Privacy Policy

Updated: 23 November 2021

1. The Purpose of this Notice

This privacy notice describes how the personal data provided in respect of one or more of the Intriva Capital Management Limited (Jersey Registered) managed funds, that are constructed as Jersey private funds (the Funds), are used, stored, transferred or otherwise processed, and other matters relating to it. This may relate to you if you are an individual or to your individual representatives if you are a body corporate. This notice also contains information about rights in relation to personal data.

Any questions about the contents of this privacy notice or how personal data will be used, stored, or transferred, should be sent to via email to compliance@intriva.com or via post at Intriva Capital, 25 Maddox Street, London, W1FS 2QR.

2. Responsibility for personal data

This privacy notice is provided on behalf of Intriva Capital Management Limited as the investment manager of the Funds and each of their respective group and affiliated companies (together the Intriva Capital Entities).

Where we use the terms we, us and our in this privacy notice, we are referring to the Funds in which you invest and the Intriva Capital Entities.

When personal data is provided to us, the Funds (acting through their general partner) and certain Intriva Capital Entities will, in relation to some or all of the personal data, be acting as a “data controller”. The data controller determines how the personal data is used and for what purposes.

3. The data we collect

The types of personal data we collect, and share depends on the nature of the contract. The types of information which we may collect include:

1. Name, address and other contact information.
2. Information about your date of birth, place of birth, passport details or other national identifier, national insurance or social security number and information about your family.
3. Information regarding bank account details, assets, income, employment, source of funds, investment history and risk tolerance.

In order to provide services we collect information about you from a number of sources, including from you directly. Other sources from which we receive data include tax authorities, government and competent regulatory authorities to whom we have regulatory obligations, publicly available directories and sources, background check providers and credit, fraud and detection agencies and bankruptcy registers.

4. How we use personal data

We require personal information for several reasons, including:

1. For compliance with applicable legal or regulatory obligations to:

• Verify the identity and addresses of our investors, directors, employees and contractors and, if applicable, any beneficial owners and individual representatives.
• Undertake our due diligence and on-boarding checks.
• Carry out verification, know your customer, terrorist financing and anti-money-laundering checks and to ensure compliance with sanctions.
• Comply with requests from regulatory, governmental, tax and law enforcement authorities including, without limitation, with respect to compliance with the US Foreign Account Tax Compliance Act (“FATCA”) and the OECD common reporting standard (“CRS”) or any legislation, regulations or guidance enacted in any jurisdiction that seeks to implement a similar tax reporting or withholding tax regime.
• Undertake investigation, surveillance and audit checks and to prevent and detect fraud.
• Maintain statutory registers.

1. In order to perform our contract with investors so that we can:

• Establish, administer and manage investments.
• Meet our contractual obligations.
• Facilitate the relationship between them and the Funds.

1. For our legitimate interests or for those of a third party to enable us to:

• Administer and manage investments in the Funds including corresponding with investors in connection with investments.
• Review, analyse and process requests or applications
• Address or investigate any complaints, claims, proceedings or disputes and to seek professional advice, including legal advice.
• Meeting our obligations and requirements including regulatory, accounting, tax reporting and audit.
• Ensure appropriate management and governance, management of risk and operations (including protecting our business against fraud and other risks) and to maintain our internal records and act in accordance with our policies and procedures.

In limited circumstances, Intriva Capital Management Limited or Intriva Capital Entities may approach the relevant individual for written consent to allow us to process certain particularly sensitive data, known as special category data. If we do so, we will provide the individual with full details of the information that we would like and the reason we need it, so that the individual can carefully consider whether to give consent.

5. Consequences of not providing personal data

We require personal information in respect of the Funds to be able to comply with our legal and regulatory obligations and to operate the relevant Fund. Accordingly, if personal data required is not provided, an investor or prospective investor may not be able to invest in a Fund and we may not be able to manage your investment.

6. Disclosure to third parties

In relation to personal data processed in connection with a Fund, each Fund’s structure involves legal entities affiliated with Intriva Capital Management Limited to allow it to operate and fulfil its aims. Affiliated entities to which personal data may be transferred include:

• Investment managers and advisers and Intriva Capital Entities in order that we can manage our relationship with you.
• Administrators and depositories in connection with the management of investments, the administration of investment related activities and to enable compliance with applicable laws and regulations.
• Tax authorities to comply with applicable laws and regulations or where requested by such tax authority (including authorities outside of the European Economic Area (EEA)).
• Service providers and our professional advisers to facilitate investments, provide investment related services and to provide us with legal advice in relation to the Funds and investments.
• There may also be circumstances where Intriva Capital Management Limited is obliged by law to disclose personal data, including to law enforcement agencies and applicable regulators.

7. Location of personal data

It may be necessary for Intriva Capital Management Limited, Intriva Capital Entities or associated third parties to effect cross-border transfers of personal data, including to the United States of America and to countries outside the EEA. In some cases, personal data may be transferred to jurisdictions outside of Jersey and the EEA that are not deemed to have data protection frameworks that are equivalent to those of the EEA. Such transfers may be to other Intriva Capital Entities, to governmental, regulatory or judicial authorities, auditors, legal advisors or agents as well as to sub-contractors engaged by Intriva Capital Management Limited. In these situations we will seek to put appropriate safeguards in place to maintain the security of your data. Please contact us if you would like to know more about these arrangements.

8. Retention of your data

Intriva Capital Management Limited and those third parties to whom personal data is transferred will retain that data as long as is necessary for the purposes set out above. In particular, Intriva Capital Management Limited will hold certain personal data and other information regarding investors in the Funds for at least as long as they remain investors. The retention period may extend beyond the investment term where necessary for the Funds’ legitimate interests, including to comply with legal or regulatory obligations or to facilitate the relevant Funds’ on-going administration and performance.

9. Individual rights

Individuals whose personal data is processed by us have certain legal rights in respect of the information. These include:

• The right to request access to personal data.
• The right to obtain information about the use of personal data.
• The right to require rectification (correction) of errors in personal data without undue delay.
• The right to have personal data erased without undue delay in certain circumstances.
• The right to restrict the processing of personal data in certain situations.
• The right to receive personal data in a structured, commonly used and machine-readable format and transmit that data to a third party.

If an individual wishes to exercise any of these rights and Intriva Capital Management Limited has transferred that person’s data to a third party, Intriva Capital Management Limited or Intriva Capital Entities will communicate that request to the relevant third party unless it would be impossible or involve disproportionate effort for Intriva Capital Management Limited to do so.

10. Right to withdraw consent

In the limited circumstances where the individual may have provided their consent to the collection, processing and transfer of personal information for a specific purpose, the individual has the right to withdraw consent for that specific processing at any time.

To withdraw consent, please contact Dean Walsh at compliance@intriva.com. Once we have received notification that the individual has withdrawn consent, we will no longer process information for the purpose or purposes that the individual originally agreed to, unless we have another legitimate basis for doing so in law.

11. Updates

This notice is under regular review and may be updated periodically and without prior notice to reflect changes in Intriva Capital Management Limited’s personal information practices.

12. Concerns or Queries

Any questions about the contents of this notice or Intriva Capital Management Limited’s use of personal data should be addressed to Dean Walsh via email at compliance@intriva.com or via post at Intriva Capital, 25 Maddox Street, London, W1S 2QR.

Issues or concerns individuals have regarding their personal data can also be brought to the attention of the applicable supervisory authority in your country, where you live or work, or the location where the data protection issue arose.

Use of cookies on Our website

What is a cookie?

Cookies are small data files that many internet sites automatically download to a user’s computer, phone or tablet’s hard disk. They are primarily used to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of a website, improve the functionality of a website and to compile statistical reports on website activity.

What cookies will this website use and for what purpose?

This website uses cookies to store information on your computer phone and/or tablet. By storing information such as location and web pages visited, Intriva Capital Management Limited or Intriva Capital Entities (“we”, “us”, “our”) can improve your browsing experience and the quality of the services we provide you. These cookies are set when you submit a form or interact with this website by doing something that goes beyond clicking on simple links. We also use some non-essential cookies to anonymously track visitors or enhance your experience of this website. The cookies that this website uses include:

• Single session cookies. These enable this website to keep track of your movement from page to page in order to ensure that you will not be asked for the same information you have previously given during your visit to this website. These cookies allow you to proceed through this website quickly and easily without having to authenticate or reprocess each new area you visit. We may use such cookies to analyse user behaviour, such as which pages have been visited during the session, in order to improve your overall experience, for example by enabling us to determine and display more relevant content.
• Persistent cookies. These cookies enable us to collect information such as the number of visitors to this website and the pages visited (in aggregate) in order to analyse user behaviour. This information is collected in an anonymous form and will be collated with similar information received from other users to enable us to compile reports in order to develop and improve user experience by displaying more tailored and relevant content.

Information tracking

We may use third party technology,  to provide us with information about how you use this website. This may include the use of cookies to collect anonymous information, including the number of visitors to this website, where they have come to this website from, the pages they visit and the length of time they have spent on this website. We may use this information to compile statistics and to help us to improve our website and the services we offer.

This data is collected primarily for monitoring the usage and performance of our website. We may use your IP address and track browser types to build a profile of our users.

Further information about cookies

For further information about cookies, visit www.aboutcookies.org or www.youronlinechoices.eu.
You can set your web browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, some of our website features may not function as a result. The way in which you adjust your browser security setting varies from browser to browser.