Privacy Notice

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Privacy Notice

General

The information in this notice is provided for visitors to my website. If you are looking for specific information about how we process information about investors in our funds or other investment products, please see our privacy notice for investors in MKTimothy funds below. If you are in the network of MK Timothy employee, MK Timothy may store and use your personal data for internal business purposes

If you submit information about yourself through this website - for example, by sending an email to one of the addresses displayed on the site - we will only use your information for the intended purpose or purposes for which it has been provided. For example, we will use it for the purposes of responding to your enquiry or if your enquiry requires investigation or research on our part, then to facilitate such purposes. I may also store your information for our internal business purposes (for example, to improve the site and our services generally). We will not disclose your information to other persons outside MK Timothy, except: (i) to service providers, investment advisers, professional advisors and their respective agents and/or employees under strict confidentiality obligations; (ii) exceptionally, where we are required to make the disclosure by law, in connection with legal proceedings or otherwise upon governmental or regulatory request; or (iii) where we believe it is necessary or appropriate to protect the rights or property of MK Timothy.

If, as a consequence of contacting MKTimothy, we use your details to send you information about MK Timothy which we believe may be of interest to you (other than in response to your original query), you will have the opportunity to tell us that you do not wish to receive that information. Alternatively, you may contact MK Timothy at [email protected] and ask us not to contact you for such purposes and/or not to provide you with such information.

As MKTimothy uses a common IT environment, when you provide information to MKTimothy it may be accessed by authorised persons within MKTimothy from countries whose laws provide various levels of protection for personal data which may not be equivalent to the level of protection that is provided in member states of the European Economic Area. MK Timothy maintains appropriate organisational and security management systems to protect your personal information throughout our organisation.

Some of the affiliates of MK Timothy are authorised firms that are required to record telephone calls. Recordings of telephone calls will be stored only for as long as required by law and will not be used for any other purpose except as may be required in connection with legal proceedings or otherwise upon governmental or regulatory request.

We do not seek to identify visitors to this website. However, we generally record certain usage information such as the number and frequency of visitors to this site. The information I may collect may include the websites that you access immediately before and after you visit our site, the internet browsers you are using and your IP address. If we use such data at all, it will be on an aggregate basis and we will not disclose to any third party, other than IT providers, any information that could be used to identify you personally, except as may be required by law, in connection with legal proceedings or otherwise upon governmental or regulatory request. This website uses cookies - small data files which are downloaded on your hard disk so that the site can monitor your access to the site and recognizes that you have visited the site before, without identifying you. For more information, please refer to MKTimothy’s Cookie Policy which can be found here. If you don't want to accept cookies, you should read the information that came with your browser software to see how you can turn off the automatic download feature.

We welcome suggestions and comments about the site and our business. As noted above, we will only use your information in relation to a suggestion or comment for the purpose which it was provided and shared in accordance with the policy described above.

You have the right to see a copy of the information that we hold about you and have information that we hold about you corrected or deleted. You may also object to the processing of our information where we process your data on legitimate grounds. If you wish to do so, please contact us at: [email protected]

1. This Notice

This Notice is provided by MK Timothy AB on behalf of itself and his various divisions, branches, subsidiaries, affiliates and any other MKTimothy associated entities (collectively, “MK Timothy” or “we”, “us” or “our”). This notice is provided for the benefit of natural persons (excluding those working for, or within, our organisation) with whom we interact in the course of conducting our business. This includes people who view my website or make contact with us through the website, investors and prospective investors in our various funds or investment vehicles, individuals acting for, or on behalf of, or otherwise providing us with personal data in connection with actual or prospective institutional investors in such funds or investment vehicles and all other persons with whom we interact in the course of our business (“you”).

MK Timothy manages a dynamic alternative investment fund business and this Notice is expected to be updated from time to time, e.g., if there are changes in law, or to reflect other changes in our policies and procedures with respect to our handling of your personal data. If you have an ongoing business or investment relationship with MKTimothy, we encourage you to visit my website regularly to review any changes to this Notice.

You may contact MK Timothy if you have any queries about this Notice or his currency – please see the contact details below.

2. Data Protection Terminology

Certain words are given specific meanings under data protection legislation. Please note that those divisions, branches, subsidiaries and affiliates of MKTimothy located within the EEA are subject to the GDPR (as defined below), but if you are not resident in the EEA, there may be other laws in your country that are different. Other laws may use different or additional legal terms, or define the same terms differently. The terms listed below are intended to have the following meanings in this Notice:

“adequacy decision” means a decision of the European Commission determining that a country outside the EEA ensures an adequate level of protection for personal data;

“criminal offences data” means personal data about any actual or alleged criminal convictions or offences related security measures;

“data controller” means the MKTimothy entity that decides how and why personal data is processed;

“EEA” means the member states of the European Economic Area;

“EU data protection laws” means all laws and regulations relating to the protection of personal data applicable in the EU, the EEA and, if outside the EU, the UK, including: the Data Protection Directive (95/46/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Data Protection (Processing of Sensitive Personal Data) Order 2000, Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), and any other applicable legal requirement concerning the protection and processing of personal data;

“personal data” means information from which it is possible to identify a natural person (an individual), or information from which any individual is identifiable;

“processing” means anything that is done with personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“processor” means the person or entity that processes personal data on behalf of a data controller; and

“sensitive personal data” means personal data about an individual’s race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, criminal offences or any other information that may be deemed to be sensitive under applicable law.

3. Who controls the data we collect?

The general partner of any MKTimothy investment fund in which you are invested is a data controller. If the general partner has engaged a fund manager, an investment adviser, or the investment manager has itself engaged a portfolio manager, these additional entities may also process your data will act as independent data controllers.

4. From whom do we collect personal data?

MKTimothy collects your personal data from a variety of sources:

a) when you provide it to us, e.g., in telephone conversations, in voicemails, through written correspondence, or via e-mail;

b) when you engage in business with us, e.g., by subscribing to a fund or investment vehicle (including, in the case of an investment relationship, providing applicable any anti-money laundering identification, verification documentation, and source of funds information), responding to an investor questionnaire, requesting treatment as a professional client, etc.;

c) when you visit my website, including any registration information or information captured via “cookies”;

d) when it is available in the public domain, e.g., on the internet, in books, journals, magazines, news reports, in public directories, registries, or any other source available to the public; and

e) when we receive information about you from third parties e.g.:

tax authorities, including those that are based outside the UK and the EEA if the relevant applicant for interests in an MKTimothy fund or other investment vehicle is subject to tax in another jurisdiction;
governmental and competent regulatory authorities to whom I may have regulatory obligations;
credit agencies; and
fraud prevention and detection agencies and organisations.

The information collected in this fashion could relate to you, or your organisation, his officers, directors, partners, employees, shareholders, ultimate beneficial owners or affiliates or to any other data subjects.

MKTimothy may also create personal data by combining or organising our records, or combining information you have provided with information received from other sources. This will include information collected in an online or offline context.

5. What data do we collect?

The types of personal data we collect and share may depend on the nature of your relationship with MKTimothy. With respect to an investment in an MKTimothy fund or other investment vehicle, I may process the following categories of personal data:

a) names, dates of birth and birth place;

b) contact details and professional addresses (including physical address, email address and telephone number);

c) account data, payment instructions, and other information contained in any document you provide to MKTimothy (whether directly or indirectly, e.g., through a financial adviser);

d) risk tolerance, transaction history, investment experience and investment activity, or if the decision to invest is made by individuals within your organisation, information about their experience, knowledge and expertise in investing in alternative funds;

e) information regarding your status under various laws and regulations, including social security number, tax status, income and assets;

f) accounts and transactions with other institutions;

g) information regarding your interest and holding in MK Timothy funds or other investment vehicles, including ownership percentage, capital investment, income and losses;

h) information regarding your citizenship and location of residence;

i) source of funds used to make the investment in the MK Timothy fund or other investment vehicle; and

j) anti-money laundering, identification (including passport and drivers’ license), and verification documentation and, if applicable, additional information for any individual regarded as a politically exposed person.

We will only process sensitive personal data, to the extent required by law, and then only with your express consent.

6. Why do we collect personal data?

MKTimothy needs a lawful basis to process your personal data. Depending on the nature of the data and your relationship with MKTimothy, there can often be more than one lawful basis for processing. The table below describes certain processing activities associated with an investment in an MKTimothy fund and the various lawful grounds for processing that data, including where personal data is provided in connection with an investment by an institutional investor in an MKTimothy fund or other investment vehicle: