1. Introduction

This Privacy Policy relates to Eden Rock Capital Management LLP (“Eden Rock”) as controller of certain personal information and explains how and why we collect and use such personal
information. It also explains what we do to keep such information secure. The partners of Eden Rock are committed to ensuring that personal information is used in accordance with data protection legislation.

This policy was last updated on 14 May 2018. The Policy may be updated from time to time and posted on our firm’s website at www.edenrockcm.com.

2. Types of personal information we hold 

Eden Rock collects and processes the following types of personal data: names, residential or business addresses and other contact details (telephone numbers, email addresses and related web profiles), other business details (role, title or other company contact details), signatures, nationality, date and place of birth, Tax Identification Number, identification documents (e.g. passports), bank account and source of funds details, Information about assets or net worth, Credit history and other information arising from background checks.

If you access our website, we will record your IP address and we will store information about the pages you view.

If you visit our offices, we capture CCTV images.

3. How we collect personal data

Most personal data we collect will come directly from you or be provided by another person on your behalf. If you are an existing or potential client of Eden Rock, information will be collected at or prior to any investment or engagement of Eden Rock. Information is also collected if you engage in general communication with Eden Rock, attend an event organised by Eden Rock or provide Eden Rock with such details if you express an interest in our services or as part of an inquiry you have made.

In some instances, we may obtain personal information from third parties and these may include fund administrators, publicly available databases and registers, previous employers, governmental and/or credit agencies and supervisory bodies.

Certain information is also collected when you access our website, if you visit our offices or if you are on a telephone call with us that is recorded.

4. What we use personal information for

We collect personal information to provide individuals with services and to keep them informed about us and the services we provide. Information is also used to administer the client relationship between Eden Rock and investors, for direct marketing to potential investors and complying with our legal and regulatory requirements (including tax reporting, anti‐money laundering checks or attending to requests from regulatory or governmental agencies).

Eden Rock also collects personal data in the course of working with other businesses on potential transactions, investments and events and initiatives.

We also collect personal information in connection with employment matters. IP address information is used by Eden Rock to monitor potential system abuses and cyber threats. CCTV
recordings captured at the firm’s offices are used for security purposes.

Processing of personal information by Eden Rock as set out in this Policy will be in accordance with data protection laws and regulations. This means that it will be processed with your consent, if we have to comply with a legal obligation, or if Eden Rock has a legitimate interest.

5. Sharing Personal Information

We may share personal information with third parties and affiliates including fund administrators, executing brokers, custodians and other third‐party service providers needed by Eden Rock to provide its services and to run its everyday business (including IT firms providing general support services and web analytics). We will also share information if required to by law or regulation.

Eden Rock does not sell or trade in personal information. We do not share any personal information to non‐affiliates for the purposes of marketing.

6. Your rights

Under data protection law, individuals have rights to understand and access the personal data held about them. In connection with any personal data Eden Rock may hold about you, you have the right to (a) access that data, (b) request a rectification of such data, (c) request erasure of such data, (d) restrict how we process or use such data, (e) request a transfer of such data, (f) withdraw any consent that you have previously provided regarding the use of such data, (g) the right to lodge a complaint regarding the use of your data with a supervisory authority.

The rights described above are subject to certain exemptions and limitations and there will be instances where there might a legitimate reasons to refuse a specific request.

7. Storage and Retention of personal information

Personal information is collected and retained by Eden Rock for various purposes as described in this Policy. Eden Rock will hold such personal information for only as long as it is necessary to retain such information for such purposes. You should note however that certain information may have to be retained for longer periods to comply with regulatory requirements. In particular, information relating to the firm’s regulated activity is usually kept for at least 5 years, although there are instances where information is kept for a longer or shorter period.

We will review the personal data we hold from time to time to determine whether continued retention of such information is necessary and to identify personal data that no longer needs to be retained.

8. Transfer of Personal Information outside the EU

Personal information held by Eden Rock is stored within the European Economic Area (EEA). However, there may be situations where Eden Rock needs to transfer personal information to a
service provider located outside the EEA. In such cases, Eden Rock will process personal data under appropriate contractual arrangements in accordance with relevant data protection law.

Eden Rock may also rely on certain service providers who are covered under relevant Privacy Shield certifications.

9. Contact Information and Complaints

If you have any questions about this Policy, please contact us at info@edenrockgroup.com. You should also contact us if you believe your privacy rights have been infringed or that Eden Rock has not complied with this Policy. You may also lodge a complaint against Eden Rock with the Information Commissioner’s Office (ICO) and details of how to do this can be found on the ICO’s website at www.ico.org.uk.