This Privacy Notice applies to personal data collected on our websites https://henriotgroup.com/ and https://gammadeltafund.com/ (“Websites”). This Privacy Notice sets out the categories of personal data we collect from you, how we collect it, what we use it for and with whom we share it in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”). For the purposes of this Privacy Notice, “Henriot”, “we”, “us”, and “our” means Henriot Investment Management Ltd.

By “personal data” we mean any information relating to you such as your name, contact details, taxpayer identification number, account number, account balance and transaction information or online identifiers such as your IP address. Personal data does not include data where you can no longer be identified from it such as anonymized aggregate data. If you have any questions about this Privacy Notice or how we handle your personal data, please contact us at support@henriotgroup.com. This Privacy Notice applies to personal data about you that we collect, use and otherwise process in connection with your relationship with us as a user of the Websites. We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. Those supplemental notices should be read together with this Privacy Notice.

How do we collect your personal data?

We may collect personal data about you:

 

• When you submit your information on our Websites through our collection forms

• ​When you request literature or research information from us

• When you visit our Websites

• When you attend our webinar presentations

• When you attend other Henriot-hosted events

• When we send you emails

We may also automatically collect certain data when you interact with our Websites, such as technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

 

 What if you do not provide the personal data we request?

If you do not provide us with certain personal data when requested, we may not be able to provide you with the services or products you have requested.

Change of purpose
We will only use your personal data for the purposes for which we collected it (as identified above in the What we use this personal data for column), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose for which you provided it to us. If we need to use your personal data for a purpose that is unrelated to the original purpose for which you provided it to us, we will notify you and we will explain the legal basis which allows us to do so.

How long will we retain your personal data?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.In some circumstances, we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
 

Once we no longer require your personal data for the purposes we collected it for, we will securely destroy your personal data in accordance with applicable laws and regulations.

Accuracy of personal data
It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.

Your rights in relation to your personal data
You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:

• Request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;

• Request rectification of your personal data;

• Request the erasure of your personal data;

• Request the restriction of processing of your personal data;

• Object to the processing of your personal data;

• Request the transfer of your personal data to another party.

If you want to exercise any of these rights please contact us at support@henriotgroup.com

Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our Websites and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

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