Privacy Notice

1. Data Controller

Hengistbury Investment Partners LLP (“we”, “us”, “the Firm”), partnership number OC365747, with registered office at First Floor, 34 Brook Street, London W1K 5DN, is the data controller responsible for your personal information.

We process personal data in accordance with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

2. Personal Data We Collect

We may collect and process the following categories of personal data:

• Identity data: name, date of birth, nationality, passport or identity document information;
• Contact data: address, email address, telephone numbers;
• Financial data: bank account details, source of wealth, investment experience and objectives;
• Due diligence data: information collected for the purpose of anti-money laundering (AML) and know-your-customer (KYC) compliance;
• Technical data: IP address, browser type, operating system and other data collected automatically when you access our website or investor portal;
• Communications data: emails, meeting notes and other correspondence.

3. Lawful Basis for Processing

We process personal data on one or more of the following lawful bases:

• Contract: processing is necessary for the performance of a contract to which you are party, or to take steps at your request prior to entering into a contract;
• Legal obligation: processing is necessary to comply with applicable laws and regulations, including FCA rules, AML legislation and tax requirements;
• Legitimate interests: processing is necessary for the purposes of our legitimate interests in managing the Firm, communicating with investors and prospective investors, and protecting the security of our systems;
• Consent: where required by applicable law, we will request your consent before processing your personal data.

4. How We Use Your Data

We use personal data for the following purposes:

• Managing your investment relationship with the Firm;
• Complying with our regulatory and legal obligations, including AML/KYC checks;
• Communicating with you about your investment, portfolio updates and fund matters;
• Maintaining our books and records;
• Responding to enquiries; and
• Operating and improving our website and investor portal.

We do not sell personal data to third parties. We may share data with regulators, legal and compliance advisors, auditors, fund administrators, custodians and other service providers strictly as necessary to provide our services and meet our obligations.

5. Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

In accordance with AML regulations, certain due diligence records are retained for a minimum of five years following the end of a business relationship. Other records may be retained for longer periods where required by law.

6. Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

• The right to be informed about how your data is used;
• The right of access to your personal data;
• The right to rectification of inaccurate data;
• The right to erasure in certain circumstances;
• The right to restrict processing;
• The right to data portability;
• The right to object to processing based on legitimate interests; and
• Rights in relation to automated decision-making and profiling.

To exercise any of your rights, please contact us using the details below. You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) at ico.org.uk.

7. Contact

If you have any questions about this Privacy Notice or how we process your personal data, please contact us at: