EU and UK Website Privacy Policy

EU-UK Privacy Notice Supplement

This EU-UK Privacy Notice Supplement supplements the information contained in the Privacy Policy above and applies solely to the processing of personal data which is subject to EU-UK Data Protection Laws. For the purposes of this EU-UK Privacy Notice Supplement and the Privacy Policy, the “EU-UK Data Protection Laws” means all applicable laws and regulations relating to privacy, the protection and/or the processing of personal data in the EEA, EU and UK, including (without limitation): the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR”), as amended or supplemented, and any other legislation which implements any other current or future legal act of the European Union or United Kingdom concerning the protection and processing of personal data and any national implementing or successor legislation, and including any amendment or re-enactment of the foregoing. The terms “controller”, “data subject”, “personal data”, “process” and “processing” have the meanings given to them in the applicable EU-UK Data Protection Laws.

Who is responsible for processing your personal data?

To the extent that EU-UK Data Protection Laws apply to our processing of your personal data, one or more of us are a “controller” of your personal data. In simple terms, when applicable, this means we: (i) “control” the personal data that we collect from you or other sources; and (ii) make certain decisions on how to use and protect such personal data.

What type of personal data do we collect?

The types of personal data that we collect are set forth in the “The Information We Collect” section of the Privacy Policy. Please note that 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.

Purposes and Legal Bases for Collecting and Using Personal Data

We rely on various legal bases under the EU-UK Data Protection Laws in order to process your personal data, as we have set forth in the “How We Use Your Personal Information” section of the Privacy Policy. Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data. These business and commercial purposes are also set out in the “How We Use Your Personal Information” section of the Privacy Policy.

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 we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations).

No solely automated decision making, including profiling, is used when processing your personal data.

Disclosure and Transfers of Personal Data

We may disclose and transfer your personal data to third parties as set forth in the “Disclosure of Personal Information” section of the Privacy Policy above, which may involve the transfer of your personal data outside of the outside the UK, EU or EEA.

Whenever we transfer your personal data across borders, we will only do so in accordance with applicable laws. Such transfers of personal data may be made further to applicable adequacy decisions, appropriate or suitable safeguards permitted under the EU-UK Data Protection Laws (such as the standard contractual clauses issued by the European Commission and/or the UK equivalent) or any other valid means permitted by applicable law. Furthermore, we may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfill the purposes described in the Privacy Policy and in accordance with applicable laws. For information on the safeguards applied to such transfers, please contact us at privacy@invidiacap.com.

For the purposes of this EU-UK Privacy Notice Supplement, “Non-Equivalent Country” means a country or territory other than: (i) a member state of the EU or EEA; (ii) the United Kingdom; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the United Kingdom (as applicable) in accordance with the applicable EU-UK Data Protection Laws to ensure an adequate level of protection for personal data.

Data Subject Rights

To the extent set forth in EU-UK Data Protection Laws, you may have certain rights relating to the collection and use of your personal data, including, as applicable, the right to (i) request a copy of the personal data retained by us; (ii) to correct any inaccurate information contained within the personal data retained by us; (iii) delete any personal data retained by us; (iv) restrict the processing of personal data retained by us, including the purposes for which personal data is processed by or on behalf of us; (v) object to the processing of personal data undertaken by us; (vi) direct the transfer of your personal data to a third party designated by you; (vii) withdraw your consent to our processing of your personal data at any time; and (viii) not be subject to solely automated decision making. Individuals located in the UK or EU may also “opt out” or unsubscribe from any marketing communications from us. An individual may contact us at privacy@invidiacap.com if they wish to exercise any of the rights set forth herein. Furthermore, you have a right to lodge a complaint with the appropriate supervisory authority. These rights are not absolute and in certain circumstances their exercise may not be possible including when personal data must be maintained to comply with applicable laws.

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.

Questions, Complaints and Contacting Us

To the extent EU-UK Data Protection Laws apply, should you have any questions, concerns, or complaints in relation to this EU-UK Privacy Notice Supplement and the Privacy Policy, please contact us at at privacy@invidiacap.com.