Blue Diagonal is committed to protecting your privacy and maintaining the confidentiality and security of your personal information, and is committed to the principle that a citizen's personal data belongs to them and not to the organisation collecting it. Blue Diagonal complies with the provisions of GDPR both in its capacity as data controller of its client's personal data and data processor of its client's personal data, and we require all Data Processors that we engage pursuant to binding contractual arrangements to be GDPR compliant as of 25 May 2018.
Blue Diagonal has a GDPR Policy, which includes a breach notification process and policies for protection of the rights of Blue Diagonal's data subjects, including the right to erasure and the right to data portability. This privacy notice explains the main aspect in which Blue Diagonal collects, utilizes and maintains nonpublic personal information about its clients and investors ("Clients"), as required under Cyprus Law pursuant to GDPR.
"Blue Diagonal" collectively refers to Blue Diagonal Capital Ltd, Blue Diagonal Variable Capital Investment Company PLC, and each investment account, partnership, limited liability company or funds for which they serve as investment manager, investment advisor, general partner, managing member and/or director. As noted above, this Privacy Notice only applies to products and services provided by Blue Diagonal to individuals (including regarding investments in the Funds).
I. COLLECTION OF CLIENT INFORMATION
Personal data is collected for specified, explicit and legitimate purposes, and will not be further processed in a manner that is incompatible with those purposes, and the data collected will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Blue Diagonal collects personal information about its Clients from the following sources:
Application forms, Client Profile Questionnaires, account forms, and other information provided by the Client in writing, in person, by telephone, electronically or by any other means. This information includes name, address, employment information, and financial and investment qualifications;
Transactions within the funds the company manages, including account balances, investments, withdrawals/ redemptions and fees;
Other interactions with Blue Diagonal (for example, discussions with our staff); and
Verification services and consumer reporting agencies, including a Client’s creditworthiness or credit history. (Blue Diagonal generally utilise these services prior to the establishing of a business relationship.)
All reasonable steps will be taken by the company to ensure and maintain the accuracy of the personal data that it collects.
II. DISCLOSURE OF NON-PUBLIC PERSONAL INFORMATION
Personal information will be processed by the Company and other third party delegates, agents and data processors including the company’s money-laundering compliance officer (“MLCO”), Administrator, Manager, Investment Manager, Depositary and in accordance with GDPR and the Cyprus Data Protection Law. Personal information will be processed for the purposes of carrying out services on behalf of the company and to comply with legal obligations including legal obligations under company law and anti-money laundering legislation. The company or its data processors will disclose personal information to third parties where necessary to ensure the company is in compliance with its regulatory obligations. This may include disclosure to third parties such as auditors and the Regulators or the company’s data processors or their agents who process the data for anti-money laundering purposes or for compliance with other regulatory requirements.
Blue Diagonal (including its delegates), the Administrator, the Investment Manager and its/or their duly authorised agents and any of their respective related, associated or affiliated companies may share nonpublic personal information, without a Client’s consent, with affiliated and non-affiliated parties in the following situations, among others,
holding, using, disclosing and processing the data to manage and administer any holding in Blue Diagonal and any related accounts on an on-going basis;
holding, using, disclosing and processing data for any specific purposes where the Client has given consent to do so;
holding, using, disclosing and processing data to carry out statistical analysis and market research; and
- holding, using, disclosing and processing any data to comply with legal and/or regulatory requirements applicable to the Company and the Client;
Blue Diagonal does not transfer personal data to countries outside of the EEA in the normal course of business.
III. FORMER CLIENTS
The same Privacy Notice applies to former Clients.
IV. PROTECTION OF CLIENT INFORMATION
Blue Diagonal maintains policies in respect of the physical, electronic and procedural safeguards to protect client information including policies that restrict access to the personal and account information of clients to those employees and or delegates who need to know that information in the course of their job responsibilities.
V. FURTHER INFORMATION
Blue Diagonal reserves the right to change this Privacy Notice at any time to remain compliant with GDPR. The examples contained within this Notice are illustrations and extracts from the company's GDPR policy, and are not intended to be exclusive. All individuals have the right to obtain , on request, confirmation as to whether their data is being processed, including:
The purpose of the processing, including the recipients of the data;
The retention periods;
The existence of the right to request rectification or erasure, or to object to the processing;
The right to lodge a complaint with the Data Protection Supervisory Authority;
In the case of automated processing, the details of profiling;
- Information on the sources of the data.
The company will provide the information requested without undue delay, and at the latest, within one month month of the receipt of the request.
A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We may use both “session” cookies and “persistent” cookies on the website. We may use the session cookies to keep track of you whilst you navigate the website and the persistent cookies to enable our website to recognise you when you visit. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites.