This Privacy Notice applies to the website www.bsifund.com, as well as any subdomains and any other websites on which this Notice is posted, and any content from or through the websites operated by Black Stars Investments Limited of Kemp House, 152-160 City Road, EC1V 2NX (“BSI”, “we” or “us”), and which is the Data Controller of the personal data provided via this website (“Personal Data”). This Privacy Notice describes how BSI collects, uses, shares and secures the personal information you provide via this website (i.e. by email). It also describes the choices available to you regarding our use of your Personal Data and how you can access and update this information.

1. Personal data we may collect

In order to provide you with information about BSI and its funds and associated investment opportunities it may be necessary for BSI to process certain personal information such as names, telephone numbers and email addresses and any personal identification documents you supply in order to confirm your identity and circumstances.

BSI may collect a variety of Personal Data via any email address listed on the website. This Personal Data may include information such as name, email address, mailing address, phone number.

We may use this information for our legitimate business interests, including to:

• send you requested business, product or service information;
• respond to queries and requests;
• administer and manage delivery of our services and products to you; and
• comply with our legal and regulatory obligations.

2. How we collect this data

BSI may collect personal data through a range of means. These may include:

• direct interactions (where you provide personal data to BSI via telephone or email correspondence or other direct methods of communication, including applications to invest in BSI’s funds or for prospective employment);
• from third parties such as intermediaries and banks in the case of prospective investors or third party recruitment firms in the case of prospective employees; and/or
• other publicly available sources (such as websites (for example, LinkedIn), or online registers (for example, FCA or other regulatory registers).

3. Information Sharing

We will only share your Personal Data with third parties in the ways set out in this Notice. We do not sell your Personal Data to third parties for them to market their services to you.
We may provide your Personal Data to our service providers to help us with our business activities. In all cases we will have a written data processor agreement with these companies safeguarding your Personal Data, including that it may only be processed for the purposes of that agreement and on our instructions.

We may also disclose your Personal Data:

• to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation or regulation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;

• as permitted by law, such as when we believe in good faith that disclosure is necessary for our legitimate interest such as investigating fraud, to make or defend a legal claim, to protect your safety or the safety of others, or to maintain our compliance or that of our personnel with applicable laws and regulatory requirements, in accordance with applicable law; and/or

• with our business partners. For example, this could include our partners from whom you or your company or your organisation purchased the BSI product. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
• with third party agents and contractors for the purposes of providing services to us (for example, our accountants). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Policy;
• if we sell any of our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
• if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer. 
• in other situations, only with your prior consent.

4. Transfers outside the EEA

BSI is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country. We will put in place appropriate measures to safeguard Personal Data transferred, and by providing your Personal Data you consent to such transfer. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:

• the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme;
• such transfer being otherwise permitted pursuant to appropriate safeguards envisaged by applicable law; or
• in other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.

You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us at info@bsifund.com

5. Your Rights

You have the right to ask whether BSI processes your Personal Data and to request a copy, to object to direct marketing and in certain circumstances to have the data rectified or blocked. To request this information, please email info@bsifund.com. If your personal information changes, or if you no longer desire our services, you may ask to have your Personal Data corrected, amended, removed or deleted by emailing info@bsifund.com. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation. You also have the right to object to direct marketing and, under certain circumstances, to object to our processing of your Personal Data. You may choose to stop receiving communications such as our newsletters by following the unsubscribe instructions included in such emails or by contacting us at info@bsifund.com.

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.

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.

6. Security

The security of your Personal Data is very important to us. We follow all applicable legal and regulatory requirements in protecting the Personal Data provided to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. If you have any questions about the security of your Personal Data, please contact info@bsifund.com.

7. Retention

We will retain your information for the longer of the period we are required to do so by law, as is reasonably necessary for the purpose (for example to comply with our legal obligations, resolve disputes, and enforce our agreements), or as needed to provide you services.

8. Updates to this Notice

We may update this Privacy Notice to reflect changes to our information practices; where we do so the updated Notice will be published on our website.

Telephone Recording

Telephone and other electronic communications made to or from BSI may be recorded by us in order to comply with our regulatory obligations.