Privacy Policy

HF Fund Services Ltd. (HF) is a limited liability company incorporated under the laws of the Cayman Islands.  HF provides services to alternative investment funds from the Cayman Islands, Ireland and Singapore.  References to HF include its affiliated operations in Ireland and Singapore.  HF is committed to protecting your privacy and maintaining the confidentiality and security of your personal information.  This Privacy Policy applies to personal information about you that we collect, use and otherwise process in connection with your relationship with HF.

 

If HF processes personal data that is possessed by us, we will be considered the Data Controller of that information.  HF may also engage outside service providers that would be considered Data Processors of personal data.  Personal data would include information that could be used to identify an individual.  HF may obtain personal data for the following reasons:

 

  • Engage in client development where we receive a direct solicitation for services through email or our website;
  • Establish a business relationship either directly with a client or with other service providers affiliated with our clients;
  • Engage individuals to be employees of HF;
  • Establish contractual relationships with service providers of HF.

 

The above information may be received directly by HF or through third party information service providers and the World Wide Web.  If HF establishes a business relationship with an entity, personal data may be collected from its beneficial owners, employees, officers, etc.

 

Generally HF maintains personal data for the following reasons:

 

  • Regulatory requirements with respect to maintaining know your client information and to prevent and detect money laundering and terrorist financing;
  • Establish contractual relationships with clients and service providers and to ensure orderly communication with these entities.

 

Personal data that is maintained by HF is stored on our secure servers that are located in Toronto, Canada.  Our secure servers are maintained and managed by IT Weapons which is SOC II compliant and audited annually by Deloitte.  HF will only share personal data under the following circumstances:

 

  • Specifically requested to do so by a client, service provider or individual;
  • To communicate with services providers of our clients such as lawyers, accountants, etc.
  • To respond to requests from any competent legal or regulatory body if required to do so by law.

 

HF and its Data Processors will retain your personal information for as long as required for HF or its Data Processors to perform its services or perform investigations in relation to the services. The length of the retention period will be determined by such considerations as legal or regulatory obligations that require HF or its Data Processors to retain your personal information, and applicable statutory limitation periods, whichever are longer.  Generally personal data will only be retained for a period of 7 years after the termination or our relationship with a client, employee or service provider.

 

Individuals within the European Union (or any jurisdiction with equivalent legislation to the European Union General Data Protection Regulation “GDPR”) have the following rights, in certain circumstances, in relation to your personal data:

 

  • Right to access your personal data;
  • Right to rectify your personal data;
  • Right to restrict the use of your personal data (in certain specific circumstances);
  • Right to request that your personal data is erased (in certain specific circumstances);
  • Right to object to processing of your personal data (in certain specific circumstances);
  • Right to data portability (in certain specific circumstances);
  • Right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by HF or its Data Processors infringes the GDPR.

 

You are not obliged to provide HF with your personal information, however where HF or its Data Processors require your personal information to maintain a business relationship, or to comply with HF’s legal obligations, failure to provide this information means that HF may not be able to maintain a business relationship with you.  

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