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Privacy Policy

GDPR Privacy Policy Note

 

Introduction

 

Blossom Ventures LTD with registered office at Trident Chambers, P.O.Box 146, Road Town, Tortola, British Virgin Islands is a limited liability company with registered Number 288180, incorporated under the Laws of the British Virgin Islands.

The Company ('we' or 'us' or 'our') gathers and processes personal information in accordance with this privacy notice and in compliance with the applicable data protection laws and regulations, including the General Data Protection Regulation 2016/679 (“GDPR”) (to the extent it applies to us) and/or any applicable local data protection laws as amended or replaced or incorporated into domestic legislation, such as the law providing for the protection of natural persons with regard to processing of personal data and for the free movement of such Data Protection Law 125(1)/2018, hereinafter the “Data Protection Law”).

This notice applies to you if (i) you are an applicant for shares in the Company; (ii) you are a client/investor or prospective client/investor of ours; (iii) your personal data has been provided to us in connection with an application for shares in the Fund or the Company or to become a client of ours, in each case by another person (such as where you are a director, partner, trustee, employee, agent or direct or indirect owner of an applicant); (iv) we otherwise use your personal data; (v) you are an applicant for a job within the Company; or (vi) you are a data subject. GDPR defines “data subjects” as “identified or identifiable natural person[s].” In other words, data subjects* are just people from whom or about whom the Fund collects information in connection with our business and its operations.

This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

Information we collect/Information you provide to us

We process your personal information for the purpose of meeting our legal, statutory and contractual obligations and of providing you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way other than as specified in this notice.

The personal data that we collect from you is:

• Personal Data such as name, surname, date of birth, photograph, passport details, CV, contact details, banking details, signature, investment history etc.

• Residential Address Confirmation such as a utility bill, a bank statement or a tax bill.

• Forms that contain Employment Details as well as the net worth and annual income of the client and any information and supporting evidence within the local regulatory requirements for the purposes of construing the Economic Profile and Suitability Assessment of potential investors.

• Tax identification Number and Country of taxation for CRS/FATCA purposes.

We might also process the following personal data about you:

• Information that we collect or generate, which might include information relating to your (or an applicant's) investment in the Fund or the Company, emails (and related data), call recordings and website usage data and messages submitted via our website.

• Information that we obtain from other sources, which might include information obtained for the purposes of our Know Your Client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, counter-proliferation financing procedures, politically-exposed-person checks, sanctions checks, among other things), information from public websites and other public sources, and information received from your advisers or from intermediaries.

According to the General Data Protection Regulation (2016/679), personal data is defined as any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. The Data Protection Law defines personal data in much the same way.

Any personal data that will be collected by us through provision of the Services shall be processed according to the General Data Protection Regulation (EU) 2016/679 (hereinafter the "GDPR") (as well as the relevant regulatory framework incorporating GDPR domestically) and, where applicable, the Data Protection Law.

We collect information in the following ways:

• Through the documents and forms provided by the potential investors in the Fund or the Company;

• Face to face meetings with potential investors, if applicable;

• Electronic and hard copies, in simple written form or certified/notarized/apostilled;

• From third parties with whom we have a contractual relationship.

We only ask for personal information that we are obliged to collect from you under our legal obligations and are relevant to your specific requests for the provision of our services.

More details are included in our full Personal Data Protection Policy.

You are committed to supplying true, complete and accurate information and to keeping it up to date. If you are in any doubt about any personal data, please feel free to email us at  with details of the problem. We shall take every reasonable step to ensure that inaccurate data, with regard to the purposes for which they are processed, are deleted or rectified without delay.

Blossom Ventures may store information and data regarding your bank account, credit/debit card details or other payment account information under the requirements of the Law.

How we use your personal data

We take your privacy very seriously and will never disclose, share or sell your data without your consent, unless required to do so by law. We only retain your data for as long as necessary and for the purpose(s) specified in this notice. If you have given your consent to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.

The purposes and reasons for processing your personal data:

• We collect, store and process your personal data for the purposes of assessing and processing applications for investment in the Fund and/or the Company and other share dealings, including performing Know Your Client procedures, issuing and redeeming shares, receiving payments from and making payments to the applicant, calculating net asset value, and overseeing these processes.

• We collect, store and process your personal data for the performance of a contract with us or to provide a service to you as our client.

• We collect, store and process your personal data as part of our legal obligations in the sphere of business accounting, tax purposes, audit purposes and any legal or regulatory obligation or industry standards stemming from our licenses or registrations as regulated entities.

 

We may occasionally send you marketing information which we have assessed to be beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests for the purpose of proper monitoring and updating of client information in accordance with local legislation and provision of better-quality services.

 

Your Rights & Data Request and Access Rights to Personal Data

You have the right to access any personal information that we process about you and to request information about:

•What personal data we hold about you;

•The purposes of the processing;

•The categories of personal data concerned;

•The recipients to whom the personal data has/will be disclosed;

•How long we intend to store your personal data for;

•If we did not collect the data directly from you, information about the source.

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible, unless there is a valid reason for not doing so, in which case you will be notified.

You also have the right to request the deletion of your personal data or to restrict processing (where applicable) in accordance with data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

 

Where applicable, under the GDPR or any other applicable data protection laws, you may have the right to: 

• obtain access to, and copies of, the personal data that we hold about you; 

• require that we cease processing your personal data if the processing is causing you damage or distress; 

• require us not to send you marketing communications; 

• require us to erase your personal data; 

• require us to restrict our data processing activities; 

• receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and/or 

• require us to correct the personal data we hold about you if it is incorrect

 

Please note that the above rights (if applicable) are not always absolute, and we may be entitled to refuse requests where exceptions apply in accordance with applicable laws and regulations. Requests for access, correction, complaints, or other queries relating to how your personal data is processed should be addressed to us via the contact details set out under the heading “Queries and Contact Details” below. 

 

If you are located in the EU and the GDPR applies: 

 

• please refer to the EU regulator in the jurisdiction where you are located (in the EU) to find out more about your rights; and 

• you can also make a complaint to a local EU regulator in the jurisdiction where you are located if you are not satisfied with how we are processing your personal data.

Sharing and disclosing your personal data

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Where necessary, we may disclose your personal information to third parties for the performance of our business operations or if so required by law. When we share personal information, we do so in accordance with data privacy requirements.

Sharing your personal information with third parties may entail the transfer of your personal information outside the European Union.

We use third parties to provide the services and business functions specified below; however, all processors acting on our behalf only process your data in accordance with our instructions and comply fully with this privacy notice, data protection laws and any other relevant confidentiality and security measures. Both parties (data subjects and/or data-controller and/or data-processor) do not disclose information unless it is absolutely necessary in accordance with the law or business operations.

Personal information may be shared with:

•Affiliated companies (such as brokers, auditors, legal advisors, consultants, tax advisors etc.) for the purpose of providing services, fulfilling regulatory and legal requirements, and increasing the quality of the services provided.

•Regulated banking institutions with which we cooperate in order to provide services to our investors.

•Regulatory authorities and bodies, tax authorities, immigration department, credit institutions etc. for the purposes of complying with the applicable laws and regulations or seeking a professional advice, clarifications.

Safeguarding measures 

We take your privacy seriously and take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures in place, including:

•Restricted access to hard files and electronic files;

•Firewalls;

•Anti-virus/malware.

Transfers Outside of the EU

We utilize some products or services (or parts of them) that may be hosted/stored in the EU and/or non-EU countries, the transfer of personal data to non-EU countries might be necessary for the performance of a contractual agreement between you and us or for the implementation of pre-contractual measures taken at your request. It means that we may transfer any information which is submitted by you outside the European Economic Area ("EEA"), including to a jurisdiction which is not recognized by the European Commission as providing for an adequate level of personal data protection, for the following purposes:

• Electronic storage of your personal information;

• Brokerage services;

• Operational services;

• Legal services;

• Marketing services.

Therefore, when you provide us with your personal information and/or you use our website and/or send us an email and/or sign up to our newsletter etc., the personal information you submit may be stored on servers which are hosted in the EU and/or non-EU countries. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by the strict agreements and measures set out by us to protect your data and comply with the relevant data protection laws.

Consequences of not providing your data 

You are not obligated to provide your personal information to us, however, as this information is required for us to provide you with our services, we will not be able to offer some/all our services without it.

Legitimate Interests 

As noted in the 'How We Use Your Personal Data' section of this notice, we may process your personal information under the legal basis of legitimate interests. Where this is the case, we have carried out a thorough Legitimate Interests Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests, ensuring that they are proportionate and appropriate.

Processing of Personal data is performed in accordance with all applicable laws and regulations. We are obliged to process personal data fairly and lawfully, for specified, explicit and legitimate purposes, and to the extent that is relevant, appropriate and not excessive with regard to the processing purposes.

We use legitimate interests as a legal basis for processing your personal data for the purposes of sending you marketing information that we have assessed as beneficial to you as a customer and in our interests, and have identified that our interests are the proper monitoring and updating of client information in accordance with local legislation and provision of better-quality services.

Legal obligations 

We may also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person. In this respect, we may use your personal data for the following purposes: 

 

• for marketing to you. In this respect, see the separate section on Marketing set out below; 

• training our staff or monitoring their performance; 

• for the administration and management of our business, including recovering money owed to us, and archiving or statistical analysis; 

• seeking advice on our rights and obligations, such as where we require our own legal advice; and 

• defending, prosecuting or making a claim against you, us or a third party. 

 

In this respect, we may share your personal data with, or transfer it to, the following parties: 

 

• your agents, advisers, intermediaries, and custodians of your assets who you tell us about; 

• third parties whom we engage to assist in delivering the services to you; 

• our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers; 

• our bankers, insurers and insurance brokers; 

• other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you; 

• our data storage providers and any other software providers that we require to perform our services; and 

• third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.

We may also process your personal data for our compliance with a legal or regulatory obligation. In this respect, we may use your personal data for the following purposes: 

• to meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws; or 

• as required by tax authorities or any competent court or legal authority. In this respect, we may share your personal data with the following parties: 

• our advisers where it is necessary for us to obtain their advice or assistance; 

• our auditors where it is necessary as part of their auditing functions; 

• third parties who assist us in conducting background checks; 

• relevant regulators or law enforcement agencies where we are required to do so

How long can we keep your data?

We only ever retain personal information for as long as necessary under the applicable laws and regulations (e.g. for 5 years from the end of the relationship with the investor for personal data collected in compliance with our obligations in accordance with the AML Law) and we have strict review and retention policies in place to meet these obligations. Your information is retained in electronic or paper format, or both. When it is no longer required, it will be deleted or destroyed, subject to applicable laws and regulations.

Where you have given consent to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Termination or cancellation

 

Should your relationship with us be cancelled or terminated at any time, we shall cease processing your personal data as soon as reasonably practicable following such cancellation or termination, provided that we may keep copies of your data as is reasonably required for archival purposes, for use in relation to any actual or potential dispute, for the purpose of compliance with applicable laws and regulations or for the purpose of enforcing any agreement we have with you, for protecting our rights, property or safety, or the rights, property or safety of our employees, and for performing or discharging any functions, obligations and responsibilities we may have.

 

Information We Receive From Other Sources.

 

We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Where this is the case, we will ensure this will be in full compliance with applicable regulations.

Cookies

 

We follow the “implied consent” basis for processing cookies. The first time you visit our website we will inform you of the cookies we use and that by continuing to browse our website you are implying your consent for us to use cookies. A cookie is a very small text file placed on your computer, that allows us to distinguish you from other users of our website. These cookies help us to provide you with a good experience when you browse Our website. We use the following cookies: Strictly necessary cookies – These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of Our website. Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you, by remembering your preferences (for example, your choice of language or region). Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Marketing Consent 

We may occasionally send you information about our products and services by email and/or post that have been identified as being beneficial to our customers and in our interests. Such information will be relevant to you as a customer and is non-intrusive. You will always have the option to opt-out/unsubscribe at any time.

If you would prefer not to receive the above-mentioned marketing and offers, please contact us accordingly.

If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting us directly.

Changes to this Privacy Note 

This Privacy Policy is effective as of May 2018 and will remain in effect except with respect to any changes in its provisions in the future.

Lodging a complaint 

We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority

Contact information about us 

The registered address for correspondence registered office address is published on our website.

Email: info@blossombvi.com

Tel.: +44 7502 209755, +44 77 65 05 23 87

Applicable law

This Privacy Notice is subject to the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016, as amended or replaced or incorporated into domestic legislation, such as the law providing for the protection of natural persons with regard to the processing of personal data and for the free movement of such data (Law 125(1)/2018).

Blossom Ventures welcomes your comments regarding this Privacy Notice. If you believe that Blossom Ventures has not adhered to this Privacy Notice, please contact us if needed. We do our efforts to promptly identify and remedy the problem.

Blossom Ventures has designated a Data Protection Officer (DPO).

You can contact DPO at the email: info@blossombvi.com

 

Other Websites

 

Our website may contain links to other websites which are not maintained by us. This policy only applies to our website. When visiting these third party websites, you should read their privacy policies which will apply to your use of the websites.

 

Changes to our privacy policy 

 

Any changes we may make to this policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to Our privacy policy.

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