Open Disclaimer
Disclaimer
 

It is the responsibility of the individual user to consider his or her legal and regulatory position in the relevant jurisdiction, the risks associated with trading such products and to ensure that the use of the content and the subsequent making of any investment does not contravene any such restrictions or applicable laws and regulations of any jurisdiction. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific security, index, report, opinion, advice or other content. This does not exclude or restrict any duty or liability that Hereford Funds has to its clients under the Financial Services and Markets Act 2000 (as amended from time to time) or any other regulatory system under the laws of applicable jurisdictions.

Hereford Funds, its subsidiaries, associated entities, partners, employees, representatives or suppliers will not be liable, on any grounds whatsoever, contractually or not, for any direct or indirect damage that may arise as the result of it being possible or impossible to gain access to this site, the accessing, visiting or use of this site and/or the information provided, the sending, or receiving of information via this site and/or the operation or non-operation of this site, except in the event of intentional or serious blame on its part. The information contained on this site, including any third party data is published in good faith and Hereford Funds believes that the information is accurate at the time of publication but no representation or warranty, express or implied, is made by Hereford Funds as to its accuracy or completeness and it should not be relied on as such.

Hereford Funds shall therefore have no liability, save for any liability that Hereford Funds may have under the UK Financial Services and Markets Act 2000, for any loss or damage arising out of the use or reliance on the information provided including without limitation, any loss of profit or any other damage, direct or consequential. Nor will Hereford Funds, its subsidiaries, associated entities, partners, employees, representatives or suppliers be, under any circumstances, liable for any corruption of data that may occur as the result of technical problems (e.g. transmission errors, technical failures, breakdowns, intervention of third parties, etc.) and/or for any damage or loss relating to software or hardware that is the result of any virus, defect or malfunction in relation to access or use of the site.

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Exceptional Investment Funds
Privacy Policy

PRIVACY NOTICE

1. Data protection
 
Hereford Funds and Hereford Funds LLP takes your privacy seriously, and adhere to high data protection standards as well as transparency of personal data collection and processing for our clients. This privacy notice contains general information on what personal data we collect, what we do with that information, and what rights you have.
 
If after reading this you have any questions or comments, please contact info@herefordfunds.com
 
‘Personal data’ is any information that relates to an identified or identifiable natural person (rather than to a legal entity, such as a company).
As part of our commitment to protect your personal data in a transparent manner, we want to inform you:
 

  • why and how we collect, use and store your personal data;
  • the lawful basis on which your personal data is processed; and
  • what your rights and our obligations are in relation to such processing.
 
2. What types of personal data do we collect?
 
We will, depending on the product or service we provide to you (if any), collect and process personal data about you including:
 
  • personal details such as your name, phone number, physical and electronic address
  • where applicable, professional information about you, such as your job title and work experience;
  • details of our interactions with you and the products and services you use;
  • Where we have your email address stored in our systems, we track and store email communications between you and us;
  • identifiers we assign to you, such as your client reference number.
 
When you access our Website, data transmitted by your browser and automatically recorded by our website service provider, including date and time of the access, name of the accessed file as well as the transmitted data volume and the performance of the access, your web browser, browser language and requesting domain, and IP address (additional data will only be recorded via our Website if their disclosure is made voluntarily, e.g. in the course of a registration or request).
 
When you visit our website, that website will contain additional information about how we use your information while you are visiting that website.
 
3. On which legal basis and for which purposes do we process personal data?
 
3.1 Legal basis for processing
 
Depending on the purpose of the processing activity (see section 3.2), the processing of your personal data will necessary for the legitimate interests of Hereford Funds and Hereford Fund LLP without unduly affecting your interests or fundamental rights and freedoms (see below) provided such interests are not overridden by your privacy interests.
 
Any consent we have obtained to process ordinary personal data does not apply for the purposes of the EU General Data Protection Regulation 2016/679 ("GDPR"). Instead, for the purposes of the GDPR, we rely on the lawful grounds of compliance with a legal obligation, contractual necessity or legitimate interests (as specified in this notice) and our ability to rely on any such consent for the purposes of the EU GDPR is hereby waived or extinguished.
 
3.2 Purposes of processing
 
We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process personal data for the following purposes:
 
a) managing our relationship with you, including communicating with you in relation to the services you obtain from us and from our business partners, handling customer service-related queries and complaints.
b) helping us to learn more about you as a customer, the services you receive, and other services you may be interested in receiving, for instance by looking at the types of products and services that you use from us, how you like to be contacted and so on;
c) taking steps to improve our services and our use of technology, including testing and upgrading of systems and processes, and conducting market research to understand how to improve of our existing services or learn about other services we can provide;
d) meeting our on-going regulatory and compliance obligations (e.g. laws of the financial sector, anti-money-laundering and tax laws), including in relation to recording and monitoring communications, disclosures to tax authorities, financial service regulators and other regulatory and governmental bodies, and investigating or preventing crime;
e) any other purposes we notify to you from time to time.
 
4. Who has access to personal data and with whom are they shared?
 
4.1 Within the organisation
 
Employees have access to personal data in order to ensure a consistently high service standard across our business, and to provide services to you.
 
  1. Third Parties
When providing services to you, we will obtain explicit consent in order to share personal data with persons acting on your behalf or otherwise involved in the transaction (depending on the type of service you receive from us), including, where relevant the following types of companies.
 
  • other financial institutions, credit reference agencies or credit bureaus (for the purposes of obtaining or providing credit references);
  • any third-party fund manager who provides asset management services to you; and
  • any introducing broker or intermediary (e.g. Lawyer, Accountant, Tax Adviser) to whom we provide introductions or referrals.
 
4.3 Service providers
 
In some instances, we also share personal data with our suppliers, including other business partners who provide services to us, such as IT and hosting providers, communication services, credit reference agencies, and others. When we do so we take steps to ensure they meet our data security standards, so that your personal data remains secure.
 
4.4 Public or regulatory authorities
 
If required from time to time, we disclose personal data to public authorities, regulators or governmental bodies, including when required by law or regulation, under a code of practice or conduct, or when these authorities or bodies require us to do so.
 
  1. Others

 
We may need to disclose personal data to exercise or protect legal rights, including ours and those of our employees or other stakeholders, or in response to requests from individuals or their representatives who seek to protect their legal rights or such rights of others.
 
5. International transfers of personal data
 
The Recipients referred to in section 4 above may be located outside the UK. In those cases, except where the relevant country has been determined by the Information Commissioner’s Office to provide an adequate level of protection, we require such recipients to comply with appropriate measures designed to protect personal data contained within a binding legal agreement. If and to the extent required by applicable law, we implement the necessary legal, operational and technical measures and/or enter into an agreement with you before such transfers.
 
6. How long do we store your data?
 
We will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. To help us do this, we apply criteria to determine the appropriate periods for retaining your personal data depending on its purpose, such as facilitating client relationship management, and responding to legal claims or regulatory requests. Examples of retention periods are set out in section 11 below.
 
7. Your rights
 
You have a right to ask us to rectify inaccurate personal data we collect and process and the right to request restriction of your personal data pending such a request being considered.
 
Where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time. Please also note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
 
You have a right to ask us to stop processing your personal data, or to request deletion of your personal data – these rights are not absolute (as sometimes there may be overriding interests that require the processing to continue, for example), but we will consider your request and respond to you with the outcome.
 
Where we process your personal data on the basis of your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right under applicable data protection laws to request your personal data be transferred to you or to another controller.
 
You have the right to ask us for a copy of some or all of the personal data we collect and process about you.
 
You can exercise the rights set out above by contacting us using the details in section 8 of this notice.
 
8. Exercising your rights, and complaints
 
If you are not satisfied with how we have been processing your personal data, we would like to discuss it with you to understand how we can rectify the issue. If you would like to speak to us about our use of your personal data, you can do this by contacting info@herefordfunds.com
 
If you are not satisfied with our response, you have the right to make a complaint to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen
.
 
9. Security Note
 
We have in place appropriate technical and organisational measures to prevent unauthorised or unlawful access to the personal data you have provided to us. As complete data security cannot be guaranteed for communication via e-mails, instant messaging, and similar means of communication, we would recommend sending any particularly confidential information by an alternative secure means and using appropriate passwords when using unsecure mediums of communication.
 
10. Changes to personal data
 
We are committed to keeping your personal data accurate and up to date. Therefore, if your personal data changes, please inform us of the change as soon as possible.
 
11. Example of retention periods
 
In general we will retain personal data for the period of your relationship or contract with us plus seven years, reflecting the length of time for which legal claims may be made following termination of such relationship or contract. An ongoing or anticipated legal or regulatory proceeding may lead to retention beyond this period. Due to requirements laid down by the Financial Conduct Authority (FCA), We must furthermore store all electronic correspondence (e-mails, etc.) and evidence of any calls made on business telephones by employees for a period of seven years. We must also make this information available to the FCA on demand. We also store all incoming and outgoing business and private communication data (in particular e-mails with attachments) in a separate, protected electronic archive located in Ireland for a period of seven years.
 
12. Status of this privacy notice
 
This privacy notice was updated in May 2018. It is a notice explaining what we do, rather than a document that binds us or any other party contractually. We reserve the right to amend it from time to time. If the notice has been updated, we will take steps to inform you of the update by appropriate means, depending on how we normally communicate with you, such as through your account statement.
 

Cookies

About cookies

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.