Data Protection Privacy Notice

In accordance with applicable data protection laws, including the European Union's General Data Protection Regulation ((EU) 2016/679) ("GDPR") and the retained EU law version of GDPR, as supplemented by the Data Protection Act 2018 ("UK GDPR"), GSA hereby provides you with the following Privacy Notice, which describes how we collect and use personal information about you.

In this Privacy Notice:

  • "GSA", "us" and "we" means each of GSA Capital Partners LLP, GSA Capital Services Limited, GSA Switzerland AG, Global Statistical Arbitrage Pty Ltd, GSA Guernsey Limited, GSA Capital Partners (New York) LP, GSA Capital Partners (USA) LP, each series within that LP, GSA PEV LP and GSA NYGP Ltd. GSA's contact address is Stratton House, 5 Stratton Street, London W1J 8LA.
  • "You" means the individual whose personal information is held and used by GSA.
  • "Personal information" or "personal data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

This Privacy Notice applies to all external parties who may provide GSA with their personal data, or the personal data of those individuals who represent them in the course of their interactions with GSA including contractors and service suppliers to GSA, GSA's clients, trading counterparties, investors and potential investors, and recruitment candidates. This Privacy Notice does not apply to GSA staff.

Reasons for collecting and processing your information

Depending on the nature of your relationship with GSA, GSA may rely upon one of the following grounds as the legal basis for collecting and processing your information:

  • Compliance with law or regulation - we may need to collect and process your personal data in order to comply with laws or regulations applicable to us;
  • Performance of a contract - we may need to collect and process your personal data in order to enter into a contract with you and perform our obligations thereunder;
  • Legitimate interests - we may need to collect and process your personal data for the purposes of our legitimate interests, including but not limited to:
    • providing investment management services to our funds and managed account clients, including the execution and facilitation of trading in financial instruments;
    • providing you with information, opportunities, services and/or products which you request from GSA or which GSA considers may interest you, and to determine your suitability to receive such materials from GSA;
    • facilitating communication with you and your staff, including servicing our relationship with you effectively; and
    • making decisions regarding the creation, maintenance and/or termination of a relationship with you, including a contractual, employment or professional services relationship; and
  • Consent - in some cases, we may require your consent to collect and process your personal data. In such cases, you can withdraw your consent by contacting us.

Some of the above grounds for use will overlap. If you fail to provide certain information when requested, or we fail to use your personal information for these purposes, GSA may not be able to perform, administer or otherwise commit to any relationship with you, including any contractual relationship, and we, or our funds and managed accounts, may no longer be able to do business with you.

We will only use your personal data in compliance with all applicable laws, and where our legitimate interests do not override your fundamental rights. We will only use your personal information for the purposes for which we collected it, unless we need to use it for another reason compatible with its original purpose of collection. We may process your personal information without your knowledge or consent where such usage is required or permitted by law.

Personal information we collect about you, how we collect and store it, and how long we will use it

We collect your personal information either directly from you or from a third party who refers us to you. We may also collect personal information from third parties including credit reference, background check and recruitment agencies and we may collect data by other automated means, such as through cookies or other commonly used technologies when you visit our website. Depending on the nature of our relationship with you, we may collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and email addresses (professional and/or personal).
  • Details concerning your current employment or workplace, including your CV, your professional history, your regulatory status, your investment history and experience, your educational, employment and residency qualifications.
  • Financial information such as your payment information, tax residency and source of funds.
  • Personal details concerning you, including your date of birth, your gender, your marital status, dependants, next of kin and emergency contact details.
  • CCTV footage in the event that you visit our offices.
  • Information about your use of our investor portal and/or managed account portal.
  • Identifying information, such as copies of your passport, driving licence or your electronic signature.
  • Publicly available personal information concerning you.

We will retain your personal information for as long as necessary to fulfil the purposes we have collected it for, including for the purposes of satisfying any legal requirements. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm to you from its unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

GSA is committed to protecting the privacy and security of your personal information. We safeguard your data through a series of electronic, physical and procedural controls, which restricts access to your personal information to those staff and third parties who need access to your information. In some circumstances we may anonymise your personal information so that it can no longer be associated with you. Given the laws and regulations applicable to GSA's business and the complex contractual arrangements that GSA's business has developed, we anticipate holding your personal data on an ongoing basis. Information held by GSA will also be archived over time and held securely at both GSA and third party locations.

We use third-party web analytics services on our website (including Google Analytics Demographics and Interest Reporting). Where we collect information such as usage data (e.g. how long you stay on the site), this is used to help us analyse the use of the website and to improve it. For further information on how Google processes the data, please visithttps://www.google.com/policies/privacy/partners/ (or any other URL that Google may provide).

If you want further information on Google Analytics, including how to opt-out, control and/or delete cookies, please visit: https://analytics.google.com/ and https://tools.google.com/dlpage/gaoptout.

Sharing your personal data with third parties

We will share your personal information with third parties where required by law, or to facilitate our legitimate interests explained above. "Third parties" includes service providers who carry out payment services and custodial work, perform background checking, AML & KYC checks, administration and recruitment services, and also perform several types of necessary IT services for GSA. Subject to applicable data protection laws, we may transfer your personal information outside the jurisdiction in which it was collected. If we do, you can expect a similar degree of protection in respect of your personal information, either through the country to which we transfer your personal information having been approved by relevant data protection authorities as providing an adequate level of protection for your personal data, or by us putting other appropriate safeguards in place.

Your rights

You have rights as an individual which you can exercise in relation to the information we hold about you. Under GDPR and UK GDPR, these include:

  • the right to withdraw any consent to processing you have provided.
  • the right to obtain information regarding the processing of your personal data and to access to the personal data that GSA holds about you.
  • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and the right to request that GSA transmits that data to a third party where this is technically feasible.
  • the right to request that GSA rectifies your personal data if it is inaccurate or incomplete.
  • the right to request that GSA erases your personal data in certain circumstances. Please note that there may be circumstances where you ask GSA to erase your personal data but GSA is legally entitled to retain it.
  • the right to object to, and the right to request that GSA restricts, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask GSA to restrict, its processing of your personal data but GSA is legally entitled to continue processing your personal data or to refuse that request.
  • the right to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by GSA. In the UK, the relevant data protection authority is the Information Commissioner's Office, which can be contacted at ico.org.uk.

You can read more about these rights on the Information Commissioner's Office website -https://ico.org.uk/your-data-matters/. If you have any questions about this Privacy Notice or how we handle your personal information, please contact GSA's Data Protection Officer atcompliance@gsacapital.com. This Privacy Notice does not form part of any agreement between you and GSA for the provisions of any services or goods between us. We may update this Privacy Notice from time to time and in such event, we will post the revised Privacy Notice on our website. Changes to this Privacy Notice will take effect as soon as they are posted to our Website.

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