available at http://www.google.com/policies/privacy.

This data is collected primarily for monitoring the usage and performance of our website. We may use your IP address and track browser types to build a profile of our users.

Further information about cookies

For further information about cookies, visit www.aboutcookies.org or www.youronlinechoices.eu. You can set your web browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, some of our website features may not function as a result. The way in which you adjust your browser security setting varies from browser to browser.

Privacy Policy

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