Website Privacy Notice

This website, www.jasmef.com, provides information about JASMEF I Limited ("JASMEF")

While JASMEF does not have operations in the UK, this site and its contents were issued in the United Kingdom, and comply with appropriate UK legislation and regulation.  

References to “we”, “us” and “our” in this Privacy Notice are references to JASMEF.

We are the controllers of your personal data under applicable data protection law, including the United Kingdom's General Data Protection Regulation (“GDPR”) that took effect in 2018.

Purpose of the Privacy Notice

When an individual interacts with us through this website we may collect information that constitutes personal data under GDPR and this Privacy Notice sets out how we collect, share and protect that data.

Whose personal data do we collect?

When someone interacts with this website 

When someone sends a message by email to us

The sorts of personal data we collect

The data that we collect depends on the nature of the interaction with an individual through the website.  It may include data such as name, e-mail address, and other information provided on application forms and related documents.

How your personal data is collected

Personal data may be provided to us in a number of different ways, such as:

Via our website's forms, such as for contacting us by email.

Our website may also use cookies.  Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website.  This allows the website, through its server, to provide the users with a tailored experience within the website. We may use cookies to remember personal settings you have chosen at our website.  In no other context do we use cookies to collect information that identifies you personally. We may use anonymous session cookies (short-term cookies that disappear when you close your browser) to help you navigate the website and make the most of the features.

Collecting data from third parties

For due diligence and Know Your Customer purposes, we may also collect personal data from third parties such as a financial adviser, the organisation you represent, credit reference agencies, authorities and other legal entities and individuals and publicly accessible sources. In certain circumstances we may be required to carry out enhanced due diligence checks to comply with our obligations under the Money Laundering Regulations 2017. These enhanced checks may reveal information about criminal convictions or information about an individual’s political opinions and associations and/or other sensitive personal data. We will only collect and process such information to the extent necessary to comply with our regulatory obligations and in accordance with the applicable data protection laws.

How we use your personal data

Below we set out the purposes that we use your personal data for and the legal bases that we rely on to ensure that your personal data is processed lawfully:

to perform our contract with you when you act as an intermediary;

to perform a contract with you when you invest in our fund or when we invest in a business e.g. to verify your identity, admitting an investor to the fund, maintaining a share register and providing information to you;

to comply with our legal obligations, notably under company and tax law, including the Companies Act, the OECD Common Reporting Standard (“CRS”), the Foreign Account Tax Compliance Act (“FATCA”) and all applicable AML, KYC and CTF laws, and screening against sanctions lists;

to pursue our or a third party’s (such as our associates, service providers, agents or delegates) legitimate interests, such as:

sharing your personal data within our group of companies for administrative purposes;

preventing, detecting and investigating fraud and other crime;

ensuring network and information security;

purchasing services from third parties that help us to provide our services to you and to comply with our legal obligations;

retaining electronic records and communications;

developing, and informing you about, events, services and investments that you may be interested in;

undertaking market research;

maintaining our relationship with you;

mitigating business and operational risks;

defending our interests;

ensuring that our associates, agents and third party service providers also comply with all relevant legislation;

When evaluating whether legitimate interests can be relied on as a legal basis for the activities above we are required to carry out a balancing test to ensure that the use of your personal data will not be overridden by your fundamental rights and freedoms. In certain circumstances we will seek your consent and you will have the right to withdraw such consent at any time.

What happens if you fail to provide the requested personal data for application or due diligence processes?

If, for example, you fail to correctly complete all the necessary sections on an application / subscription form or fail to provide the correct information (e.g. for AML, KYC, CTF, FATCA or CRS) we may reject or delay your application / subscription until the relevant information is received or we may decide not proceed with a transaction or a business relationship.

Who do we share your personal data with?

We may share your personal data for the purposes set out in the Privacy Notice with our associates, intermediaries, agents, third party service providers and delegates, such as registrars, auditors, professional advisers and third party service providers.

Where we use a third party who process your personal data as a processor we will ensure that they do so in accordance with our instructions and that they put appropriate measures in place to protect your data.

We may allow third parties who we share your personal data with to process your data as controllers solely for the purpose of providing services to us.  In such cases we will ensure that these controllers will process your personal data in accordance with this Privacy Notice and in accordance with applicable laws. We do not allow third party service providers to market to you unless they obtain your consent. We may also share your personal data with a potential buyer in connection with any proposed purchase, merger or acquisition of any part of the business.

Keeping your data secure

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us (see ‘Contacting us?’ below).

We will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Transfers of your information out of the UK & the EEA

As we use a number of cloud-based systems your personal data may be transferred outside the United Kingdom & the European Economic Area.  In such cases we will ensure that adequate safeguards are put in place to ensure the security of your personal data.

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  For example, in accordance with our legal and regulatory requirements, we will retain investors’ records for a minimum period of at least six years following the termination of our agreement with such investors.  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you.

Your rights in relation to the personal data that we hold about you

Subject to the conditions set out in applicable laws you have the following rights:

To access, rectify or request the erasure of your personal data;

To ask that the processing of your personal data be restricted;

To request the portability of your personal data;

On certain grounds, to object to the processing of your personal data based on our legitimate interests; and

To object to the processing of your personal data for direct marketing purposes.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us.

Contacting us

Please address all questions and concerns about the contents of the Privacy Notice to privacy@jasmef.com