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Privacy Policy

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.

This privacy notice comprises:

  1. WHO WE ARE AND IMPORTANT INFORMATION
    2. THE PERSONAL DATA WE COLLECT ABOUT YOU
    3. HOW WE COLLECT YOUR PERSONAL DATA
    4. HOW WE USE YOUR PERSONAL DATA
    5. WHO WE SHARE YOUR PERSONAL DATA WITH
    6. INTERNATIONAL TRANSFERS
    7. DATA SECURITY
    8. DATA RETENTION
    9. YOUR LEGAL RIGHTS
    10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
    11. QUERIES, REQUESTS OR CONCERNS
  2. WHO WE ARE AND IMPORTANT INFORMATION

What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website.

This website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller(s)
H.M. Pelagic Partners Ltd is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). Our contact details are Miltonos 32, P.C. 3050, Limassol, Cyprus. +357 25 58 40 00. For all data matters contact info@pelagic-partners.com.

Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes name, gender etc.
• Contact Data includes address, company details, telephone numbers, email address etc.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  1. HOW WE COLLECT YOUR PERSONAL DATA

We will collect your personal data directly.

You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.

  1. HOW WE USE YOUR PERSONAL DATA

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:
• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

  • Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

We will use your personal data for:
• Newsletter subscription: to supply you with our regular newsletter if you have chosen to subscribe.
• Marketing: to make you aware of relevant information about our company and its services.

Opting out
You can ask us to stop sending you marketing messages at any time by contacting enquiries@navigatepr.com

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

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 enquiries@navigatepr.com

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.

  1. WHO WE SHARE YOUR PERSONAL DATA WITH
    We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
    • Third-party email client to ensure you receive our newsletter or marketing material
    • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

  1. INTERNATIONAL TRANSFERS
    We do not transfer your personal data outside of the EEA.
  2. 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.

  1. DATA RETENTION
    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.
    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, 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.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

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.

  1. YOUR LEGAL RIGHTS
    Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
    • The right to request a copy of the personal data which we hold about you;
    • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
    • The right to request your personal data is erased where it is no longer necessary to retain such data;
    • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
    • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
    • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
    • The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact info@pelagic-partners.com

No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
    This notice might change from time-to-time, please re-check this page periodically. Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
  2. QUERIES, REQUESTS OR CONCERNS
    To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact info@pelagic-partners.com
By entering this website you will gain access to information regarding H.M. Pelagic Partners Ltd.

This website is directed at professional and well-informed investors only, within the meaning of the Cyprus Alternative Investment Funds Law. RAIFs which are addressed to professional and/or well-informed investors do not apply protective measures provided by the law for retail investors. You are solely responsible for choosing your investor category. You declare that this choice is compliant with all the relevant definitions under the applicable laws and regulations.

Persons accessing the contents of this website are aware that they are solely responsible for complying  with the applicable laws and regulations of their country of residence and/or citizenship. If in doubt, they should seek advice from their independent tax advisor, legal counsel, and/or financial advisor.

The content of this website is being provided for informational purposes only and does not constitute an advertisement, a personal recommendation or an investment advice. The content of this section of the website is not exhaustive, is subject to change and may be modified or updated at any time by H.M. Pelagic Partners Ltd. without prior notice. Regulations concerning the marketing of Alternative Investment Fund units vary depending on the country and your status (as a professional or well-informed investor). If you are in any doubt, we advise you to speak to your advisor.

The prospectuses and KIDs (Key Information Document) of the Registered Alternative Investment Fund units in this website are approved and/or authorised by the Cyprus Securities and Exchanges Commission (CySEC).

All data and material has been obtained from sources believed to be reliable, but their accuracy is not guaranteed. They are subject to modification without prior notice. Information provided in this website shall not be considered as any kind of undertaking or guarantee whatsoever from H.M. Pelagic Partners Ltd.

Any investment involves specific risks. All potential investors must take prior measures and seek specialist advice in order to analyse the risks involved and establish his or her own opinion independent of H.M. Pelagic Partners in order to determine the relevance of such an investment pertaining to one’s own financial situation. Before making any investment decisions, investors should read the relevant offering documents and in particular the investment policies and the risk factors. Investors should ensure they fully understand the risks associated with the investment and should also consider their own investment objective and risk tolerance level.

Investment in AIFs does not guarantee an investment return and previous investment returns do not guarantee any future ones. The value of the investment in units of the AIFs is subject to increase or decrease, whereas the initial value of the investment is not guaranteed.

Use of this site and these terms and conditions are subject to the law of the Republic of Cyprus.

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