GDPR PRIVACY NOTICE

1. INTRODUCTION

Decagon Asset Management LLP (“Decagon”, “the Firm”) is a company registered in England and Wales with company number OC440645.

Decagon Asset Management LLP is authorised and regulated by the Financial Conduct Authority (“FCA”) with Firm Reference Number 969251.

For the purposes of the General Data Protection Regulation (“GDPR”), Decagon will be the “controller” of the personal data you provide.

Please read the following information carefully in order to understand the Firm’s practices in relation to the treatment of your personal data.

Should you have any questions, please email Olivia Cooper, COO and CCO, at ocooper@decagonam.com.

2. WHAT DATA PRIVACY PRINCIPLES DOES THE FIRM ADHERE TO?

• The Firm will process all personal data in a lawfully, fair and transparent manner.
• The Firm will only collect personal data where it is necessary:
  • For the Firm to provide a service to you
  • For you to provide a service to the Firm
  • For the Firm to monitor the diversity of its staff and inform the Firm’s diversity and inclusion practices
  • For the Firm to keep you informed of its products and services
  • For the Firm to comply with its legal and regulatory obligations; or
  • For the Firm to fulfil its day-to-day business operations and trade.
• The personal data collected by the Firm will be adequate, relevant and limited to what is necessary in relation to the specific purpose for which your data will be processed.
• The Firm will take all reasonable steps to ensure that personal data is accurate and, where necessary, kept up to date.
• The Firm will maintain personal data in a form that permits identification no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with the Firm’s record retention requirements as mandated by the FCA.
• The Firm will hold and process personal data in a manner that ensures appropriate security.
• The Firm will only share personal data where it is necessary to provide the agreed service, where it is necessary for the Firm to comply with its legal and regulatory requirements or where personal data is required for the Firm to carry out its day-to-day business operations and trade.
• The Firm will share high level staff diversity statistics with interested external parties (e.g. investors or prospective investors in the DAM Fund), upon request. The Firm will not share individual names but will share the gender and ethnicity aggregate percentages of the Firm’s staff base.
• The Firm will store staff ethnicity data in an anonymous manner, cognizant that it is classed as “sensitive personal data” as defined under GDPR
• The Firm will only utilise a service provider based outside of the UK for the processing of personal data where this is strictly necessary to facilitate our services to you. In all cases, we will ensure service providers are fully compliant with GDPR, or deemed equivalent, ahead of transferring any personal data.

3. WHAT PERSONAL DATA DOES THE FIRM COLLECT AND WHY?

In the course of providing products/services to you, the Firm may collect information that is considered personal information (e.g. name, contact details, address, passport number, driving licence, diversity data such as gender, race, age).

As a client, contact, employee or Partner of Decagon, we will require some personal information in order to verify your identity and have the applicable relationship with you.

Some of this information may be required to satisfy legal obligations (e.g. to comply with obligations arising under the money laundering regulations, whereas other information may be required in connection with the provision of services to you or the Firm’s provision of services to its clients).

The information collected will vary depending on the service the Firm provides to you or you provide to the Firm, but typically includes:

• Personal information: such as your name, date of birth, passport number or national insurance number
• Contact information: including your address, telephone number and email address
• Equal opportunities information: including but not limited to racial or ethnic origin, gender, religious or philosophical beliefs.

4. WHERE DOES THE FIRM STORE MY PERSONAL DATA?

The Firm has comprehensive policies and procedures in place to ensure your personal data is kept safe and secure, with these including:

• Access to data is limited to authorised individuals
• Firewalls
• Intrusion detection
• 24/7 physical protection of the facilities where your data is stored (i.e. Microsoft’s UK data centres).

5. HOW LONG DOES THE FIRM RETAIN PERSONAL DATA?

As a regulated entity, the Firm is required to maintain its books and records for a prescribed period (five years from either the ceasing of a business relationship, or, in the case of non-clients, from the making of a record. Alternatively, for seven years, where specifically requested to do so by the FCA).

As such, information that falls in scope of either of these requirements is retained in line with the mandated timeframe.

Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.

6. HOW HAVE I BEEN CATEGORISED IN ACCORDANCE WITH GDPR?

The GDPR requires the Firm to inform you of the legal basis on which we maintain your personal data.

Typically, the Firm will reach out to you personally to confirm this; however, as a general rule, the following is applicable:

• Clients: information is maintained on the basis of contractual obligation and/or legitimate interests (where relevant)
• Service providers: information is maintained on the basis of contractual obligation
• Database/marketing contacts: information is maintained on the basis of legitimate interest.
• Employee and partners information is maintained on the basis of contractual obligations and legitimate interest and for equality monitoring purposes (which would include “sensitive personal data” as defined under GDPR).

7. WHAT ARE MY RIGHTS?

Once you have provided your details to the Firm, you have certain rights which apply, depending on your relationship with the Firm, the information you have shared with us and the Firm’s legal and regulatory obligations.

You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email the Firm at ocooper@decagonam.com. The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.

You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.

You have the right to request that any information the Firm holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as “data portability”.

You have the right, as a client, to ensure that your personal information is accurate and up to date, or where necessary, rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact the Firm at ocooper@decagonam.com

You have the right to object to your information being processed, for example for direct marketing purposes.

You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.

You have the right to object to any decisions based on the automated processing of your personal data, including profiling.

You have the right to decline to provide any data that the Firm requests from you that would be categorised as “sensitive personal data”.

You have the right to lodge a complaint with the Information Commissioner’s Office if you are not happy with the way that we manage or process personal data (https://ico.org.uk/concerns).

8. WILL I BE NOTIFIED OF CHANGES TO THIS POLICY?

The Firm may, from time to time, review and update this policy.

The Firm will maintain the latest version of this policy on its website, and where the changes are deemed material, it will make you are aware of these.

9. WHO SHOULD I DIRECT QUESTIONS TO?

If you have any questions, concerns or complaints about the practices contained within this document or how the Firm has handled your data, please email: ocooper@decagonam.com.

Alternatively, you may write to:
Decagon Asset Management LLP
5 Swallow Place
London
W1B 2AF