Long Harbour arranges, manages and executes opportunities on behalf of its limited partners which are typically academic endowments, charities, family offices, pension funds, corporates and other institutional and private investors.
As Long Harbour expands its investment products within its focus areas, we are looking to raise additional capital from new limited partners as well as existing.
The purpose of this policy is to outline how Long Harbour Limited has established measures to protect your privacy and information rights.
We recognise that you have rights as a ‘data subject’, and that we have an obligation to uphold these.
This privacy notice aims to outline how we maintain these rights. In particular, it outlines:
In various circumstances, your rights are as follows:
|
Right |
Explanation |
|
Right to be informed |
This encompasses the obligation for us to be transparent in how we collect and use your personal data. |
|
Right of access |
You have the right to access your personal data and supplementary information. |
|
Right to rectification |
If the information we hold about you is inaccurate or incomplete, you can request that we correct this. |
|
Right to erasure |
You can request that we delete or remove personal data where there is no compelling reason for us to continue processing |
|
Right to restrict processing |
You have the right to request that we cease processing your data, if: · you consider it inaccurate or incomplete; · you object to processing and we are considering whether we still have a legitimate interest to process it. |
|
Right to data portability |
Where you have consented to our processing your data, or where the processing is necessary for us to deliver a contract, you can request a copy of that data be provided to a third party in electronic form. |
|
Right to object |
You have the right to object to our processing under certain circumstances. For example, you can object to: · direct marketing (including profiling); and · processing for purposes of scientific/historical research and statistics |
|
Rights relating to automated decision making including profiling |
Where we apply automated decision making, we must · give you information about the processing; · introduce simple ways for you to request human intervention or challenge a decision; · carry out regular checks to make sure that our systems are working as intended Information related to automated decision making is contained later in this notice. |
This privacy notice outlines how we are transparent in our processing. Please get in touch with us through the ‘contact details’ section to find out more or to exercise your information rights. There are circumstances in which we will decline your request, but we will explain this clearly to you.
Please find below a summary of the information we process and how we use this to deliver services to you.
|
Information we collect |
Why we collect this |
How we process this |
|
Finance |
We process this information on our employees to allow us to administer their employment and benefits. |
We process this information as one would expect of a responsible employer – to pay salaries, administer benefits, manage our obligations as an employer. |
|
Payroll |
We process this information on our employees to allow us to administer their employment and benefits. |
We process this information as one would expect of a responsible employer – to pay salaries, administer benefits, manage our obligations as an employer. |
|
Business administration (electronic file and document storage) |
We process this information on our employees to allow us to administer their employment and benefits. |
We process this information as one would expect of a responsible employer – to pay salaries, administer benefits, manage our obligations as an employer. |
|
Business administration (email) |
We process this information on our employees to allow us to administer their employment and benefits. |
We process this information as one would expect of a responsible employer – to pay salaries, administer benefits, manage our obligations as an employer. |
|
Human resources |
We process this information on our employees to allow us to administer their employment and benefits. |
We process this information as one would expect of a responsible employer – to pay salaries, administer benefits, manage our obligations as an employer. |
|
Management agent |
Our basis for processing this information is that it is necessary for us to deliver the services that you have contracted to. |
We sometimes need to share information with the managing agent for the property. |
|
Prospective client and non-clients’ data |
We process this data by consent which is obtained when a positive “sign-up” is initiated. |
We only use this data to distribute newsletters and similar as requested by the data subject. |
We share data with a number of third parties in the course of delivering our services. These are summarised below:
Long Harbour Limited retains information for seven (7) years from our point of last contact. We hold this information to support our legal and regulatory requirements. If you object to this retention, please contact us – details provided in the ‘Contact’ section.
Long Harbour Limited does not routinely make use of automated decision making or profiling in processing your data.
Long Harbour Limited applies technical and organisational security measures in line with industry good practices such as ISO 27001. Long Harbour Limited has achieved the Cyber Essentials accreditation.
We recognise that you may have questions on how we process and/or store your data, or may want to change either the data we hold on you or how we communicate with you in the future.
If you have any questions in respect of this notice, or would like to exercise your rights as a data subject (for example, to correct data or to exercise your right to access):
If you are unhappy that we have responded to your query adequately, of if you have a further complaint, The Information Commissioner’s Office can be contacted at via https://ico.org.uk/global/contact-us/ .... Or by email accessicoinformation@ico.org.uk
Post: Information Governance department. Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow. Cheshire SK9 5AF
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This Website and its contents have been approved by Long Harbour Ltd ("Long Harbour") which is Authorised and Regulated by the Financial Conduct Authority ("FCA"). The information contained in this Website relates to both regulated investment, as well as investment funds which are not recognised collective investment schemes for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the "Act"). The promotion of the unregulated funds to, and access to this Website by, persons in the United Kingdom is accordingly restricted by law to persons falling within the following definitions:
i. investment professionals having professional experience of participating in unregulated collective investment schemes.
ii. high net worth bodies, unincorporated associations, Charities qualifying under section24 of the Charities Act 1993 and endowments.
iii. market counterparties or professional investors.
By accessing this Website beyond this point you confirm your status as a professional client or eligible counterparty (as defined in the handbook of rules and guidance issued from time to time by the FCA (the “FCA Rules”) and you warrant as such. Accordingly, the protections afforded to retail clients under the FCA Rules may not be available to you if you become a client of Long Harbour. You are not entitled to sue Long Harbour under sections 71 or 150 ('actions for damages') of the United Kingdom Financial Services and Markets Act 2000. Please consult your legal adviser or visit the FCA’s Website for further explanation. Prospective investors should note that investing with Long Harbour carries a degree of risk and, if you choose to invest in any fund described or referred to in this Website, you may therefore lose some or all of any amount that you choose to invest.
This Website and the information contained in it constitutes a financial promotion for the purposes of the Act and FCA Rules. Investment information provided in this Website is believed to be accurate at the date first published and no warranty is given. It may be changed without notice. Any research or analysis used in this Website has been procured by Long Harbour for its own use and may have been acted upon for Long Harbour’s own purposes. Long Harbour reserves the right to grant access or revoke the authority to access, use or reproduce the contents of the Long Harbour internet site at its absolute discretion. While reasonable care is taken to ensure the accuracy, security and confidentiality of information available through the Long Harbour internet site, Long Harbour does not accept responsibility for any consequence of any use of the Long Harbour internet site by any user, authorised or unauthorised. This Website provides an indication of the investment strategy and key terms of the Fund. It must not be construed as investment advice.
Under no circumstances will Long Harbour be held liable for any damages, including, without limitation, direct or indirect, special or incidental losses or expenses arising in connection with the Website or use thereof or the inability by any party to use such Website, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure, even if Long Harbour, or representatives thereof, are advised of the possibility of such damages, losses or expenses.
This Website is established in England by Long Harbour in accordance with and shall be governed by, and your browsing in and use of this Website shall be deemed acceptance of, the laws of England and Wales. A condition of using this Website is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the English Courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum.
Rule 2.2.3 of the FCA’s Conduct of Business Sourcebook requires Long Harbour Ltd to make a disclosure on its website about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or where the firm does not commit to the Code, its alternative investment strategy. The Code is voluntary and sets out a number of principles relating to engagement by investors with UK equity issuers. The firm pursues a range of investment strategies for its clients, those strategies do not involve investment in any UK listed equities. Therefore, whilst the firm is supportive of the objectives that underlie the Code, the investments the firm makes on behalf of its professional clients who are not natural persons are not subject to the UK Corporate Governance Code and the associated Stewardship Code.
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