Privacy Notice

This privacy notice applies to Marick Real Estate Limited and its subsidiaries from time to time (“Marick”).

For the purposes of this Privacy Notice, the data controllers are Marick Capital Limited. The address is 33 Cavendish Square, London, W1G 0PW. We have also set out contact details towards the end of this notice.

How we use your information

This privacy notice tells you what to expect when Marick collects personal information. It applies to information we collect about:

• Visitors to our website;
• People who invest in funds where Marick act as Operator, Trust Manager, AIFM or Depositary; and
• Job applicants and our current and former employees

We only obtain, use and keep personal information where we need it for a specific purpose. We set out below the ways in which we plan to use your personal information. We are only able to use your personal information if we have a proper legal reason or basis for doing so. This is called a legal basis and the regulations require that we have a legal basis so that your privacy is protected.

Visitors to our website

When someone visits www.marickrealestate.com we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and we will explain what we intend to do with it.

Use of cookies

You can read more about how we use cookies on our Cookies page.

People who e-mail us

Any e-mail sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. E-mail monitoring and blocking software may also be used. Please be aware that you have a responsibility to ensure that any e-mail you send to us is within the bounds of the law.

Investors in funds where Marick is Operator, Trust Manager, AIFM or Depositary

Where Marick act as Operator, Trust Manager, AIFM or Depositary for a fund, we will maintain a register of the investors. Without up-to-date information, we will be unable to keep investors informed concerning their investment which we have a contractual obligation to do. We are legally obliged to use personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example, this might include confirming your identity and source of wealth. Personal information may be received directly or indirectly from investors’ financial advisors.

We will only use the personal information which we hold to communicate with investors concerning their investment. We will share the personal information with the funds’ advisors, with the individual’s own advisors and with relevant regulatory authorities, for example HMRC.

Information kept on our servers is backed up to a secure encrypted cloud based facility which may store data within the United States and locations around the world.

We will keep personal information contained in the register of investors for seven years from the dissolution of the fund. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Job applicants, current and former employees of Marick

When individuals apply to work at Marick, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Criminal Records Bureau we will not do so without informing them beforehand unless the disclosure is required by law.

Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, it will then be destroyed or deleted. We may retain de-personalised statistical information about applicants to help inform our recruitment activities but no individuals are identifiable from that data.

Once a person has taken up employment with Marick, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with Marick has ended, we will retain the file for seven years and then destroy or delete it.

We do not collect any special categories of personal data. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data.

We may share personal information with a payroll bureau and pension provider.

Information kept on our servers is backed up to a secure encrypted cloud based facility which may store data within the United States and locations around the world.

Your rights

You are provided with a number of different rights under the data protection laws in relation to your personal information. These allow you to:

• Access your information
• Request that we correct your information
• Request that we erase your information
• Object to the processing of your information
• Request a restriction on the processing of your information
• Request a transfer of your information
• Withdraw your consent

If you wish to exercise any of these rights please write or e-mail Marick at 33 Cavendish Square, London, W1G 0PW, info@marickrealestate.com. Please note that you will not have to pay a fee to access your personal information, or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.

Disclosure of personal information

In most circumstances we will not disclose personal data without consent. However there may be occasions when we need to share personal information. Further information on:

• Agreements we have with other organisations for sharing information;
• Circumstances where we can pass on personal data without consent, for example, to prevent and detect crime;
• Our instructions to staff on how to collect, use and delete personal data; and
• How we check that the information we hold is accurate and up to date

can be obtained on request.

Data transfer in the EEA

The regulations which have been put in place to protect your privacy apply throughout the EEA. The EEA is the European Economic Area which includes all the countries in the European Union plus Iceland, Liechtenstein and Norway. This means that any country within the EEA must meet the same privacy standards as the United Kingdom. All the personal information that we hold about you will be processed in the United Kingdom.

Complaints or queries

Marick aim to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Marick’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this information should be sent to the address below.

Should you feel that we are holding or using your personal information inappropriately, you may lodge a complaint with the relevant supervisory authority.

How to contact us

If you want to request information about our privacy policy you can email us or write to:

Marick
33 Cavendish Square
London
W1G 0PW

info@marickrealestate.com