We at Doxa Partners LLP (”the Company”) respect your privacy and are aware that we expected to handle all personal data responsibly. We have developed this Policy to describe what types of information we gather, how this information is used, with whom it is shared and why, and to ensure that the Company complies fully with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (the "General Data Protection Regulation" or "GDPR").
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Notice
This privacy notice aims to give you information on how Doxa Partners LLP collects and processes your personal data, whether through this website or through our exchanges with you.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Doxa Partners LLP is a data controller and responsible for your personal data (referred to as the Company, "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing question in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below:
Full name of legal entity: Doxa Partners LLP
Postal address: 35 Grosvenor Street, London W1K 4QX
Please contact us if you have any questions regarding our policy, have a specific request or want to exercise any rights
Changes to the Privacy Notice and Your Duty to Inform us of Changes
This version came into effect in July 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of “personal data “about you which we have grouped together follows:
Identity and Contact Data includes name, email address, phone number, and gender.
Employment data: includes any information you provide from your CV and from website forms regarding your employment history, qualifications, past salary and right to work status
Test data: if you take our online test, we will hold the answers you provided to our test
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or calculate the percentage of users coming from a particular advertising source. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect Personal Data from and about you including through:
Website applications and interaction
Email, telephone and postal correspondence
Meetings in person
Third parties such as recruiters where you have given consent for your data to be shared
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you or your employer and processing your personal data is necessary for such performance (e.g. where your email identifies you in person or where we are given access to your mobile or home telephone numbers) or to take steps at your request before entering into a contract with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interests are the interest of our business in conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we need to comply with a legal or regulatory obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data.
As an Investment Manager, it is in our legitimate interest to decide whether to employ candidates and to maintain relationships with suppliers, partners and clients and their related organisations.
Updates to this policy
If we make any changes to our privacy notice in future, it will be posted on this page. Please check this page frequently for any updates.
DISCLOSURES OF YOUR PERSONAL DATA
We may disclose your personal data:
where you are providing this to us specifically for the purpose of a job application that you are making to a third party using our online recruitment test, to such third party. We require that such third party will only use and process your personal data for the purposes of evaluating your job application or otherwise as required by law, and to store such personal data securely
to other third parties (e.g. IT service providers, professional advisors, HMRC, Home Office) where this is required for business administration or operational purposes or in law
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, or as required in law.
We have put in place appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available upon request.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data, such as the right to:-
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
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.
Time Limit To Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Disclaimer: Doxa Partners LLP (“Doxa”) is an Appointed Representative of Privium Fund Management (UK) Limited (“Privium”) which is authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom. The content of this website is for information only and is not intended to be independent investment advice/research. The investment services of Doxa are only available to professional clients and eligible counterparties for the purposes of the FCA’s rules. They are not available to retail clients. It is not an invitation to buy or sell an investment and is not advice on taxation or on any other matter. This information is not intended to be used by or distributed to any person or entity in a jurisdiction or country where this would be contrary to local law or regulation. We believe the information on this website is based on reliable sources, but its accuracy cannot be guaranteed. The opinions expressed represent our views at the time of publication and are subject to change. Neither Privium nor Doxa will be liable for any losses relating to the accuracy, completeness or use of information on this website. Past performance may not predict future results and the capital value of investments and the income generated can fluctuate. Where investments are exposed to currencies other than the base currency of the managed account, they may be subject to foreign exchange rate fluctuations.