INTRODUCTION

This Privacy Policy describes the manner in which, the Wine Source Fund, a sub-fund of WSF Sicav P.L.C, a company incorporated under the Laws of Malta and bearing company registration number SV 158 (“Wine Source Fund” or “we” or “us”) will process and use any personal information relating to you, and the measures we put in place to comply with the provisions of laws relating to the protection of personal information as applicable to us, in particular Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Act (Chapter 440 of the Laws of Malta).

This Privacy Policy is limited to personal data that is processed as a result of you using our website, accessible through the domain winesourcefund.com, or any other domain that will be used by us from time to time (“the website”).

Any information held by us relating to you, will be processed and managed in the manner described in this Privacy Policy. It is important for you to read and understand this Policy as it aims to help you better understand:

•    What information is collected
•    How do we use and share this information
•    Your rights
•    General information regarding privacy and security
•    Cookies, and your rights in this respect
•    How to contact us

By accepting the terms hereof, you agree that you have understood the Privacy Policy and consent to the use and processing of your personal information as laid down in this policy. If you fail to accept and agree with these terms, you are asked not to access our website.

If any significant changes will be made to this Privacy Policy, we will ensure that you are adequately informed through electronic means, and your consent will be further requested.

WHAT INFORMATION DO WE COLLECT?

When you visit our website, you may voluntarily choose to provide us personal information, by inserting the details we request in certain sections of the website, particularly:

•    Name and surname
•    Email address
•    Telephone/mobile number
•    Type of investor
•    Investment experience
•    Company name
•    Position

As is true of most websites, we gather some information automatically, such as your IP address, browser type, referring/exit pages, and operating system. We use this information to administer our website and service, understand how visitors navigate through our service, and to enhance your experience while using our service.

We may also engage a third party service provider to provide us with web analytics services.  Should we do so, such third party service provide will provide us with information about you relating to your visit on our website.

HOW DO WE USE YOUR PERSONAL DATA?

We will only use your personal data fairly and where we have a lawful reason to do so.  In particular, we will use your personal data for the following purposes:
Newsletter/Subscription pack – If you submit your personal details on our website, and request to be provided with the subscription pack and/or to sign up for the newsletter, we will process this information in order to provide you with our newsletter and/or the subscription pack as applicable.

The newsletter and/or the subscription pack may be received by you through electronic mail, direct mail, online push notification or any other means of communication deemed suitable.

When receiving communications by email, in each communication, you will be provided with instructions on how you may opt out of receiving further communications from us.

Diagnostic and Development of our Systems – We make use of certain information so as to ensure that our system operates satisfactorily. The data is used internally to help diagnose any technical or software problems that may arise. We hold a legitimate interest in carrying out such actions (research, diagnose and develop) to ensure that our business is always up to date with the current market trends.

Legal and Regulatory Obligations – Your information may be held and processed by us to fulfil a number of internal policies and to abide by legal requirements. Legal requirements pertaining to us may not be identical to those of your country of residence and thus any information held and processed by us will be processed in accordance to the laws pertaining to us and not necessarily the laws of your country of residence.

The information held by us may be utilised:

•    For us to meet our internal and external audit requirements;
•    For information security purposes;
•    For the detection and investigation of any crime or fraud;
•    To respond to any request from the courts, Law enforcement agencies, regulatory agencies and other public or government agencies. This may include entities within or outside of your country of residence.

Cookies – Cookies are small text files which are downloaded onto your computer when using any website. Cookies help us differentiate between our individual users and enable us to identify how individual users make use of our website. These cookies help us make our website more efficient, based on your previous browsing behaviour.

Cookies also help us gather analytical information about our website, such as our performance; how many visitors did we get on our website, for how long did they visit the website and what did they use the website for.
We use various types of cookies, some of which are absolutely necessary for our website to function. Some of the cookies we use include, analytical and performance cookies, functionality cookies and strictly necessary cookies.

HOW AND WHY DO WE SHARE THIS INFORMATION?

We may engage and contract with third party companies (e.g., service providers) to provide services that help us with our business activities such as cloud hosting services, event organisers, data analytics companies or providers of email and marketing platforms. We will ensure that these third party service providers only receive information that is strictly necessary for them to provide contracted services to us.  In all cases, we will make sure that such service providers are bound by an agreement, in terms of the provisions of the GDPR.

Information sent outside of the EEA – It may be the case that for us to provide our services, engage service providers, fulfil our contractual obligations or comply with legal obligations we may need to send your personal information outside of the EEA zone. To ensure that even in these instances, your personal information is safeguarded, we adopt any of the following:

•    We will check if the recipient country situated outside of the EEA has been deemed by the European Commission to offer the same level of protection as the EEA;
•    If the recipient organisation is situated in the USA, we will check whether the recipient is registered with the Privacy Shield. (Privacy Shield is offers privacy protection level which has been approved by the EU);
•    In the absence of the above, we will rely on contracts which will bind the recipient to protect your information and data with the same level of security available in the EEA.

FOR HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Your personal information will be held by us for such amount of time as is necessary for us to comply with any legal and regulatory obligations.   If you would like further information about our data retention policies, please get in touch with us on the contact details set out hereunder.

YOUR RIGHTS OVER YOUR PERSONAL DATA

You are afforded a number of rights relating to the manner in which your personal information is received, held and processed.  Where applicable, you may exercise the following rights:

•    Access to personal data: you may request that you are provided with a copy of any/all information which is held by us relating to you.
•    Correction of personal data: you may make a request to have your personal information amended or corrected if any information held by us is deemed to be incorrect
•    Right to withdraw consent: in the circumstances that any of the information held by us required your previous consent, you may revoke this consent subsequently.
•    Right of erasure: you may request us to erase your personal information when there is no necessity for us to continue processing your information. This right may only be utilized in certain circumstances.
•    Right to Data portability: You may request us to provide you with all the information gathered by us relating to you in a format which allows you to the transfer all your information to another organisation.
•    Right to restrict processing of personal data: You may request to suspend the processing of your personal information.
•    Right to object to the processing of personal data: You may object to our right to process your personal data for purposes relating to our legitimate interest. Despite you objecting, we may still process your information in order for us to fulfil any legal obligation or where we have legal grounds to do so.
•    Right relating to automated decision making and profiling: You may request that no automated decision that could have any legal effect on you be made on your behalf solely based on an automated system.

CONSEQUENCES FOR NOT PROVIDING US WITH YOUR PERSONAL DATA

Unless we have another legal basis to do so, we will not send you any newsletter and/or subscription pack if you do not consent to receive such communications.  Certain features or functions in the website may not be available if you decide to disable certain cookies.

LODGING A COMPLAINT

If you are not satisfied with the manner in which we store, process or share your information, you may lodge a complaint with the local supervisory authority, the Information and Data Protection Commissioner on idpc.info@idpc.org.mt, or any other local supervisory authority within your country of residence.

CONTACT US

If you would like further details or require further information regarding the manner in which we take care of your personal information kindly contact us on the following contact details:

Wine Source Fund, sub-fund of WSF Sicav P.L.C.
Address: Il-Pjazetta, Block B, Level 1, Office 14, Tower Road, Sliema, SLM 1605, Malta
Email:     fund@wine-source.com

Version no [1]
Date Added [20/08/2019]