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ETF Partners LLP is a Limited Liability Partnership registered in England and Wales (Company Number OC31208) and with Registered Office at 25 Hill Street, London, W1J 5LW. ETF Partners LLP is authorised and regulated by the Financial Conduct Authority (FRN 453441).

ETF will be the ‘controller’ of the personal data you provide. ETF takes your privacy seriously. This policy statement is to explain to you what personal data we hold, how and why we may collect it, and the measures we take to protect it. If you have any questions regarding this statement, please email us at [email protected] This statement is applicable to any personal data that we have collected, or will collect.

What personal data does the Firm collect?
We may store personal information relating to you, such as name, job title, employer and contact details if:
i. you have had contact with ETF, for example through an email or meeting a member of the team.
ii. you are a supplier / service provider to ETF.
iii. you submit a CV or business plan to ETF.
iv. you are involved in a transaction that also involves ETF, for example as a co-investor or investee company.
v. You are, or work for, an investor or potential investor in ETF’s funds.
In the case of iv. and v. above, in order to verify identity, we may also store previous employment details, nationality information, references provided by third parties, and the results of due diligence checks carried out.
When you access our website, or contact us via the website, we may collect information about your visit and your web browsing via cookies. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Website.

Why do we hold personal data?
We take all reasonable steps to ensure the information above is collected and processed in a lawful manner, such that at least one of the following applies:
• You have given your consent.
• It is necessary for the performance of a contract for ETF to provide a service to you, or for you to provide a service to ETF.
• It is for the purpose of compliance with a legal obligation.
• It is necessary in order to protect the vital interests of you or another person.
• It is necessary for the performance of a task carried out in the public interest.
• It is necessary for the purposes of ETF’s (a third party’s) legitimate business.

Data retention
We will retain any personal data for no longer than is required for the purpose for which it is collected or is required by law or regulation.

Sharing of data
The personal information we hold may be shared with:
• Professional advisers, such as lawyers, accountants, or other consultants.
• Companies who process / store data on ETF’s behalf, such as cloud hosting solutions and outsourced providers. We do not authorise these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
We also may disclose, announce, retain, copy or preserve data if we are required to by law, court order or any governmental, regulatory or supervisory body.

Data accuracy and security
We take all reasonable steps to make sure your data is accurate, and to protect it from unauthorised access and against unlawful processing, accidental loss and/or damage.
The data which we hold may be transferred to a destination outside the United Kingdom (“UK”). We will take all reasonable steps to ensure that the data is treated in accordance with the Data Protection Legislation.

What are my rights?
Once you have provided your details to ETF you have certain rights, which apply depending on your relationship with ETF and depending on ETF’s legal and regulatory obligations, as follows:
• You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email ETF. The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.
• You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.
• As a client, you have the right to request that any information the Firm holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as ‘data portability’.
• You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact ETF.
• You have the right to object to your information being processed, for example for direct marketing purposes.
• You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
• You have the right to object to any decisions based on the automated processing of your personal data, including profiling.
• You have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/ if you are not happy with the way that we manage or process personal data.

Business Updates
We may use personal information that we hold to send you business updates about ETF’s investments, and other news which we feel may interest you. You have the right at any time to stop us from contacting you. You can also unsubscribe from any business updates email using the links provided in the emails we send to you.

Policy Changes
ETF may, from time to time, review and update this policy. ETF will maintain the latest version of this policy on its website, and where the changes are deemed material, it will make you are aware of these.
Links and Social Media
Our website may provide links to other websites for your information. These websites may operate independently from us, and we are not responsible for their privacy practices. They may have their own privacy notices or policies, which we suggest you review.

COOKIES
This policy describes the cookies used on ETF’s website. ETF uses cookies to help personalise your use of our sites.
An HTTP cookie – commonly referred to as just “cookie” – is a parcel of text sent back and forth between a web browser and the server it accesses. Without a cookie, a web server cannot distinguish between different users, or determine any relationship between sequential page visits made by the same user. For this reason, cookies are used to differentiate one user from another and to pass information from page to page during a single user’s website session. A web server uses cookies to collect data about a given browser, along with the information requested and sent by the browser’s operator (the visitor). Cookies do not identify people, but rather they are defined themselves by a combination of a computer, a user account, and a browser. This information may include information relating to your use of our site, information about your computer such as the computer’s IP address and browser type, and, if you arrived at our site via a link from third party site, the URL of the linking page. For more information, please visit http://www.allaboutcookies.org.
You can delete cookies from your hard drive at any time however this will mean that any settings such as your stored username and password will have to be reset. You can also set your internet browser so that it will not allow cookies to be stored on your computer.
The cookies used by ETF are as follows:

Analytics Cookies
ETF uses Google Analytics, a web analytics service provided by Google, to track user visits. Google Analytics tracking uses cookies in order to provide meaningful reports about site visitors but does not collect personal data about website visitors.
Google stores the information collected by the cookie on servers in the United States. Google 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’s behalf. Google will not associate your IP address with any other data held by Google. By using www.etfpartners.capital you consent to the processing of data by Google in the manner and for the purposes set out above. For more information on the cookie set by Google Analytics, including information on how to opt out please go to:
https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
and http://www.google.com/intl/en/privacypolicy.html

Session Cookies
Session cookies are created temporarily in your browser’s subfolder while you are visiting a website. Once you leave the site, the session cookie is deleted. These are used to remember the user’s state – whether you are logged in or not, and which user account (if any) you are linked to. The session cookie persists in your browser otherwise you would have to authenticate each time you visited a new page.

CSRF Cookies
These are being used to prevent Cross Site Forgery, specifically to secure the login form used on the site. These allow ETF to prevent data being submitted from other sites/servers and ensure that only requests originated from the ETF site itself are processed. These cookies store no information regarding the user.
Who should I direct questions to?
If you have any questions, concerns or complaints about the practices contained within this policy, or on how ETF has handled your data, please email [email protected] Alternatively, you may write to: ETF Partners LLP, 25 Hill Street, W1J 5LW, London, United Kingdom.