The Fund take the privacy and protection of its investors’ personal information seriously. The Fund will operate as the data controller in respect of the data collected about you. We have set out below information about our processing of your personal information, what rights you have, and how you can get in contact if you want to know more.

When we say personal information, we mean information about you, such as your name, date of birth, address, and contact details. We collect personal information from you that is necessary for us to either provide you with the service you have requested or to comply with regulatory or contractual requirements. Unfortunately, if you do not provide all of the information we require this may mean we are unable to accept investment from you.

How we use your personal information and why

The Fund and its engaged professional bodies (Business Partners), will use the personal information you provide to us, together with other information, for the following purposes:

• the administration of our products and services, including to enable us to perform our obligations to you and to provide any relevant services as discussed with you prior to any purchase of a product or service;
• complying with any regulatory or other legal requirements;
• carrying out checks using agencies such as credit reference agencies, tracing companies, or publicly available information;
• the provision of customer services – like to reply to a question, or tell you that something has changed;
• automated decision-making or profiling;
• keeping your information on record and carrying out other internal business administration.

Some of the purposes above are necessary to allow us to perform our contractual obligations to you and to enable us to comply with applicable laws and regulation. We may also rely on legitimate interests in using and sharing your personal information  for the purposes described above to improve our products and services. This allows us to explore ways to develop our business and to gain insights into how our products and services are used.

In addition, the Fund and its Business Partners may use the personal information you provide to us, together with other information, to send you direct marketing offers by electronic or non-electronic means including by post.

To the extent that we need your consent to use your personal information for these purposes, you explicitly provide your consent as appropriate.

Who we share your personal information with and why

We will share your personal information within the Fund and with our Business Partners, for any of the purposes set out in this IM. If appropriate, we may also pass on your personal information to financial crime prevention agencies, any legal, regulatory or government bodies.

As we, the Fund, and some of our Business Partners are global companies, we might need to send your personal information to countries that have different data protection laws to the UK or the European Economic Area. These transfers will only be:

• to countries in respect of which European Commission has issued a data protection ‘adequacy’ decision, or
• to other countries, such as India or the United States of America, where appropriate safeguards have been put in place.

If you want to know more about the above safeguards, further information is available on request.

We keep your personal information for a set amount of time

Your personal information will be stored either for as long as you are our customer, or longer if required by law or as is otherwise necessary. It will always be in line with our data retention policy.

Reference Checks

For certain products we may use approved credit reference agencies, tracing companies, financial crime prevention agencies, or publicly available information, to help us to check your identity, as well as to prevent fraud and money laundering; this may include checks on your current or previous addresses. Results of these may be recorded for future reference.

These checks may also be carried out for a joint policy holder or person(s) that you provide personal information on. Should we ever lose contact with you, we may use these agencies to verify your address to help us get back in touch.

Any transfer of your personal information will always be done securely.

We may use your personal information to make automated decisions or profile you

We, the Fund, and our Business Partners may use your personal information to make automated decisions affecting you or to conduct other profiling (for example marketing profiling).

To the extent that we conduct such automated decision-making activity, we’ll provide you with further information at the appropriate time.

 Use of your sensitive personal information

For certain products or service, we’ll need to process your sensitive personal information, such as information relating to health, genetics, biometric identifiers and sexual orientation. To the extent that we need your explicit consent to process this kind of personal information you explicitly provide your consent by placing investment into the Fund.

Your control

When it comes to how we use your personal information, you have the right to:

• request a copy of your personal information for free (we may charge you for this if the request is manifestly unfounded or excessive);
• in certain circumstances request that we move your personal information to another organisation if you want us to;
• request that we correct anything that is wrong, or complete any incomplete personal information;
• ask us to delete your personal information if it is no longer needed for the purposes set out in Part A or if there is no other legal basis for the processing.
• limit how we use your personal information or withdraw your consents you have given for the processing of your personal information (including consents to automated decision making);
• complain to a data protection authority or another independent regulator about how we’re using it;
• object to us using your personal information for direct marketing (including related profiling) or other processing based on legitimate interests.

If you want to do any of these, or would like an explanation as regards these rights, we have explained how you can get in touch in the ‘Contact Us’ section below.

We may monitor or record calls or any other communication we have with you. This will be for quality, staff training, dispute resolution and/or security purposes.

Others’ information

If you give us personal information about another person (or persons), we will take that to mean they have appointed and authorised you to act on their behalf. This includes providing consent to:

• our processing of their personal information and sensitive personal;
• you receiving any information protection notices on their behalf.

If for any reason you are concerned as to whether you are permitted to provide us with the other person’s information, please contact us on the phone number provided in the ‘Contact Us’ section of this notice before sending us anything.

Direct marketing

From time to time, we, the Fund, and our Business Partners may like to contact you by electronic or non-electronic means with details about products, services and any special offers.

Contact Us

If you require any other information about any part of the Fund’s privacy protocols, you can contact us in a number of different ways.

Write to us at:

Novus Black Fund UK Ltd, Suite 3, Park House, Earls Colne Business Park, Colchester, CO6 2NS

Email us at:

info@novusblack.co.uk

Phone us on:

+44 (0) 1206 582 170

Business Partners means our service providers, accountants, auditors, IT service and platform providers, intermediaries, reinsurers, concessionaires, investment managers, marketing agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance product providers and our legal advisers.