Privacy Statement

Introduction

This Privacy Statement covers personal information provided to RAW Capital Partners Limited, RAW Wealth Management Limited, and RAW Alpha PCC Limited (the legal entity whose Cells the RAW Sterling Cash Deposit Fund and the RAW Mortgage Fund are managed by RAW Capital Partners Limited).

RAW Capital Partners Limited, RAW Wealth Management Limited and RAW Alpha PCC Limited (“RAW” or “We” or “Our”) are committed to protecting your personal information when you use Our services. Personal data is any information that can be used to identify you as a person. This Privacy Statement relates to Our use of any personal information you provide.

In order to provide you with the best experience, we are required to collect information about you. We are committed to safeguarding your personal information. Whenever you provide such information we are legally obliged to use your information in line with all laws concerning the protection of personal information including the Data Protection (Bailiwick of Guernsey) Law, 2017.

This website contains hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies, including cookies, and we urge you to review them. They will govern the use of personal information you submit or are collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.

 

What information will RAW collect about me?

When you engage with or receive a service from RAW, such as enquiries about services, making investments, or arranging a mortgage we will ask for personal information about you. This will consist of your name, email address, postal address and other personal information. Different services may ask for different information.

 

By giving us your details you enable RAW to provide you with the services you selected.

 

How will RAW use the information they collect about me?

We use your personal information in a number of ways including the following:

to contact you about an enquiry you have made via email, website, telephone or other means of communication, including any content you provide

to personalise the way, we present information to you

to analyse and improve the services offered by RAW

to meet contractual, legal and regulatory obligations

 

When will RAW contact me?

We may contact you:

In relation to any service you have enquired about, where you have opted to receive further correspondence and in relation to a service we have agreed to provide.

 

You may opt‑out of receiving marketing material and other information from us at any time.

 

How will RAW Manage my personal information?

When we interact with clients a certain amount of personal information is required. This includes

Customer Due Diligence information, which we are required to obtain by law as a business licensed

by the Guernsey Financial Services Commission, in order to provide Our services to you. Your

information is protected under the Data Protection (Bailiwick of Guernsey) Law, 2017 (“the Law”)

and we have taken steps to ensure compliance with the provisions of the Law.

 

Howsoever collected, information shall be collected and held by RAW Capital Partners Limited,

RAW Wealth Management Limited, or RAW Alpha PCC Limited (the “Companies”) unless otherwise noted below and, as such, we are the controller for the purposes of the Law. The Company may not hold your data exclusively in Guernsey because, for example, it uses cloud based data storage from reputable providers such as Microsoft, in addition to local data storage.

 

Are other parties involved and how will they handle my data?

The Funds managed by RAW are held in a separate company, RAW Alpha PCC Limited, as required by law and Guernsey regulation.  RAW Alpha PCC Limited is also a controller for the purposes of the Law and utilises an independent administrator, independent custodian and auditor.  Each of these independent parties will be a processor of data and is required to comply with the same regulations. In addition, the independent administrator will be a controller for the purposes of the Law with regard to certain information such as client due diligence.

 

Personal data collected from you directly or by the other means described shall only be utilised for

the purpose of entering into and maintaining a contract with you and providing services. It shall be

held at all times in accordance with and for as long as Our statutory and regulatory requirements

require it. This includes a retention period following the cessation of Our provision of services to you,

which shall, at all times, be determined by our legal and regulatory obligations. As soon as such

obligations cease to apply, we shall permanently erase all personal information held on you from Our

records.

 

From time to time, we may undertake checks utilising accredited screening software, which searches

publicly available databases; provide your information to outsourced service providers or be

required to provide your information to law enforcement; the regulator(s) and/or associated parties

because of Our legal obligations. This may require information to be submitted to the United

Kingdom, EU or other jurisdictions. We shall not provide your information to any other third parties

(e.g. for marketing purposes) without your express consent and acknowledge that such consent may

be withdrawn by you at any time.

 

If at any time you believe we hold information in error or that the information we hold on you is

inaccurate or incomplete, you may submit a request to us to consider rectifying and/or erasing it.

 

If at any time you are concerned with the information held, the way in which we hold it or are

unhappy with any response from us in relation to information held or with any other element

relating to your personal information, you may lodge a complaint.  We would ask that you contact us n the first instance and we will seek to resolve any concerns as soon as possible. You also have a right to lodge a complaint directly with the Guernsey Data Protection Commissioner at:

 

Guernsey Information Centre

North Esplanade

St. Peter Port

Guernsey

GY1 2LQ

 

Details of the complaints and appeals processes are available on their website at www.dataci.gg.

 

Cookies, Web Statistics and third-party monitoring

We maintain continuous logs of web server activity. These log files include the details of website users’ IP address, browser type and page last visited etc. The log files are used to analyse how the website is being used by visitors and may be kept in an anonymised form for historical records.

Our website uses hosted web analytics software. This hosted service is provided and managed by a third-party company (Google, Inc). The service ‘Google Analytics’ uses ‘cookies’ (a text file sent to users’ computers as they browse Our website) to help analyse how users navigate Our website. The information generated by the cookie regarding Our website (including IP addresses) will be anonymised and transmitted to and stored by Google, Inc. on servers that may be hosted in the United States. Google, Inc. will use this information for evaluating use of Our website, compiling reports on website activity for website operators and providing other related services to RAW Capital Partners and RAW Wealth Management.

Google, Inc. may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google, Inc’s. behalf. Google, Inc. will not associate your IP address with any other data held by Google, Inc. You may decline the use of cookies by configuring your web browser to do so, but it may affect your user experience. By using this website, you consent to the processing of data about you by Google, Inc. in the manner and for the purposes set out above.

 

Can I find out what personal information RAW holds about me?

Under the Data Protection Law, you have the right to request a copy of the Personal Information We hold about you and to have any inaccuracies corrected. (Information requests are free, though we reserve the right to charge a small fee where more than one copy is requested or where the request is unfounded, repetitive and/or excessive, and we will require you to prove your identity with 2 pieces of approved photographic identification.) We will use reasonable efforts to supply, correct or delete personal information about you on Our files within 30 days of the request.

This privacy policy may be updated from time to time so you may wish to check it each time you submit personal information to RAW Capital Partners Limited, RAW Wealth Management Limited or RAW Alpha PCC Limited.

The primary point of contact for all data protection purposes is lisa@rawcapitalpartners.com. Should you wish to make contact or require any further information on any of the above, please contact tim@rawcapitalpartners.com.

.