Silverbird ("the Silverbird", "us" or "we") is committed to protecting your data and information. We believe it is important to look after your data and ensure you retain control over how it is used.
This policy and any other Agreement between you and us set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by the Silverbird. We collect some Personal Information in the course of running our business, including but not limited to information provided through website contact forms, usage information and client information.
We are committed to ensuring that your data is processed fairly, lawfully, and in accordance with your rights under the General Data Protection Regulation (GDPR; EU2016/679) (1).
Please read the full Privacy Policy carefully to understand our policies and practices regarding your information and contact our Data Protection Officer at [email protected] if you have questions.
Terms used in this policy
Agreement – refers to any Agreement between yourself and the Fund
GDPR – General Data Protection Regulation
Personal Information – any information that can identify a natural living human
Information we collect
Website contact form When you navigate our websites or contact us, we may request or you may choose to provide us with certain information. This may include Personal Information, such as name, company, job title, email address and phone number and records and copies of your correspondence with us.
If you contact us through one of our contact forms, we will assume you have a legitimate interest to do so. We will continue to hold your information for 24 months after your last opened email from us. You can request for your data to be erased at any point by emailing [email protected].
Client account information As a client of our product, we may collect and process information such as your name, email address and company.
Usage details and cookies When you visit www.silverbird.com we may collect information about how our website is used. We do this to find out things such as the number of visitors to the various parts of the site so that we can improve our service to you.
Data that we collect:
ip address
email
cell or office phone number
name
a list of browsed web site pages
version of a browser
device type
site visit time
data about device (screen resolution , OS version etc);
session parameters
cookies
[We use a third-party service, Google Analytics to collect standard internet log information and details of your behaviour patterns. This information is processed in a way which does not identify anyone. We do not make and do not allow Google Analytics, to make, any attempt to find out the identities of those visiting our website.]
Any Personal Information collected on our website is obtained via our contact forms. We will make it clear when we collect Personal Information and will explain what we intend to do with it.
Our websites use "cookie" technology to collect information about how our website is used. A cookie is a little piece of text that our server places on your device when you visit any of our websites or apps. They help us make the sites work better for you. When you apply to us for products, and during the time you use these, we carry out information searches and verify your identity.
If you would like to opt out of Google Analytics , Google provides a browser add-on that allows a user to opt-out of receiving Google Analytics cookies.
If we do wish to collect personally identifiable information through our website, we will make this clear and will explain what we intend to do with the data we collect.
How we use your information
We use information about you to:
• provide relevant products
• identify ways we can improve our products
• protect both our interests
• meet our legal and regulatory obligations; and
• decide and recommend how our products might be suitable for you.
We will not sell your data to third-parties nor use the information held about you (and information about others) to provide you with advertising or other services that you have not requested.
How long do we hold your information?
We will keep your Personal Information for the duration of your Agreement and in accordance with your instructions or for such periods as may be required by law.
Disclosure of your information
We may disclose your Personal Information to any Director of the Fund and/or a member of our group, which means our subsidiaries and our investment management company.
We may disclose your Personal Information to third parties:
in the event that we sell or buy any business or assets;
if the Fund or substantially all of its assets are acquired by a third party;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of the Fund, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection; or
where previously mentioned in this policy.
Your rights
Under the General Data Protection Regulation (GDPR), you have rights as an individual, which you can exercise in relation to the information we hold about you.
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to erasure – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to object or question automated processing or profiling.
Right to judicial review – in the event that the Fund refuses your request under rights of access, we will provide you with a reason as to why. You have the right to challenge this with the Information Commissioner Office (2).
Changes to this policy
Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. We keep our privacy notice under regular review. This privacy policy was last updated on March 04th, 2019.
Contact
Questions, comments and requests regarding this privacy policy are welcome and you can contact us by emailing our Data Protection Officer at [email protected] 1) https://www.eugdpr.org/ with amendments and updates as of 25 May 2018. It sets out a series of new EU laws concerning how data is processed and used. The objective of the regulation is to strengthen and standardise data protection laws for all EU citizens. These regulations will apply to any organisation that controls and/or processes data on behalf of an individual or group of individuals. Those responsible for adhering to these regulations include employees of the organisation, including contractors, consultants, agents and third parties who have access to data either directly or indirectly.
