This Policy is provided by Knightsbridge Advisers LLC, on behalf of itself and the Delaware, U.S. and Cayman Islands investments funds it advises (“Knightsbridge”). This Policy gives information regarding your personal information (defined as “personal data”) under the Privacy Laws and describes the basis on which we process your personal information, for what purposes, your privacy rights under applicable privacy laws including, where applicable, under the EU General Data Protection Regulation (“GDPR“), other European data privacy laws, the U.S. Gramm Leach-Baily Act, and other applicable US privacy laws (the “Privacy Laws”) and the Data Protection Law, 2017 of the Cayman Islands ("DPL") and how we protect your personal information. Maintaining your privacy is important to us and we hold ourselves to the highest standards in its safekeeping and use.
Personal data we may collect about you
In the conduct of our business, we may obtain personal information about you in connection with our business activities, including without limitation your name and other contact details, financial and transaction data. This information may come directly from you, sources supplied by you, and other written, electronic or verbal correspondence which relate to our business activities. We may also receive information from intermediaries, social media or publicly available resources. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal data on individuals connected to you for any reason in relation to your investment with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.
How we use information that we collect
We collect your personal information to fulfill our contractual obligations, our statutory obligations and/or the legitimate interests of Knightsbridge and for other purposes for which Knightsbridge has a lawful basis under the Privacy Laws, including:
for compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing or “Know your Customer” requirements, as well as to verify status and/or eligibility in regard to funds or services offered by Knightsbridge and for compliance with tax reporting requirements;
for purposes of reporting to, or communicating with, you consistent with our obligations to our clients;
in connection with investment activities, including investment due diligence or investment monitoring activities or in response to “Know your Customer” requirements of counterparties;
in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving Knightsbridge or its clients;
to send you fact sheets, newsletters, invitations to events and other information about Knightsbridge
some other form of legitimate business interest, where such interests are not overridden by your interests, fundamental rights and freedoms.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Generally, we do not rely on consent as a legal ground for processing your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you.
You can ask us to stop sending you marketing messages at any time by contacting us at email@example.com. When you opt out of receiving our marketing communications, this will not apply to communication we make with you in relation to a legitimate business interest or lawful purposes, such as the performance of a contract we may have with you.
Sharing and disclosure of your personal data
We may share your personal data with the parties set out below for legitimate business interests and lawful purposes, these may include but are not limited to:
Fund, IT and system administration service providers
Professional advisers including attorneys, accountants, auditors, tax advisers, custodians, bankers and insurers.
Other counter-parties, including any clients, any vendor, any lender or any of their respective managers, general partners or investment advisers or administrators, or any of their respective agents or representatives or any affiliate of any of the foregoing. For example, we may share personal information with a client fund in order to respond to the anti-money laundering enquiries.
Relevant regulatory and tax authorities
The security of your data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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 will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention periods
We will generally keep personal information for as long as necessary in relation to the purpose for which it was collected, or necessary for the purposes of our other legitimate interests, or for such longer period if required under applicable laws. For example, by law we must keep basic information about our clients (including contact identity, financial and transactional) for six years for tax purposes and for at least five years after a client ceases to be a client under the UK money laundering regulations 2017. We must also keep all business records and communications for at least five years as an Investment Adviser registered with the US Securities and Exchange Commission.
You have certain rights relating to the personal information we hold in accordance with and subject to the Privacy Laws to:
check whether we hold personal information about you and to access such data;
request the correction of personal information about you that is inaccurate;
have a copy of the personal information we hold about you provided to you or another controller where technically feasible;
request the erasure of your personal information; and
request the restriction of processing concerning you. To do so, please send your request to Knightsbridge at firstname.lastname@example.org
broadly analogous rights exist under the DPL
You are required to ensure the personal information we hold about you is up-to-date and accurate and you must notify us of any changes to the personal data you provided to us in, for example in information supplied in relation to an investment in a Knightsbridge client fund.
Questions and/or Complaints