Privacy

DSP Global Funds ICAV respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This policy (explains how we will process personal data you provide, when you visit our website, when you discuss or enter into transactions with us; or when you email us, telephone us, network with us or otherwise communicate with us. “Processing” is defined under applicable data protection laws, most notably the Regulation n°2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), and includes among other things, the collection, storage and use of personal data.

This policy applies where we are acting as the data controller with respect to your personal data (where we determine the purposes and means of the processing of that personal data).

Changes to our privacy policy

This policy may change from time to time and if it does, we will publish a new version on our website which will become effective immediately. Please check this page occasionally to see any updates or changes

Controller

We are the controller and responsible for your personal data, ("we", "us" or "our" in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: DSP Global Funds ICAV

 Email address: [email protected]

Postal address: 5 George’s Dock, IFSC, Dublin 1

You have the right to make a complaint at any time to the Data Protection Commission (DPC), Ireland’s supervisory authority for data protection issues (https://www.dataprotection.ie/). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us and we will do our best to resolve the issue.

Information we collect

Primarily, we collect information which you give us.

• The personal data that you give us may include:
• your title, name and date of birth
• contact information, including telephone number, postal address and email address
• information relating to your location, preferences or interests
• your personal description or photographic identification
• in certain circumstances, your and others’ signature(s), National Insurance number(s), financial details such as bank account details and details of any relevant sanctions or similar restrictions
• the content of any enquiry submitted over our website
• information about your holding in a Fund or the reference number in relation to your holding.
• In relation to investors or potential investors in our Funds, you have the right to refuse to give us your personal data in which case we may at our discretion: refuse to issue shares or units in a Fund to you; refuse to pay the proceeds of a redemption of shares or units; refuse to pay income on shares or units to you; compulsorily redeem your holding.

Information we collect about you

• Usage data
• Each time you visit our website:  we will automatically collect the following information:
• technical information about your computer, including where available your Internet protocol or “IP” address, operating system and browser type and version, your login information, time zone setting, operating system and platform; information about your visit, including the full Uniform Resources Locators (“URLs”), clickstream to, through and from our website (including date and time); time on page, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs). We will do so for administration purposes; to analyse the use of our website and services. The source of the usage data is our analytics tracking system.
• location, device and demographic information (Google Analytics provides age range and gender information. Find out more about how Google collects demographic data).

Categories of persons whose data we process

• The personal data described above may include personal data of:
• our clients (and prospective clients) and their personnel
• investors or prospective investors in our Funds
• third parties with whom we contract or enter into discussions within relation to the services that we offer
• contacts at professional adviser firms with whom we work in the context of our services
• our service providers, contractors and suppliers
• visitors to our website

Cookies

 

Cookies are text files containing small amounts of information which are downloaded to a user’s device when they visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.

If you want to remove any cookies already set, you can do so from your browser. You can find out how to do this by going to the help menu in your browser or by visiting www.aboutcookies.org.uk or by searching the internet for other independent information on cookies. You can also block cookies from your browser. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of this website.

How we use your information and the legal basis for processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• to provide you with information or services that you request from us;
• to communicate with you (including the mailing, in physical or electronic format, of periodical reports, notices or other communications that are necessary for the functioning of our relationship);
• to ensure that content from our website is presented in the most effective manner for you and for your device;
• to enable us to improve our services;
• to keep a record of the services you have subscribed to;
• to facilitate our internal administration processes;
• to comply with our legal and regulatory obligations;
• for any other purpose which you have specifically consented to when providing the information;
• where you have indicated you wish to receive further information from us and where we need to prepare or perform a contract which we are about to enter into with you; or
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Purposes for which we will use your personal data

Some of the grounds for processing personal data are described below. Some of these grounds will overlap as there may be several grounds which justify our use of your personal data.

We have set out below a description of all the ways we intend to utilise your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. If you have any questions with respect to how we use your data, or the specific legal basis on which we do so, please contact us.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your information

We will only share your personal data in accordance with applicable laws. We will not rent or sell your details to any other organisation or individual. We may disclose your personal data to:

• any member of our “group” (which means our subsidiaries, our ultimate holding company and any of its subsidiaries) in so far as necessary and for the purposes and on the legal basis set out in this policy
• our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure
• our auditors
• our bank (including as permitted under applicable anti-money laundering or anti-terrorist financing laws
• competent authorities including our regulator, the Central Bank of Ireland; tax authorities, courts and bodies as required by law for reporting or as otherwise required by law
• service providers, support services and organisations that help us market our services and third parties instructed to enable us to fulfil our contractual obligations
• our data processors providing security, email security, data governance, archiving and other IT business and support services
• Selected partner digital agencies
• Analytics and search engine providers that assist us in the improvement and optimisation of our website
• Any third party that you ask us to share your data with

Our website may, from time to time, contain links to and from the websites of advertisers and partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

We may also share your personal information when we feel there is good reason that is more important than your privacy. If this is the case, we will make sure that we record what information we share and our reasons for doing so. We will let you know what we have done and why if we think it is safe to do so. This does not happen often but we may share your information:

• in order to find or stop a crime or fraud; or
• if there are serious risks to the public, our staff or to other professionals.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transfers outside Ireland

The personal data we collect from you may be transferred to, and stored at, a destination outside Ireland. By submitting your personal data, you understand that your personal data may be transferred, stored or processed in the manner described in this privacy policy.

We will take all steps reasonably necessary to ensure that your data are treated securely and in accordance with this privacy policy as well as the requirement under applicable legislation. Unfortunately, the transmission of information via the internet is not completely secure.

We have put in place security procedures, such as passwords, plus other technical and organisational measures that we consider appropriate to safeguard your personal information and which are intended to guard against unauthorised or unlawful access to, alteration, disclosure or destruction of personal data and against accidental loss or destruction of or damage to personal data.

International transfers

During the usual course of business, we do not transfer data outside of the European Economic Area (EEA). However, from time to time, personal data may be made available to our board members located temporarily or otherwise outside the EEA for management/internal administration purposes. Where personal data is provided to a board member who is located outside of the EEA, we will take every reasonable step to ensure that your personal data are processed with at least the same standards of data protection as those provided under the Data Protection Legislation, including by imposing specific obligations and requirements on the recipient.

This transfer of personal data is necessary: (i) in order to allow us to continue providing the information or services to you which you have requested; or (ii) pursuant to a contract between us. Such transfers will not include special category data (i.e. more sensitive personal data).

If you would like further information, please contact us. 

We do not share, sell or distribute your personal data with or to unrelated third parties except in order to provide you with the information or services which you have requested, or as provided in the following limited circumstance:

to other third parties who support our administration, payroll and beneficial ownership register, information technology or handle mailings or events on our behalf (our service providers);

to comply with a legal or regulatory requirement, or for the administration of justice;

where such disclosure is necessary in relation to a potential sale or merger of our business.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

 

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Such information may be retained after our client relationship has ceased, and for client identification purposes in accordance with our data retention procedures. You may ask us for further information on these.

To determine the appropriate retention period for personal data, we consider the amount, nature, 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.

By law, we have to keep basic information about our customers (including Contact, Identity) for 6 years after they cease being customers for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your rights

In certain circumstances you may have the following rights in relation to the processing of your personal information:

• Access
  To request a copy of the personal information we process in relation to you and to be informed about how we use and share your personal information.
• Object
  To object to the processing of your personal information if (i) we are processing your personal information on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if we are processing your personal information for direct marketing purposes
• Correction
  To request that we update the personal information we process in relation to you, or to correct personal information that you think is incorrect or incomplete.
• Erasure
  To ask that we delete personal information that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.
• Restriction
  To request that we restrict the way in which we process your personal information, for example, if you dispute the accuracy of your personal information or have raised an objection which is under consideration.
• Portability
  To request a copy of your personal information that you have provided to us in a commonly used electronic format such as through the completion of an application form.
• Automated decision making
  To request manual intervention if you are subject to automated decisions where the decision results in a legal or similar effect to you.

You may exercise your rights at any time by using the details set out in the Contact Details section. To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access to the personal information requested, or to exercise any of your other rights. This is to ensure that personal information is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the personal information processed in relation to you, including, for example, the nature and location of your relationship with us.

We aim to respond to all legitimate requests within one calendar month. If we think it may take us longer than one calendar month, (such as where your request is particularly complex or you have made a number of requests), we will notify you and keep you updated.

You will not be disadvantaged in any way by exercising your rights in relation to the processing of your personal information.

Consent

• Where we process your personal data on the basis that you have provided your consent for us to do so for a purpose set out in this policy, you may withdraw your consent to this processing at any time by contacting us at [email protected] or contacting us on the details under “Contact Details”.

If you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds and will notify you of these at such time.