Privacy Policy (July 2023)
1. INTRODUCTION:
This privacy notice (“Notice”) describes how Sprints Capital Management Limited (“Sprints”) treats personal information and data that we collect, use, and share. Sprints is also the adviser to several Guernsey Limited Partnerships (“Funds”), which are Closed-ended Investment Schemes.
2. GDPR DATA PROTECTION PRINCIPLES
In respect of the collection, holding, storage, use, and processing of your Personal Data:
We will obtain the data only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
The data we collect will be relevant to the purposes we have told you about and limited to those purposes.
We will take reasonable steps to ensure that the data is accurate and kept up to date.
Subject to applicable legal or other requirements, we will keep the data only as long as necessary.
We will use appropriate technical and/or organizational measures to ensure appropriate security of the data.
3. YOUR LEGAL RIGHTS:
You have the right:
to request access to, or copies of, your data;
to request rectification of your personal data;
to request that the processing of your data is restricted and/or object to such;
to request erasure of your personal data;
to exercise your right to data portability;
where we rely on your consent to process data, to withdraw your consent; and
the right not to be subject to automated decision-making.
Please note that Sprints does not use automated decision-making. The right to erasure is not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. Erasure of the personal data requested to fulfil the purposes described in this Notice, may result in the inability to provide the services to the investor.
4. DISCLOSURES OF YOUR PERSONAL DATA:
We may disclose your personal data to other third parties who are providing services to us and/or the Funds, including but not limited to, fund administrators, any IT service providers, event management, PR and marketing service providers, background and/or credit reference services, processors of the Funds (including printers, company secretarial services, administrators) telephone service providers, document storage providers and backup and disaster recovery service providers.
5. DATA SECURITY:
Sprints will ensure appropriate measures are in place to ensure the security of the personal data it collects and stores about you. It will use its reasonable endeavours to protect your personal data from unauthorised disclosure and/or access, including through the use of network and database security measures, but it cannot guarantee the security of any data it collects and stores. We will notify you and any applicable regulator of a breach where we are legally required to do so.
6. RETENTION AND SECURITY OF PERSONAL DATA:
We employ appropriate measures to protect personal data within our control against accidental or unlawful destruction, loss, unauthorised access, and other unlawful or unauthorised forms of processing.
Personal data may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations, or where longer, such longer period as is required by applicable legal or regulatory obligations or for any applicable limitation period under applicable law. Personal data will be retained throughout the life cycle of any investment, however no longer than necessary with regard to the purpose of the investor’s relationship with Sprints. Some personal data will be retained after a data subject ceases to be an investor in a Sprints fund.
7. DATA SUBJECT CATEGORIES:
Clients
Visitors to the Website
Business Contacts and Service Providers
Job Applicants
7.1. CLIENTS
What we hold:
We may hold personal data about Clients which is provided to us by you directly as a result of your investment (by completing subscription forms, telephone calls and/or corresponding with us) or which is provided to us by third parties. This detail may include names, contact details, tax identification numbers, bank details, the names, contact details and signatures of authorised signatories, copies of IDs, contact details for individuals to receive correspondence and investor information.
How we will use the information about you:
Your personal data may be processed by Sprints or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:
(a) to provide you with information on the Fund (including performance updates);
(b) to facilitate the opening of an account in a Fund;
(c) to allow us to administer and manage your holding in the Funds;
(d) to update and maintain records for the Funds including with regulators;
(e) to carry out anti-money laundering checks and related actions which Sprints considers appropriate to meet any legal, regulatory or tax obligations imposed on the Fund or Sprints, as required by public interest and/or legitimate business interests (including in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption and tax evasion);
(f) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions or otherwise comply with fund administrator procedures;
(g) to retain records to assist with the subsequent AML screening by the fund administrator;
(h) to prepare tax related information in order to comply with legal, tax or regulatory obligation; and,
(i) such other actions as are reasonably necessary to manage the activities and/or to comply with the legal obligations of the Funds and Sprints, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for regulatory purposes and enforcing or defending the rights and/or interests of the Funds or Sprints, in order to comply with the Funds’ or Sprints’ legal, tax or regulators obligations and/or to pursue legitimate interests.
Basis on which we process your data
Such processing is carried out on the basis that it is necessary for the pursuit of legitimate interests and such legitimate interests are not overridden by your interests, fundamental rights or freedoms. Sprints and/or the Funds do not anticipate being required to obtain your consent for the processing of your personal data. If Sprints and/or the Funds wish to use your personal data for other purposes which do require your consent, Sprints will contact you to request this.
7.2. VISITORS TO THE WEBSITE
The following section of this policy sets out how Sprints may process personal data (as a controller) about visitors to its website.
How we collect your data
Analytics:
This website collects anonymous personal data to power our site analytics, including:
Information about your browser, network, and device
Web pages you visited prior to coming to this website
Web pages you view while on this website
Your IP address
This information may also include details about your use of this website, including:
Clicks:
Internal links
Pages visited
Scrolling
Searches
Timestamps
We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.
Cookies:
For more information about our cookie policy, please click here.
How we will use information about you
Your personal data may be processed by Sprints or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:
(a) to send you updates on the performance of the Funds, newsletters, invitations to events and other electronic communications which we will do on the basis of our legitimate interests if you are a client or potential client;
(b) to comply with legal or regulatory requirements; and ,
(d) such other actions as are necessary to manage the activities of Sprints and/or the Funds, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) and enforcing or defending the rights and/or interests of Sprints and/or the Funds, in order to comply with their legal, tax or regulatory obligations and/or to pursue their legitimate interests.
We will use your personal data in the following circumstances: where it is necessary for our legitimate interests, or those of a third party and where your interests and fundamental rights are not overridden by those interests, or where we need to comply with a legal or regulatory obligation.
7.3. BUSINESS CONTACTS AND SERVICE PROVIDERS
The following section of this policy sets out how Sprints may process personal data (as a controller) about its business contacts and (current, previous and/or potential) service providers (and employees of service providers) and data subjects that have provided a business card to, or have corresponded with, an employee of Sprints.
The kind of information we hold about you
We may collect, use, store and transfer different kinds of personal data about you which you provide to us including: name, date of birth, contact details, place of work and job title.
How we will use information about you
We will use your personal data in the following circumstances: where it is necessary for our legitimate interests, or those of a third party, and where your interests and fundamental rights are not overridden or where we need to comply with a legal or regulatory obligation.
Your personal data may be processed by Sprints or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:
(a) to hold your personal data on our system and to contact you on the basis of the legitimate interests of Sprints and/or the Funds (including in connection with using the services that you provide);
(b) in respect of suppliers, to allow us to process payments;
(c) to send you updates on the performance of the Funds, newsletters, invitations to events and other electronic marketing communications which we will do (i) on the basis of our legitimate interests if you are an investor in the Fund or (ii) with your consent;
(d) to comply with legal or regulatory requirements;
(e) such other actions as are reasonably necessary to manage the activities of Sprints and/or the Funds, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) and enforcing or defending the rights or interests of Sprints and/or the Funds, in order to comply with their legal, tax or regulatory obligations and/or to pursue their legitimate interests.
Such processing is carried out on the basis that it is reasonably necessary to pursue Sprints and/or the Funds' legitimate interests, such legitimate interests do not override your interests, fundamental rights or freedoms.
7.4. JOB APPLICANTS:
The following section of this policy sets out how Sprints may process personal data (to the extent that Sprints is a data controller of the personal data that you provide) about applicants for jobs or placements, and in relation to potential workers and contractors. Sprints is the data controller of the personal data that you provide or which is provided to or collected by Sprints during and/or in connection with any application for a position at Sprints. The kind of information we hold about you in connection with an application, we may collect, store, and use the following categories of personal data about you: name, marital status, address and post code, telephone number, fax number, personal email address, date of birth, gender, proof of ID (includes copies of passport photo page and utility bills), residency status, employment history, qualifications and other information contained in your CV and cover letter or email, information obtained from social media, including LinkedIn, details of referees and references, qualifications (including copy certificates of academic and professional qualifications), screening questionnaire for verification by outsourced firm and summary of findings, and information provided to us during telephone calls, interviews and/or meetings with you.
How we collect your data
We may collect personal data about candidates from the following sources: you, the candidate directly; recruitment agencies; background check providers; credit reference agencies; disclosure and barring service in respect of criminal convictions, your named referees; and data from third parties if from a publicly accessible source including Companies House records and social media (such as LinkedIn).
How we will use the information about you
Your personal data may be processed by Sprints or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:
(a) to assess your skills and qualifications;
(b) to carry out background and reference checks, where applicable;
(c) to communicate with you about the recruitment process;
(d) to keep records related to our hiring processes;
(e) to comply with legal or regulatory requirements;
(f) such other actions as are reasonably necessary to manage our activities, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for regulatory purposes and enforcing or defending Sprints’ rights and interests, in order to comply with our legal obligations and/or to pursue our legitimate interests.
How we will use information about you
We process this personal data on the basis of our legitimate interests (in order to decide whether to appoint you to work for us) and/or in order to comply with applicable laws. Once we receive your CV and/or covering letter, we may process that information to decide whether Sprints has any suitable vacancies and if you meet the basic requirements to be shortlisted for that role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the work. If we decide to offer you the work, we will then take up references and we may carry out a criminal record or other checks before confirming your appointment. If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. We may share your personal data with the following third parties for the purposes of processing your application: employee screening and IT service providers.
8. CHANGES TO THIS POLICY:
We may update this privacy policy from time to time, and will communicate such updates when they occur.
9. FURTHER INFORMATION:
If you have any concerns about the way in which Sprints uses your personal data please contact us at:
If you want to complain, you may also contact the data protection authority in your country. In the United Kingdom, this is the ICO and can be contacted at the below address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk