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.

 

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.