Privacy Policy

1. INTRODUCTION

Temporis Capital Limited (“Temporis”, “we”, “our” and “us”) is committed to protecting the
privacy and security of the Personal Data that we hold.
This notice is intended to explain how we collect, use and protect your Personal Data.

2. WHO WE ARE

Temporis is a UK based investment manager authorised and regulated by the Financial
Services Authority.
Temporis is committed to handling Personal Data fairly and lawfully and takes its data
protection obligations very seriously. Temporis ensures that it processes Personal Data in
compliance with applicable data protection laws, including without limitation, the General Data
Protection Regulation 2016/679 (“GDPR”).

3. WHAT IS PERSONAL DATA AND WHAT DATA DOES TEMPORIS HOLD?

We define Personal Data as “data relating to living, identifiable individuals”. The information
we collect and hold can be categorised as follows:

Employees and Prospective Employees – includes, but is not limited to, contact details,
identification information, bank account details, background checks, employment history,
performance information, remuneration, healthcare and pension arrangements.

Clients and Prospective Clients – in relation to our individual clients, includes, but is not
limited to, contact details, identification information, bank account details, background checks,
transaction histories etc. For our corporate clients, includes but is not limited to the names,
and contact details of the individuals we interact with together with background and
identification information of Directors and Officers that we are required to collect for regulatory
purposes. For our prospective clients, primarily includes names and contact details but if being
on-boarded could also include other information as described above.

Service Providers, Suppliers and Contractors – the names and business contact details of
the individuals we interact with at our service providers, suppliers and contractors together
with background and identification information that we are required to collect.

Other Business Partners / Contacts (e.g. banks, brokers, registrars, lawyers, accountants,
actuaries, regulators, HMRC, investee companies, managing agents etc) – the names and
business contact details of the individuals we interact with at these entities together with
background and identification information that we are required to collect.

4. HOW IS PERSONAL DATA COLLECTED?

Temporis uses different methods to collect Personal Data including the following:
• personal details provided directly by employees, clients, suppliers & contractors and
other business contacts; and
• information from third parties and publicly available sources e.g. Companies House,
Registrars and Background Check Providers.
It should be noted that the Temporis website does not capture or record any Personal Data
relating to website users/visitors.

5. HOW DO WE USE PERSONAL DATA?

The Personal Data we obtain and hold is used to enable us to:
• provide investment, management and administration services to our clients;
• fulfil our contractual and other obligations to employees, suppliers, contractors and
other business partners; and
• meet our legal and regulatory obligations.
Under the GDPR a firm must have a legal basis / justification for processing data. In the vast
majority of instances, Temporis will have one of the following justifications:
• Performance of a contract;
• Compliance with legal obligations; and
• Legitimate business interests – in this instance the processing must be “necessary”
and must balance the interests of the controller with the rights of the individual.
We may combine the Personal Data that we collect from Data Subjects with information
obtained from other sources to the extent permitted by law.
It is important that the Personal Data we hold is accurate and current and therefore the Data
Subject should advise us as soon as possible in the event of any changes.

6. TO WHOM DO WE DISCLOSE PERSONAL DATA?

We will only use a Data Subject’s Personal Data for our internal business purposes. This
includes the provision of marketing related correspondence to the Data Subject on our
products and services.
We do not sell any Personal Data to third parties and we do not share Personal Data with third
parties for the third parties’ marketing purposes.
However, we may need to disclose Data strictly on a need to know basis to our service
providers, contractors, suppliers and other parties such as banks, brokers, registrars, lawyers,
accountants, actuaries, regulators and HMRC.

7. WHAT DO WE DO TO KEEP PERSONAL DATA SECURE?

We have put in place appropriate physical and technical measures to safeguard the Personal
Data we collect in connection with our services. In addition, we limit access to Personal Data
to those employees, agents, contractors and other third parties who have a business need to
know. They will only process Personal Data on our instructions and are subject to a duty of
confidentiality.
However, please note that although we take appropriate steps to protect Personal Data no
device, computer system, transmission of data or wireless connection is completely secure
and therefore we cannot guarantee the absolute security of Personal Data.

8. INTERNATIONAL TRANSFER OF DATA

The Personal Data that we collect may be stored and processed in the European Economic
Area (“EEA”) or transferred to, stored at or otherwise processed outside the EEA.
Where Personal Data is transferred outside the EEA we will take all steps reasonably
necessary to ensure that the Data is kept secure and treated in accordance with this Privacy
Notice and the requirements of applicable law wherever the data is located. Appropriate
transfer agreements and mechanisms (such as the EU Model Clauses) will be put in place to
help ensure that our third party service providers provide an adequate level of protection for
Personal Data. We will only transfer Personal Data outside the EEA in accordance with
applicable laws or where the Data Subject has given us consent to do so.

9. DATA RETENTION – HOW LONG IS PERSONAL DATA STORED / KEPT?

Temporis retains Personal Data for as long as necessary to fulfil the purposes for which the
Data has been collected as outlined in this Privacy Notice unless a longer retention period is
required by law. Data is kept under regular review to ensure that it is not held longer than is
strictly necessary, whilst taking account of Temporis’s other regulatory obligations such as the
requirement to retain evidence of anti-money laundering checks.
When Personal Data is no longer required for the purpose it was collected or as required by
applicable law, it will be deleted or in certain circumstances returned to the Data Subject in
accordance with applicable law.

10. ACCESSING PERSONAL DATA AND OTHER RIGHTS THAT A DATA SUBJECT HAS

Temporis will collect, store and process Personal Data in accordance with the Data Subject’s
rights under the GDPR. Under certain circumstances the Data Subject has the following rights
in relation to their Personal Data:
• the right to request details of their Personal Data held by Temporis and to request copies
of such information;
• where Temporis’s use of Personal Data is based upon their consent, the right to
withdraw such consent at any time;
• the right in certain circumstances to request Temporis to port (i.e. transmit) their
Personal Data direct to another organisation;
• the right to request Temporis to rectify or update any Personal Data that is incorrect or
complete;
• the right to have Personal Data erased in certain specified circumstances;
• the right to request Temporis to stop processing their Personal Data and to only store
such Data;
• the right to object to specific types of processing of Personal Data, for example where it
is being used for the purpose of direct marketing; and
• the right in certain circumstances not to be subject to decisions being taken solely on the
basis of automated processing (e.g. profiling).

11. HOW CAN A DATA SUBJECT ENFORCE THEIR RIGHTS?

In the event of a Data Subject wishing to enforce any of their rights under the GDPR then
please use the contact details at section 14. A response to the request will be made without
undue delay and no later than one month from receipt of such a request. We will not charge
a fee for processing such a request.
If a Data Subject is concerned that we have not complied with their legal rights under
applicable Data Protection Laws, they may contact the Information Commissioner’s Office
(www.ico.gov.uk) which is the data protection regulator in the UK. Non-UK Data Subject’s may
contact their local data protection supervisory authority.

12. THIRD-PARTY LINKS AND PRODUCTS ON OUR SERVICES

Our websites, applications and products may contain links to other third-party websites that
are not operated by Temporis, and our website may contain applications that can be download
from third parties. These linked sites and applications are not under Temporis’s control and
as such, we are not responsible for the privacy practices or the content of any linked websites
and online applications. If a user chooses to access any third-party websites or applications,
any Personal Data collected by the third party’s website or application will be controlled by the
Privacy Notice of that third party. We strongly recommend that you take the time to review the
privacy policies of any third parties to which you provide Personal Data.

13. CHANGES TO THIS PRIVACY NOTICE

We will update this Privacy Notice from time to time and hence it is important to check the
“Date Notice Last Updated” legend at the bottom of this Notice. Any changes will become
effective upon posting the revised Privacy Notice on our website.
We will provide notice to Data Subjects where any of the changes are material and, where
required by applicable law, we will obtain your consent. We will provide this notice by e-mail
or by posting notice of the changes on our website.

14. CONTACT US / FURTHER INFORMATION

If you have any questions concerning the content of this Privacy Notice, including any requests
to exercise your legal rights, the relevant contact details are set out below.

Contact details

Name of Contact: Mark Lawson
Position: Compliance Officer
Email address: Mark.lawson@temporiscapital.com
Postal address: Temporis Capital Limited, Berger House, 36-38 Berkeley Square, London,
W1J 5AE

Date Notice Last Updated – 30th June 2019

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