Strix Varia is the trading name for both Strix Varia Limited, a private limited company incorporated in England & Wales with registered address, Suite 12, Fourth Floor, 11 Palace Court, London, W2 4LP and company number 11402253, and its wholly owned subsidiary Minerva Risk Limited, a private limited company incorporated in England & Wales with registered address Suite 12, Fourth Floor, 11 Palace Court, London, W2 4LP and company number 12234660.

PRIVACY NOTICE

Why are we providing this notice? 

The General Data Protection Regulation (“GDPR”) (implemented across all EU member states from 25th May 2018) applies to the collection, processing and storage of personal data (including special category data – please see below) undertaken by organisations within the EU, as well as to firms outside the EU that handle personal data relating to the offering of goods or services to individuals in the EU.

The GDPR has two key purposes: (i) to set guidelines for the collection, processing and protection of personal data and (ii) to give individuals certain rights in relation to their personal data (such as to access and correct it and object to further processing).

This Privacy Notice is intended to ensure that individuals outside our organisation with whom we interact, including visitors to our website, personnel of service providers or other suppliers and others who interact with us whether via our website or by corresponding with us by other means (e.g. by emailing or telephoning us) (“you”, or “your”) are aware of the categories of your personal data Strix Varia Limited and its affiliates (“we”, “us” or “our”) may collect, how we collect it, what we use it for and with whom we share it in accordance with the GDPR.

By “personal data” we mean any information relating to you such as your name and contact details. Personal data does not include data where you can no longer be identified from it such as anonymised aggregated data.

We will generally be a data controller in respect of your relationship with us. A data controller is responsible for deciding how to hold and use personal data about you. We may process your personal data ourselves or through others acting as data processors on our behalf.

We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. These supplemental notices should be read together with this Privacy Notice.

If you have any questions about this Privacy Notice please contact compliance@strixvaria.com

What information do we collect about you and what do we use it for? 

Personal data held by us may include, but is not necessarily limited to, your name, address, place of business, email address, other contact details, corporate contact information, job title, signature, correspondence records, information about how you use our website, other technical data (such as your IP address, login data for our web portal, browser type and version, referral source, length of visit, page views, time zone setting and location).

The purposes for which we may collect, store and use personal data about you and our ‘lawful basis’ for processing such data are set out in the table below. The law specifies certain ‘lawful bases’ for which we are allowed to use your personal data.

In addition to the uses above, please note that we may also process your information where we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Special categories of personal data 

There are more limited bases for processing special category personal data. This is personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation.

We do not intend to actively collect special category data about you. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally. For example, where you volunteer special category data to us, such as if you send us an email containing special category data.

What if you do not provide the personal data we request? 

In some circumstances, if you do not provide us with certain information when requested, we may be limited or restricted in our ability to deal with you and may in some cases be prevented from complying with our legal obligations. Where we require your personal information to comply with anti-money laundering or other legal requirements, failure to provide this information means that we may not be able to engage with you.

Change of purpose 

We will only use your personal data for the purposes for which we collected it (as identified in the above table), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

How do we collect this information? 

We typically collect personal data about you when you provide information to us when communicating or contracting with us in writing or by corresponding with us by phone, email or otherwise.

In addition, we may receive personal data about you from third parties, such as public sources or introducers.

With whom will we share your information? 

We may share your personal data with a third party where this is required by law or where we have another legitimate interest in doing so.

We may need to share your personal data with:

• other entities within our group as part of our reporting activities in company performance, or for assistance in relation to marketing and business development;

• professional advisers including lawyers, auditors and insurers to the extent such information is relevant to their performance of their services;

• cloud service providers;

• any of our service providers where such information is relevant to their performance of such services;

We may share your personal data with third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protection our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

We may transfer the personal data we collect about you to non-EEA countries (including North America, Hong Kong, Switzerland and the remainder of Europe) where the parties listed above are based for the purposes outlined in the table above. Those countries may not have the same standard of data protection laws as the EEA.

Where this is the case, unless an exemption applied, we will seek to put in place appropriate safeguards where possible, such as the EU-approved standard contractual clauses to ensure that your personal data is treated in a manner that is consistent with and respects the EU and UK laws on data protection. If you require further information about this please request it from compliance@strixvaria.com

How long will we retain your information? 

We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. This will normally include any period during which we are dealing or expect to deal with you and what we consider to be a suitable period thereafter for our internal record-keeping purposes. In doing this we will have regard to 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.

Once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data in accordance with applicable laws and regulations.

Accuracy of information 

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

Your rights in relation to your information 

You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:

• request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;

• request rectification of your personal data;

• request the erasure of your personal data;

• request the restriction of processing of your personal data;

• object to the processing of your personal data;

• request the transfer of your personal data to another party.

If you want to exercise one of these rights please contact compliance@strixvaria.com

You also have the right to make a complaint at any time to a supervisory authority for data protection issues.

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent 

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact compliance@strixvaria.com. Once we have received and processed the notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.

Changes to this privacy notice 

We reserve the right to update this privacy notice at any time, and we will make an updated copy of such Privacy Notice available to you and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

Further information

This privacy notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please do not hesitate to contact compliance@strixvaria.com

WEBSITE TERMS OF USE

Whilst every effort is made to ensure that the information contained on this website is accurate and up to date. Strix Varia Limited and its affiliates accept no liability to any third party for any error or omission.

Use of the website includes accessing, browsing, or registering to use the website Please read these terms of use carefully before you start to use the website, as these will apply to your use of the website. By using our website, you confirm that you accept these Terms of Use and that you agree to comply with them. If you do not agree to these Terms of Use, you must not use the website.

Changes

We may revise these terms of use at any time by amending this page. Please check this page from time to time to take notice of any changes we make, as they are binding on you in law. We may update our website from time to time, and may change the content at any time without notice to you or any other third party.

Accessing our site

We do not guarantee that the website, or any content on it, will always be available or be uninterrupted. Access to the website is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of the website without notice. We will not be liable to you if for any reason our website is unavailable at any time or for any period. You are also fully responsible for ensuring that any person who has access to the website through your internet connection is aware of these Terms, and that they comply with them.

 No Reliance on Information

The information contained on the website has been prepared in good faith. However no representation or warranty, express or implied, is or will be made, and no responsibility or liability is, or will be accepted, by us, or by any of our respective officers, employees or agents in relation to the contents of the website.

Limitation of Liability

The internet is not a completely reliable transmission medium. We do not accept any liability for any data transmission errors such as data loss or damage or alteration of any kind. Whilst we use all reasonable skill and care in compiling the information contained on the website, errors or omissions may occur because of factors inherent in internet systems, such as unauthorised access or hardware, software or operator error or malfunction in data transmission. No responsibility or liability is, or will be accepted, by us, in relation to the accuracy or completeness of the information contained herein and any such liability is expressly disclaimed.

We will not be liable to you or any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with use of or inability to use the website.

We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your or any other user’s computer equipment, computer programs, data or other proprietary material due to the use of the website or to your or any other user’s downloading of any content on it, or on any website linked to it.

To the extent permitted by law, we hereby expressly exclude all conditions, warranties and other terms which might otherwise be implied by statue, common law or the law of equity.

Indemnity

By using this website you agree to indemnify, defend, and hold harmless us, our affiliates and licensors, and the officers, partners, employees, and agents of ours and their respective affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of the website.

Nothing in these terms of use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law.

Linked websites

The website may be linked to third party websites or contain information provided by third parties. We make no representations as to the accuracy or completeness of such websites or information, have not and will not review or update such websites or information, and you are hereby warned that any use made of such websites or information is at your own risk. We accept no liability arising out of the information contained on any linked website or information on the website provided by a third party and the use of such websites and information is at your own risk.

Intellectual Property

All information and imagery contained on this website is our property. The entire contents of the website are subject to copyright with all rights reserved. Reproduction of all or part of the website (for any purpose other than described below) or copying, editing or alteration of its contents is not permitted.

Users of the website may print, copy, download or temporarily store information from this website for their personal use but all intellectual and other property information shall remain our property and no rights in it shall be transferred to you or any other users.

You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use the website for any public or commercial purpose the website.

Governing law and jurisdiction

The information on this website is directed only at persons or entities in any jurisdiction or country where such access to information contained on this website and use of such information is not contrary to local law or regulation. It is your sole responsibility to be aware of and to observe all laws and regulations applicable to you in your country of residence and in any other country the laws of which are capable of affecting you. The agreement between you and us relating to your access to and use of the website is subject to English law and you agree to submit to the exclusive jurisdiction of the English courts.

To contact us, please email compliance@strixvaria.com