Privacy Policy

This Privacy Policy sets out how personal data is collected, processed and disclosed in connection with Fundline PCC Limited (“Fundline”) and the Core Resilience Cell and the Regenerative Growth Cell (together the “Cells”), as well as any further cells using the Fundline structure.

This Privacy Policy is issued by Fundline in its capacity as data controller.

Our policy is to protect your privacy and your personal information. This Privacy Policy sets out the information we collect from you in order for you to use our services, how we manage that data and our reasons for holding it. We respect the confidentiality of your information and your right to privacy.

As a result of your investment (or an investment made by a person firm or entity with which you have a connection) in the Cells, your personal information may be provided to Fundline, Thornbridge Investment Management LLP (the “Investment Manager”), and Suntera (Guernsey) Limited (the “Administrator”). The Investment Manager and the Administrator may also be data controllers and, if so, are independent data controllers and not joint controllers. Fundline, the Administrator and the Investment Manager may process your personal information or such data in respect of your directors, officers, employees or beneficial owners.

As each of Fundline and the Administrator are entities incorporated in Guernsey, Fundline and the Administrator are obliged to comply with the provisions of the Guernsey data protection laws. References to “we” in this notice include Fundline, the Cells, the Investment Manager and the Administrator as the context requires.

This Privacy Policy should be read in conjunction with the Data Privacy Policy of the Administrator, which can be accessed at https://www.suntera.com/privacy-notice-clients.

Where we obtain your personal data:

Your personal data comprises the following categories:

• Information obtained from identification documentation (including name, contact details, nationality and national identify numbers (where applicable); employment history, income and personal wealth, tax status and tax identification numbers, marital status, date of birth; and bank account details. We primarily collect your personal data from the following sources:
  • from information which you or your authorised representative gives to us, including but not limited to:
  • information set out in any subscription agreement with Fundline (acting for and on behalf of the Cells); such other forms and documents as we may request that are completed in relation to the administration/management of any investment in the Cells
  • Client due diligence documentation as part of our regulatory requirements; and any personal data provided by you by way of correspondence with us by phone, e-mail or otherwise; personal data we receive from you or any third-party sources which may include: entities in which you or someone connected to you has an interest, your legal and/or financial advisors
  • Other financial institutions who hold and process your personal data to satisfy their own regulatory requirements; and credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements.

from information which you or your authorised representative gives to us, including but not limited to:

information set out in any subscription agreement with Fundline (acting for and on behalf of the Cells); such other forms and documents as we may request that are completed in relation to the administration/management of any investment in the Cells
client due diligence documentation as part of our regulatory requirements; and any personal data provided by you by way of correspondence with us by phone, e-mail or otherwise;

personal data we receive from you or any third-party sources which may include: entities in which you or someone connected to you has an interest, your legal and/or financial advisors

other financial institutions who hold and process your personal data to satisfy their own regulatory requirements; and credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements.
We may also collect and process your personal data in the course of dealing with advisers, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act.

Why we collect your Personal data:

Lawful grounds for processing:

• The Fund, the Administrator and the Investment Manager are entitled to hold and process your personal data on the following lawful grounds:
  • the processing is necessary for the legitimate interests of Fundline provided your interests and fundamental rights do not override those interests;
  • the processing is necessary to comply with our respective contractual duties to you under the terms of our subscription agreement with you and all supplemental agreements thereto;
  • to comply with the legal and regulatory obligations of each of Fundline, the Administrator and the Investment Manager;
  • (on exceptional occasions) where we have obtained your consent; and
  • (on rare occasions) where it is needed in the public interest.

Some of the grounds for processing described above will overlap and there may be several   grounds which justify our use of your personal data.

Inaccurate or Amended Information

• Please let us know if any of your personal data (including correspondence details) changes as soon as possible. Failure to provide accurate information or to update changed information may have a detrimental impact upon your investment, including the processing of any subscription or redemption instructions or the suspension of your account. Failure to provide information where the same is required for anti-money laundering, pursuant to automatic exchange of information agreements, or other legal requirements means that Fundline may not, or may no longer, be able to accept you as an investor in any of the Cells.

Purposes of Processing

• Pursuant to paragraph ‎2.1, Fundline, the Administrator and the Investment Manager may process your personal data for the purposes set out below (“Purposes“). Those based wholly or partly on our legitimate interests are set out in paragraphs ‎2.3.1 to ‎2.3.6 inclusive:
  • conducting credit reference checks;
  • to facilitate the opening of your account with Fundline, the management and administration of your holdings in the Cells and any related account on an on-going basis which are necessary for the performance of your contract with Fundline, including without limitation the processing of redemption, transfer and additional subscription requests, and the payment of distributions;
  • communicating with you as necessary in connection with your affairs and generally in connection with your investment in any of the Cells;
  • operating Fundline’s, the Administrator’s and the Investment Manager’s IT systems, software and business applications;
  • supporting our IT and business applications support teams, accounting, legal, reporting, internal audit and risk management, administrative, transfer, document storage, record keeping and other related functions, including but not limited to processing personal data in connection with Fundline and the Cells;
  • monitoring and recording telephone and electronic communications and transactions:
    • for quality, business analysis, training and related purposes in order to improve service delivery;
    • for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act); and
    • to enforce or defend Fundline’s, the Administrator’s and the Investment Manager’s respective rights, or through third parties to whom we each may delegate such responsibilities or rights in order to comply with a legal or regulatory obligations imposed on each of us;
  • disclosing your personal data (including identity and interest in the Cells to any bank, financial institution or other third party lender providing any form of facility, loan, finance or other form of credit or guarantee to Fundline or the Cells;
  • detecting and preventing crime such as fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanction on an ongoing basis (“Regulatory Assessments“);
  • facilitating the internal administration of each of Fundline, the Administrator and the Investment Manager and retaining your personal data as part of our Regulatory Assessments or future services entered into by you;
  • liaising with or reporting to any regulatory authority (including tax authorities) with whom Fundline is either required to cooperate or report to, or with whom it decides or deems appropriate to cooperate, in relation to an investment, and which has jurisdiction over Fundline and the Cells or its investments in a third country without the same or similar data protection laws as Guernsey or any EU member state (a “Third Country Without Adequacy“);
  • communicating with our professional advisers for the purposes of obtaining professional advice; and
  • conducting business analytics and diagnostics.

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where these are required or permitted by law.

• To the extent that such personal data contains special category data such as, for example: data relating to racial or ethnic origin, political opinion, religious or philosophical belief, trade union membership or criminal data then the processing of such data shall solely be for the purpose of complying with any duty imposed on Fundline and/or the Administrator and/or the Investment Manager by an enactment including, but not limited to, legislation and regulatory obligations relating to Anti-Money Laundering and Combatting the Financing of Terrorism and all other related legislation.
  • None of Fundline, the Administrator or the Investment Manager make decisions about you based on automated processing of your personal data.

Sharing personal data

• This means that the countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal information. However, to ensure that your personal data receives an adequate level of protection we will ensure that your personal data receives an adequate level of protection and will put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU laws and the laws of the Bailiwick of Guernsey on data protection, including the use of model contractual safeguards. If you require further information about these protective measures, you can request it from Fundline using the contact details in the “How to Contact Us” section below.

Retention of personal data

• Whilst we have taken every reasonable care to ensure the implementation of appropriate technical and security measures, we cannot guarantee the security of your personal data over the internet, via email or via our websites nor do we accept, to the fullest extent permitted by law, any liability for any errors in data transmission, machine, software or operating error or any other cause.

Your rights

• In limited circumstances we may approach you for your written consent to allow us to process certain particularly sensitive data or to use data for another purpose. Where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Data Protection@iag.co.gg. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

How to contact us:

If you have any questions about our use of your personal data, our retention procedures or our security processes, please contact Fundline@suntera.com.

Changes to this Policy

We reserve the right to amend this Privacy Notice at any time without notice, in which case the date of the policy will be revised.

Cookies Policy

Our website uses cookies. You consent to our use of cookies in accordance with the terms of this policy.
Cookies consist of small files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.

Cookies can be used by web servers to identity and track users as they navigate different pages on a website and to identify users returning to a website.

Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies on this website

We use both session cookies and persistent cookies on this website.

How we use cookies

Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies.

We may use the information we obtain from your use of our cookies for the following purposes:

• to recognise your computer when you visit our website;
• to track you as you navigate our website, and to enable the use of the some of the features on our website;
• to improve the website’s usability;
• to analyse the use of our website;
• in the administration of this website;
• to personalise content on our website for you.

Third party cookies

When you use our website, you may also be sent third party cookies. We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.

Blocking cookies

Most browsers allow you to refuse to accept 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;
• in Firefox you can block all cookies by clicking “Tools”, “Options”, and un-checking “Accept cookies from sites” in the “Privacy” box.

Blocking all cookies will, however, have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use many of the features of this website.

Deleting cookies

You can also delete cookies already stored on your computer. The method of doing so will depend upon your web browser. Instructions are available at the following URLs.
Internet Explorer: http://support.microsoft.com
Firefox: http://support.mozilla.com
Chrome: http://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647
Opera: http://help.opera.com/opera/Mac/2308/en/controlPages.html#manageCookies
Safari: https://support.apple.com/k