Pursuant to the General Data Protection Regulation ("GDPR") that comes into effect on 25th May 2018,
please find below a copy of Algebris (UK) Limited’s ("Algebris" or "we" or "us" or "our") Privacy Notice (the
"Notice") to inform you how we hold your data and what we use it for in connection with the provision of
discretionary investment management services.
Algebris is committed to protecting and respecting your private data.
This Notice sets out the basis upon which any personal data that Algebris collects from you, or that you provide to Algebris, will be processed by us.
“Our Group” means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies.
We are an investment management firm authorised and regulated by the Financial Conduct Authority. We act as the discretionary investment manager to a number of collective investment schemes and a number of managed accounts.
We collect personal data of the following types of people to enable us to undertake our discretionary investment management activities:
We collect information about you in order to carry out our core business and ancillary activities.
This is information about you that you give to us in connection with the provision of our investment management services and/or by corresponding with us by phone, email, in writing or otherwise.
It includes information that you provide to us when you enquire about or invest in a collective investment scheme for which we act as investment manager, subscribe to our mailing lists and/or attend events or meetings organised by us. It includes information that you provide to us when you appoint us as the investment manager of your managed account.
The information that you provide to us, or that we collect from you, may include your name, address, date of birth, private and/or corporate email address, private and/or corporate telephone number, specific and general financial information, sensitive documentation and other data which relates to your background, circumstances, investment experience, and information pertaining to your employment including obtaining information from public registers with governmental and/or quasi-governmental organisations (e.g. the Financial Conduct Authority), copies of identification documents such as a passport or driving licence, photographs, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, and/or a corporate website.
We use information held about you in the following ways:
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below within section 4, although we will also in certain circumstances rely on contract, legal obligation and consent for specific uses of data.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal and/or regulatory obligations.
Our legitimate interests in collecting and retaining your personal data is described within this section 4.
As an investment management firm we provide discretionary investment management services to a number of collective investment schemes and a number of managed accounts. In this capacity, the exchange of personal data between: us; you; the collective investment schemes or managed accounts (for which we act as investment manager); certain third parties (appointed to provide ancillary services directly related to the provision of our discretionary investment management activities); and global governmental and quasi-governmental agencies is a fundamental and essential part of our business.
In order to support those collective investment schemes and managed accounts for which we act as investment manager, we maintain databases of personal data of investors or prospective investors in such collective investor schemes and managed accounts which contain both current and historical information of the kind described within section 2 above.
In order to maintain, expand and develop our business we must record the personal data of investors and prospective investors in the collective investment schemes that we manage.
We may disclose information about you to our affiliates or third parties, including the administrator, the prime brokers and the custodians of the collective investment schemes and/or managed accounts that are managed by Algebris, for our everyday business purposes, such as to facilitate transactions, maintain your account(s) or respond to court orders and legal investigations. It may also be necessary, under anti-money laundering and similar laws, to disclose information about the investors in order to accept subscriptions from them or to facilitate the establishment of trading relationships with executing brokers or other trading counterparties. We will also release information about you if you direct us to do so.
We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us as described in this privacy notice. We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes. If you are a new investor, we may share your information with affiliates in accordance with this privacy notice. When you are no longer our investor, we may continue to share your information as described in this privacy notice.
We do not share your information with non-affiliates for them to market to you.
In addition to the above, we may also disclose your personal information to third parties in the following circumstances:
The lawful basis for the third party processing will include:
The data that we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA to enable us to provide our discretionary investment management services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, amongst other things, the provision of discretionary investment management services. By submitting your personal data, you agree to this transfer, storing and/or processing. Algebris will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention policy and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
The GDPR provides you with the following rights:
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Act/GDPR.
A subject access request should be submitted to firstname.lastname@example.org.
Any changes we make to our privacy notice in the future will be posted on our website and, where appropriate, notified to you by email. We would encourage you to periodically review our privacy notice to ensure that you continue to be aware of your rights.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to email@example.com.
For the purposes of data protection legislation in force from time to time the data controller is Algebris (UK) Limited, 4th Floor, 1 St. James Market, London, SW1Y 4AH.
Our nominated representative is Mr. Philip Walsh.