This Policy sets out the basis by which 4BIO Partners LLP collect, use, and disclose your Personal Data, as well as your rights with respect to such Personal Data.
4BIO Partners LLP (“we”, “us”, “our”) may obtain data directly from you in our role as an investment manager for our funds.
Your personal information may be shared with 4BIO Partners LLP Affiliates. By ‘Affiliates’ we mean, any corporation, firm, partnership or other entity, which controls, is controlled by or is under our common control. “Control” means direct or indirect ownership of fifty per cent (50%) or more of the outstanding stock or other voting rights entitled to elect directors thereof or the ability to otherwise control the management of the corporation, firm, partnership or other entity.
In compliance with the General Data Protection Regulation (‘GDPR’), is committed to protecting any personal data it receives in relation to its investors, service providers and suppliers (“you”, “your”).
How we get the Personal Data
Upon visiting our website, you may be asked to provide certain information about yourself including your name and contact details, in order to access restricted sections of our website content. We may also collect information about you from e-mails, letters or any other correspondence between you and us.
When information is received, we act as the data controller under GDPR.
Our contact details:
Address: 4BIO Partners LLP, 78 Pall Mall, London SW1Y 5ES, United Kingdom
Phone Number: 02034275500
Point of Contact for data control: Vasily Fedorin
The types of personal information we collect
Examples of the types of Personal Data that we may collect from you and hold protected can be found in the list below, please note that the list is non-exhaustive and may change from time to time:
Information about you: name, email address, telephone number, address, date of birth, nationality; in some cases: payment details, identity verification documents, information relating to tax residency status, and preferred language, job title, place of employment.
Photographs, passport and/or driving license details, electronic signatures.
Electronic footprint: Online profile and social media information and activity, based on your interaction with us and our websites and applications, including for example your banking profile and login information, Internet Protocol (IP) address, smart device information, location coordinates, online and mobile banking security authentication, mobile phone network information, searches and site visits.
How we get the personal information and why we have it
When entering our Site, you may give us information about you by filling in forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Site, become a member, post material, participate in discussion boards or other social media functions on our Site, when you request further services, and when you report a problem with our Site. If you contact us, we may keep a record of that correspondence.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
Your consent. You are able to remove your consent at any time. If you wish to cancel your account or request that we no longer use your identifiable personal data to provide you, by simply emailing firstname.lastname@example.org. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements;
We have a contractual obligation;
We have a legal obligation;
We have a legitimate interest.
The reasons why we collect your personal information may include the below:
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to notify you about changes to our service;
to complete surveys that we use for research purposes, although you do not have to respond to them;
to email you monthly factsheets and periodic newsletters;
for the purposes of offering, marketing and selling relevant products and/or services to you;
to carry out various compliance checks as required by law, regulations, or internal policies and procedures. Such policies are designed to review creditworthiness, guard against money laundering or fraud and to ensure compliance with sanctions regimes. We may also use personal information to help us determine appropriate client relationships by reviewing political affiliations and records of criminal offences committed or alleged to have been committed and searching media databases;
if we are subject to a court action or other proceedings or require, to the extent necessary, to exercise and defend our legal rights we may be required to use your personal information;
to facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
How we store your personal information and for how long
We have security arrangements in order to store your personal information protected against unauthorised access, improper use, alteration. Nevertheless, please also ensure that your own personal information and your colleagues’ and that of third parties are kept secure. You should not share your (or anybody else’s) personal information unless you have the permission to do so.
We retain your personal data for as long as it is permitted in light of the purpose(s) for which it was obtained and as long as your account remains active.
Where we are required to collect your personal data to comply with a legal obligation in relation to an investment in one of 4BIO Partners LLP’s funds, we may be required to retain such data for 7 years following the end of your investment, or longer if the relevant regulatory authority requires, or as otherwise required by applicable law or related legal purposes.
Your data protection rights
Under Data Protection Law, you are entitled to exercise certain rights in relation to your data as of 25 May 2018. These rights may be subject to statutory restrictions, where they are applicable. The rights include:
Your right to access - You have the right to ask us for copies of your personal information. Requests to access your data under the GDPR is free.
Your right to rectify - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
Your right to complain – You have the right to make a complain if you have an issue with how we are using your personal information or you believe that your data is not treated as lawfully.
Where data is provided by you based on consent, you are within your rights to withdraw that consent at any time. Withdrawal of consent may result in benefits that were otherwise provided to you being withdrawn.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at email@example.com if you wish to exercise any of your rights or you would like to make a request.
You can also complain to the Information Commissioners Officer (‘ICO’) if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk.
We follow generally accepted standards to protect Personal Information submitted 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. Therefore, while we will put in place appropriate technical and organisational measures designed to ensure the security of your Personal Information, we cannot guarantee that, notwithstanding such compliance by us, information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please help keep your account safe by using a strong password. We advise that you do not make any confidential information publicly available through our websites.