Privacy policy

Geminiglobalasset prioritizes the protection of your personal information and privacy. We have implemented an extensive privacy notice and policy designed especially for investors to further emphasize our commitment to this. You can be guaranteed that, with the exclusions listed below, we never give personal information about our clients or past clients to outside parties.

We obtain personal information from a variety of sources, such as our communications with you, any documents you may provide, and when we provide advisory services. Providing consulting services, creating accounts, enabling transactions, and taking part in activities that further our company goals are all examples of how this personal data is used. Please read the rest of this policy for a comprehensive understanding.

Access to your personal information will only be granted to our staff members and employees in situations where it is necessary for us to provide you with goods or services. Strict precautions are taken, such as technological, procedural, and physical security procedures that comply with national, state, and local laws and norms. We think these security measures are strong enough to stop any unwanted disclosure of your personal information. They are intended to protect your personal data.

The parts that follow in this policy contain more details about our privacy policies, the purposes and means for processing or exchanging your personal data, and how we comply with applicable privacy and data protection laws.

This is a shared document for informational purposes only; no reaction is required. If you have any questions, though, please don't hesitate to contact us using the information below. We value your privacy above all else, and we're here to answer any questions or concerns you may have about how your personal information is handled.

Why You Encounter This Policy:

• You provide us with specific personal information if you are an investor in one or more funds or accounts that Geminiglobalasset manages or advises. This information may be related to you personally or, in the event of a corporate organization, to your designated representative, contact person(s), employee(s), trustee(s), nominee(s), agent(s), and/or ultimate beneficial owner(s). Information pertaining to an identified or identifiable natural person is the only category of data considered personal for the purposes of this policy.
• Our goal is to make it clear how and why we use, keep, and handle your personal information when you interact with us or our affiliated businesses.

Motivation for Publishing This Policy:

This policy has been prepared and is being presented on behalf of Geminiglobalasset, the general partners of any fund for which it manages investments, and any linked organizations that handle, process, or have control over personal data now or in the future.

The terms "we," "us," and "our" in relation to this policy relate to Geminiglobalasset. The funds, usually through their general partner or investment manager, take on the role of a data controller for some or all of your personal data when you share it with us. Said another way:

• We safeguard the privacy of your personal information by managing it.
  
• Based on the information we have shared with you or as allowed by law, we make judgments about how to use and protect your personal data. We are dedicated to protecting and honoring your right to privacy.

Certain entities inside Geminiglobalasset may have the role of data processor.

The Private Information We Acquire About You:

The type of investor and the particular investment at hand determine the parameters surrounding the gathering and exchange of personal data. Some examples of the personal information we might get are:

• Name, home address, phone number, email address, and, if relevant, tax information are all considered forms of contact.
• Resources and investment expertise combined with past transactions and risk tolerance.
• Investment activity, past performance information, and possible accounts with other organizations.

We might need to process particular categories of personal data as outlined by the General Data Protection Regulation (GDPR), which includes criminal convictions and offenses, in order to comply with regulatory requirements like AML-KYC. Your personal information is collected with the intention of strengthening our capacity to deliver exceptional service to you and advancing our commercial relationship. In some cases, we might combine the personal information you provide with information that we have either gathered offline or from you online. Below is more information about how this personal data is shared with third parties.

Corporate entities are required by law to treat personal data in accordance with the GDPR framework and to send said data to the data controller. This includes the obligation, in compliance with the GDPR framework, to notify the pertinent parties about the content described in this section.

Sources of Information Acquisition:

We obtain your personal information through a number of sources, including direct contributions from you.

• The Personal Information We Gather and How We Get It: Your personal information: Collected from tax returns, subscription paperwork, and other related documents filled out throughout the investment subscription procedure. Name, address, date of birth, passport data, national identifiers, driver's license, national insurance or social security number, income, work history, and investment-related information are a few examples of the information that may be included in this. Furthermore, information is gathered from you when you give it to us via emails, chats, or bank account information for fund-related activities.
• Personal information gleaned from third parties: publicly accessible databases, credit agencies, fraud prevention and control organizations, tax authorities (including those outside the United Kingdom and the European Economic Area), background check companies, bankruptcy registrations, and governmental and regulatory entities.

Motivations for Gathering and Handling Data:

• Contractual obligations: Essential to carrying out our agreement with you, such as setting up, managing, and overseeing fund investments, offering consultation services, completing transactions, and making sure that fund investors' contractual obligations are met.
• Respect for laws and regulations: necessary for upholding legal or regulatory requirements, including Know Your Customer (KYC), anti-money laundering (AML) checks, investor due diligence, verification, compliance with Common Reporting Standard (CRS) obligations, investor and beneficial owner identity verification, answering requests from regulatory bodies, audits, statutory register maintenance, and fraud prevention while abiding by sanctions laws.
  

Your Rights When It Comes to Processing Data:

• For marketing purposes: Direct marketing is something you can choose not to get. We shall stop using your data for marketing if you object to the processing of your personal information.
• Monitoring and surveillance: In order to safeguard our company's operations and the security of our systems, we monitor communication as mandated by law, regulatory requirements, or other duties.

Please get in touch with us if you would like more information or to make use of your rights. We value your preferences regarding privacy.

With whom we disclose the acquired data:

As required by applicable laws or regulations, as well as for regular business operations, the personal information we collect may be shared with other parties. Among these beneficiaries are:

• Partners, advisers, and investment managers connected to Geminiglobalasset.
• Fund managers include depositories, administrators, and custodians.
• tax authorities as well as pertinent service suppliers.
• counterparties and their legal counsel, as well as providers of hedging and financial services.
• Attorneys, accountants, auditors, and other advisors, especially those connected to Geminiglobalasset.

Under unusual situations and in accordance with legal requirements, your personal information might be shared with:

• governmental, prosecutorial, and regulatory organizations as well as their global litigation counterparts.
• agencies and organizations as mandated by law.

Giving Us Your Personal Information:

When we get your personal information directly, we'll say if

• Making provisions is required to comply with the law.
• There are no repercussions if you decide not to provide it; it is completely voluntary.

Presume that we need the data for commercial or compliance reasons unless otherwise specified. We need to provide the needed data in order to complete our end of the contract. Our ability to manage your investment and provide services may be impacted if you do not give this information.

International Data Transfers:

Personal information may be shared with Geminiglobalasset organizations, partners, and third-party service providers—some of whom may be based outside of the European Economic Area, Jersey, or Luxembourg—that have different data protection regulations. In these situations, we put in place the proper measures and look for agreements in contracts to protect confidentiality and use data only for those purposes.

Consent and Withdrawal:

Although we often rely on legal justifications for processing, you have the right to revoke consent at any moment if it is requested.

Retention and Deletion:

For the sake of our business, our contractual duties, or legal requirements, we keep personal data on file. When data is no longer required, it is destroyed.

Your Rights:

You have rights regarding data protection under GDPR, including the ability to view, restrict, and correct missing or erroneous data. You can also request to stop processing data, and in certain cases, delete it.

Concerns or Queries:

We appreciate your concerns and urge you to share them with us. We are here to provide any more information or clarity.

Get in touch with us:

Please email us if you have any issues concerning this policy or your personal information.

Modifications to the policy:

This policy is evaluated on a regular basis, and any modifications that may come up in the future will be announced directly to investors on this page.