Private Equity - Real Assets - Managed Account Platform - Funds of Hedge Funds

SCIENS GROUP DATA PROTECTION AND PRIVACY POLICY (“Policy”)

Privacy Commitment

All personal data which can identify you as an individual will be handled and processed with due care and consideration as you may expect, and in accordance with the following Laws: Data Protection (Bailiwick of Guernsey) Law, 2017; Data Protection Act 2018 (UK), General Data Protection Regulation (EU) 2016/679; the Privacy and Electronic Communications (EC Directive) Regulations 2003 and The Data Protection Law, 2017 (Cayman Islands) (Effective September 2019).

We take your privacy and cyber security seriously. We do not sell on your data nor share beyond what is required under law or for a valid legal reason. This Policy will explain the purposes of processing your personal data, the information we may collect and the rights you have and how to exercise them.

Data Controllers and Registration Details

Sigma Asset Management (Guernsey) Limited
Registration No: 11006 Office of the Data Protection Authority, Guernsey
Suite 5, Windsor House (f.k.a. Pollet House), Lower Pollet, St. Peter Port, Guernsey, GY1 1WF

Sciens Capital Limited
Registration No: Z5797943 Information Commissioner’s Office, UK
6 Arlington Street, London, SW1A 1RE, UK

Sciens Group Risk Services Limited
Registration No: ZA208127 Information Commissioner’s Office, UK
6 Arlington Street, London, SW1A 1RE, UK

Sciens Group

This Policy belongs to the “Sciens Group” which contains at least the following companies Sciens Capital Limited, Sciens Group Risk Services Limited, Sigma Asset Management (Guernsey) Limited, Sciens Investment Management LLC, Sciens CFO I Management Ltd., Sciens Offshore Management Ltd., and other such companies where this applies.

Contact Sciens Group

You may contact the Sciens Group regarding your personal data at any time using the following email address: GDPR@sciensam.com. Where you wish to complain, we would prefer if you contact us first, but you may address any complaint to the relevant authority as listed above.

Reasons for Processing Personal Data

The business of the Sciens Group is investment management and all the personal data we process is in accordance with our legal and contractual obligations necessary for the Sciens Group business. We also use information gathered from https://www.sciensam.com (the “website”) to administer, diagnose, improve our services and to correspond with you. All information gathered may be used for our own internal business purposes such as business development and promotion, as well as to protect our business from; financial crime, cyber threats, breaches of confidentiality and theft of our proprietary information.

Personal information received outside of our usual business activities contained in CVs, business plans and service provider enquiries, is considered voluntary and this information is processed purely in that relevant context. Marketing and promotion are also voluntary.

Information that is Gathered

Sciens Group will gather your IP address, browser type and activity such as, time accessed, and time spent. This data may be used to determine demographic and geographic information. Much of this data will be gathered through cookies, a small text file stored on your computer or device that accessed the website.

Personal information is also gathered through the usual course of a relationship or enquiry; from emails, telephone calls and other forms of correspondence, as well as from legal documentation such as application forms. Your personal information may also come to us from third parties such as fund administrators, as part of the course of Sciens Group’s business activities.

What We Do with Personal Data

All personal data is private and securely stored. We also have a data retention policy which is to ensure all personal information is deleted or individuals can no longer be identified after its purpose or legal requirement to maintain it has passed.

Personal data is also shared within the Sciens Group under the purposes it is required to be processed. Data is shared with our contractual third-party administrators, suppliers and custodians as necessary for the performance of our business. Personal data may also be shared with the relevant competent authorities for the following purposes: tax information exchange, regulatory, anti-money laundering and countering terrorist financing, prosecuting, litigation and any required legal disclosure.

International Transfer of Personal Data

Data which is required to be shared and is transferred outside of the EU or a GDPR equivalent jurisdiction are safeguarded to ensure the standards of data protection are maintained. The Sciens Group has harmonised policies and procedures with respect to data protection, contractual arrangements are in place between third parties outside of a GDPR equivalent jurisdictions and we confirm our administrators have similar contractual arrangements in place. Sciens Group will, unless
otherwise restricted, allow personal information to be shared to fulfil our legal and contractual obligations.

Access to your Personal Information and Rights

You are allowed to request the data we hold about you and ask Sciens Group to; correct or amend data we hold on you, stop or restrict processing of personal data where there is no legal basis nor purpose to continue to do so, and erase data we hold on you where there are no legal grounds for us to retain. Where processing is voluntary, you are free at any time to withdraw consent to stop the processing of your personal data.

To make any of those requests, please email and specify clearly what you want achieved. Whether you make such access requests personally, via a third party and onwards to a third party, we will have to undertake necessary verification checks to ensure it is a legitimate instruction. There are no costs for such requests unless it is a burdensome task.

Cookies

By using this website, you consent to the use of cookies in accordance with this Policy. You will have seen a pop up to this effect on your first visit to the website; it will not usually appear on subsequent visits but you may withdraw your consent at any time by disabling them by following the instructions set out for your browser here. Some services will not function correctly if cookies are disabled.

Cookies are widely used in order to make websites work efficiently and securely, and to provide information on visitor behaviour to the website owner.
Session cookies are deleted automatically when you close your browser, while persistent cookies remain on your device after the browser is closed (for example to remember your user preferences when you return to the site).

Cookies we use are:

Cookie Name Source Purpose
ASP.NET_SessionId Sciens This session cookie implements a Microsoft technology which is essential for the operation of our websites. It assigns an identification number to each visitor so they can navigate the site correctly.
.AspNet.ApplicationCookie Sciens Forms authentication cookie – this is required for logon functionality on the website.
_sm_au_c Google Analytics These cookies are used to collect information about how visitors use the website. Sciens uses the information to compile reports and to help us improve our site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.