GDPR Privacy Policy

Introduction and background

The purpose of this policy is to outline how Long Harbour Limited has established measures to protect your privacy and information rights.

Your 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:

How we collect and process your information
Why we do this
How you can exercise your rights;
Who to contact in the event you’re unhappy with our performance.

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.

Information we collect

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:

Our IT service provider, ReflectiveIT, provides offsite backup services for us.
Moore Stephens LLP are our auditors and operate payroll on our behalf.
PeopleHR provides us a cloud-based HR management system, to help us administer employee records.
We can share information with other members of the Long Harbour group to support us in day-to-day business administration.
We use the Office 365 suite provided by Microsoft to handle our email and other office automation.

Retention of data

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.

Automated decision making

Long Harbour Limited does not routinely make use of automated decision making or profiling in processing your data.

Securing your information

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.

Contact details

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):

Long Harbour Limited, as data controller, can be contacted as follows: 33, Wigmore Street, London W1U 1QX
The Data Protection Officer can be contacted at the above address

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

Disclaimer

Introduction and Suitability

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.

Warranty

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.

Limitation of Liability

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.

Law and Variation

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.

Stewardship Code

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.

Cookie Information

What are cookies?

Like most websites, this one uses cookies.

Cookies are small text files stored on your computer by your browser.

They're used for many things, such as remembering whether you've visited a site before, so that you remain logged in - or to help you to pay for
things online. The most commonly used cookies are 'analytical' and allow website owners to gather anonymous information about how their
website is used so that they may improve your experience.

What are our cookies used for?

We may use such 'analytical' cookies to collect information automatically when you visit the Website.
The information collected by cookies does not include personal information about you (they don't store your name, for instance);
it includes general information about your computer settings, your connection to the Internet e.g. operating system and platform, IP address,
your browsing patterns and timings of browsing on the Website and your location.

Most internet browsers accept cookies automatically, but you can choose, below, not to allow cookies. If you do, we can't guarantee that
your experience with the Website will be as good as if you do allow cookies.

How do I disable cookies?

If you want to disable cookies you need to change your website browser settings to refuse cookies.
How to do this depends on the browser you use. Below are details on how to disable cookies for the most popular browsers:

For Microsoft Internet Explorer:

Choose the menu "tools" then "Internet Options"
Click on the "privacy" tab
Select the setting the appropriate setting

For Mozilla Firefox:

Choose the menu "tools" then "Options"
Click on the icon "privacy"
Find the menu "cookie" and select the relevant options

For Opera 6.0 and further:

Choose the menu Files"> "Preferences"
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