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DELFF Management Limited (hereinafter referred to as “DELFF”, “we” or “us”) fully understands the importance of protecting your personal information and respecting your privacy when you visit our website www.delff.co.uk (« Website »).  This Privacy and Cookies Policy (the “Policy”) applies to any user of our Website. It defines treatment of personal information that DELFF collects when the user accesses to and uses the Website.

Please read the following carefully as it explains how we use and protect your personal data. You may contact us at contact@delff.co.uk if you have any questions about this Policy. We may amend it at any time without notice by updating this page. Other sites linking to or from this Website will have their own privacy policies and we are not responsible for the privacy practices of the relevant operators.

We will ensure that all information that you provide to us is treated in confidence and in accordance with our obligations under:

• the UK Data Protection Act 1998,
• from 25 May 2018, the EU General Data Protection Regulation (which replaces the Data Protection Act 1998),
• the Privacy and Electronic Communications (EC Directive) Regulations 2003.

We will not disclose such information to any third parties except (a) where required or permitted by law; or (b) where your consent has been received.

We may disclose your personal data to agents and service providers (within the European Economic Area) of DELFF for such purposes, or if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or in order to enforce or apply these terms and conditions or other agreements that may be in place with you, or to protect the rights of DELFF or its customers.

By using the Website, you consent to using your personal data in accordance with this Policy and you confirm that all data provided by you is accurate. DELFF reserves the right to change this Policy from time to time and you should therefore check the Website frequently to ensure that you are happy with any changes.

DELFF Management Limited, registered in the United Kingdom with registered office 37 Thurloe Street, London, SW7 2LQ, UK, company registration number 4432678;

Collection of Personal Information

By using the Website and providing any personal information, you consent to the collection and use of the data in accordance with this Privacy Policy. The personal information you provided us, may be retained by DELFF to keep track of user’s access to the Website, to better serve you, or to contact you either electronically or otherwise. DELFF does not intend to retain your personal information longer than is necessary for the purpose it was collected.

We may typically collect the following information about you when you engage with us through this Website or by contacting us via emails, telephone or by visiting.

• Your name and contact details, including email address, postal address, mobile and fixed line telephone numbers and your job title and CV where you apply for a role with us.
• Your job title, business contact details, the charitable body, private investor, corporate entity or other person or institution you represent for investment purposes and/or to whom you provide financial advisory services.
• Log in details and pin numbers and/or passwords as necessary to set up and administer registered user accounts. Where you make use of our Website we may also collect information about your use of the Website (e.g. your IP address and choice of web browser).
• Investment products and related services which are of interest to you.
• All personal information about you as may be contained in free text boxes, including in relation to enquiries or comments submitted to us through this Website.

Personal Information can be collected and processed for legal compliance and/or to analyse the use of our Website and services and support our clients and staff.

Purposes

We may typically use your personal information:

• for our internal business administration and record keeping purposes,
• to supply the investment services you have requested and correspond with you,
• to provide support to you in respect of these services,
• to respond to your enquiries or comments submitted through this Website.
• to improve our Website and services,
• to comply with legal and regulatory obligations, including as necessary to respond to governmental, regulatory or law enforcement agency requests; to ensure the continuing security and integrity of our systems, business dealings, reputation or the security and reputation of DELFF and its staff; to identify misuse of DELFF’s systems and any fraud or other illegal or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations.
• and where relevant, to process your application for employment.

Data disclosures and Data Sharing

DELFF does not disclose your personal information to third parties, except as described in this Policy. Your personal information may be shared as necessary with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to DELFF such as the funds’ administrators and our advisors. They may be retained to provide services in relation to administration; website hosting and management; data storage and back up; and such other services as may be relevant to our business. This includes disclosures to any person or company to whom we delegate responsibility for the administration, operation and/or maintenance of this Website. These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of such information to the extent they receive it, and to use your personal information only while providing such services and only for the purposes that DELFF dictates.

Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance:

• in response to a court order, request for cooperation from a law enforcement or other government agency; to establish or exercise legal rights; to bring or defend legal claims.
• to protect against fraud, other illegal or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations; to protect and defend the rights, property or safety of DELFF, its investors and clients, directors, employees, and/or service providers.
• to otherwise cooperate with law enforcement or regulatory authorities.

By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. You should know that DELFF does not sell your personal information.

Security Measures and Data Deletion

We will retain your personal information in accordance with applicable laws for so long as it is needed and, in any event, only for as long as the Data Protection Legislation allows.

Where you have chosen a password, which allows you to access certain parts of the Website, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

In accordance with our obligations under applicable data privacy law, we take all reasonable precautions to seek to keep your personal information secure, including precautions against unauthorised access or loss. Likewise, we seek to keep secure all confidential information you send to us. However, in common with all website operators, we cannot guarantee the security of any data transmitted by Internet email or through this Website.

Accessing and Updating your Personal Information

You have the right to access your personal information at any time to:

• check whether it is accurate and up-to-date or make any changes,
• erase or stop processing any Personal Information we hold about you where there is no longer a legal or regulatory ground for us to hold it; or
• transfer any information we hold about you to a specified third party.

If you change your mind about us using your Personal Information in the ways described in this Policy, please let us know by contacting us at contact@delff.co.uk.  You may also opt out of receiving marketing emails from us by following the instructions outlined in the relevant marketing emails.

This Statement applies to any information obtained by DELFF through your use of the Website, direct contact or use of services or products provided by DELFF. It is not applicable to any Internet websites controlled by third parties not affiliated with DELFF that the DELFF Website may link to (« Third Party Sites »).”

Complaints

Should you have any queries or complaints in relation to how we use your Personal Information, please contact us on contact@delff.co.uk. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office (or equivalent in the EU member state of your habitual residence, place of work or place of the alleged infringement) regarding such issues.

Cookies and Consent Collection

DELFF may use cookies, which are text files containing small amounts of information which are downloaded to your computer or other device from a web server when you visit a website. They are used to speed navigation, keep track of sessions and remember data. They help us to analyse how the Website is used and some improvements and updates to the Website services are based on such data collected by the cookies. By using our Website, you agree that we can place these types of cookies from us and third parties on your device.

A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Website and the Personal Information you choose to share with us (including Personal Information you automatically share with us by way of your browser settings).

We use the following cookies:

• Strictly necessary cookies

These cookies are essential in order to enable you to move around this Website and use its features, such as accessing secure areas such as the ‘My Account’ function. A session cookie is only stored on your computer’s hard drive for the duration of your visit (known as an ‘active session’), it is removed as soon as the active session has ended.

• Performance cookies

These cookies are used by web analytics and collect information in an anonymous form about how visitors use our website. They allow us to track site usage, page visits and monitor trends over time. The data collected is limited to managing the performance and design of this site. These cookies are third-party cookies (Google Analytics) but the information is in an anonymous form and is obtained for the exclusive use of DELFF. It is only used to improve how our Website works.

• Functionality cookies

These cookies allow us (and Investor Portal) to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. DELFF uses functional cookies to recognise you when you return to this Website, enabling us to personalise our content for you and remember your preferences. The information these cookies collect is anonymised and they cannot track your browsing activities on other websites.

• Sharing cookies

These cookies allow you to interact with third party services such as LinkedIn. You will normally see a message on our Website (or Investor Portal) before we store a cookie on your computer which describes the types of cookies we use and what information they might collect. We may also use banners and pop-ups from time to time to give you options around cookies use. You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings.

Classification of cookies

Cookies can be classified by duration and by source

Duration: This Website uses both session and persistent cookies:

• Session cookies– a cookie that is stored temporarily and is destroyed when you close the link, specifically by closing the browser and terminating the particular ‘active session’ you are on and during which you made your visit to this Website.
• Persistent tracker cookies– a cookie that enables a website to remember you on subsequent visits, speeding up or enhancing your experience of services or functions offered. These cookies are not deleted when you close your browser and they will remain on your computer or other device unless you choose to disable them.

Source

Cookies can be classified as first party or third-party cookies.

• First party cookies are those issued on behalf of the website visited, all other cookies are third party cookies. This website uses both first party and third party cookies.
• Other third-party cookies: this website has links to other third party websites, and the linking process may involve third party cookies being placed on your machine or other device.

If you wish to remove or block cookies set by this Website from your browser, you may not be able to access all or parts of our Website as its functionality could be impaired.

You can find more information about cookies generally on www.allaboutcookies.org. Please note that third party providers may also use cookies to assess the ways in which you make use of their websites and we have no control over these.

Emails

Our emails may contain a single, campaign-unique “web beacon pixel” to tell us whether our emails are opened and combined with other technology verify any clicks through to links within the email. We may use this information for purposes including determining which of our emails are more interesting to you and to query whether users who do not open our emails wish to continue receiving them. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should select to receive emails from us in plain text rather than HTML or choose not to click links that we send you or unsubscribe from the receipt of our emails. This information may be connected to your personal identity.

Monitoring and Interception of Communication

Emails and telephone calls, SMSs, communications sent through this Website and communications through third party instant messaging systems (as relevant), as between you and DELFF staff, may be monitored and, in specific circumstances, intercepted, for legal and regulatory compliance purposes; to address actual or potential HR disciplinary matters; to ensure the continuing security and integrity of DELFF’s systems, business dealings, reputation or the security and reputation of DELFF and its staff; and for all other purposes as may be required or permitted by applicable legal and regulatory obligations.

This website uses cookies to provide you with a better experience. By continuing to use this website you are agreeing to our Privacy and Cookies Policy, which includes details on how you can amend your preferences. This website is operated by DELFF Management Limited, which is authorised and regulated by the Financial Conduct Authority and registered in England and Wales (Company No. 4432678). Registered office: 37 Thurloe Street, London, SW7 2LQ, UK.

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