Odey Asset Management LLP, Odey Wealth Management (UK) Limited, Odey Wealth Management (C.I.) Limited, Odey Asset Management Group Limited and the funds and accounts managed by us (“Odey”) each act as a data controller and/or data processor in respect of your Personal Data for the purposes of the European Union’s General Data Protection Regulation (including as applicable in the United Kingdom, where it is supplemented by the Data Protection Act, 2018) and, where relevant, the Cayman Islands’ Data Protection Act, (Revised) (“Data Protection Law”). Odey is responsible for ensuring that it uses your Personal Data in compliance with Data Protection Law.
All service providers appointed by Odey to process Personal Data (“Data Processors”) will process Personal Data provided in accordance with Odey’s instructions and Odey will act as the Data Controller of any such Personal Data.
This Privacy Notice applies to you if:
This Privacy Notice sets out the basis on which Personal Data about you will be processed by us.
The term “Personal Data” under Data Prospection Law is defined as:
“any information relating to an identified or identifiable natural person ('Data Subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
We might process the following Personal Data about you:
Your personal data may be stored and processed by us for the following purposes:
We are entitled to process your Personal Data in these ways for the following reasons:
We may from time to time, in accordance with the purposes described above, disclose your Personal Data to other parties, including our funds’ administrators and their affiliates, professional advisers such as law firms and accountancy firms, other service providers, including technology service providers, counterparties, other fund managers in connection with a transfer of your investment to a fund to be managed by a third party manager and courts and regulatory, tax and governmental authorities. These entities will process your Personal Data in accordance with our instructions and will themselves be responsible for their use of your Personal Data under Data Protection Law.
Your Personal Data may be transferred to and stored by entities outside the European Economic Area (the “EEA”) the United Kingdom (“UK”) or the Cayman Islands, such as service providers to Odey or fund administrators.
Where Personal Data is transferred outside the EEA, the UK or the Cayman Islands, we will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted under applicable law. For example, the country to which the Personal Data is transferred may be approved by the European Commission, the recipient may have agreed to model contractual clauses approved by the European Commission that oblige them to protect the Personal Data,.
You can obtain more details of the protection given to your Personal Data if it is transferred outside the EEA, the UK or the Cayman Islands, including a copy of any standard data protection clauses entered into with recipients of your Personal Data, by contacting us using the details set out below.
The provision of certain Personal Data is necessary for shares in an Odey fund to be issued to any applicant and for compliance by the fund and its service providers with certain legal and regulatory obligations. Accordingly, if certain Personal Data is not provided when requested or withdrawn, an application for shares might not be accepted or shares might be compulsorily redeemed.
How long we hold your Personal Data for will vary. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which we have to keep your Personal Data).
You have a number of legal rights in relation to the Personal Data that we hold about you. These rights include the following:
You can exercise your rights by contacting us using the details set out under “Contacting Us” below. You can find out more information about your rights by contacting an EU data regulator such as the UK’s Information Commissioner’s Office, or by searching their website at ico.org.uk.
If you would like further information on the collection, use, disclosure, transfer or processing of your Personal Data or the exercise by us of any of the rights listed above, please address questions and requests to: firstname.lastname@example.org or call us on 020 7208 1400.
Updated September 2023