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Privacy Notice

Privacy NoticeThis Privacy Notice sets out how personal data is collected, processed and disclosed in connection with Phaunos Timber Fund Limited (the “Fund“).

We take privacy and security of your information seriously and will only use such personal information as set out in this Privacy Notice.

As a result of your investment (or an investment made by a person firm or entity with which you have a connection) in the Fund, your personal information may be provided to:

  • the Fund;
  • JTC Fund Solutions (Guernsey) Limited (the “Administrator“);
  • Link Market Services (Guernsey) Limited (the “Registrar“), (together, the Administrator, and the Registrar are referred to in this notice as the “Processors“).

The Fund is a data controller and is the issuer of this notice.  The Fund and its Processors may process your personal information or such data in respect of your directors, officers, employees or beneficial owners on behalf of the Fund.  Each of the
Processors may also act as data controllers independently of the Fund.

The Fund is an entity incorporated in Guernsey; accordingly it is obliged to comply with the provisions of the Guernsey Data Protection (Bailiwick of Guernsey) Law 2017.  To the extent that data subjects are EU citizens, the Fund may be required to comply
with the General Data Protection Regulation ((EU) 2016/679).

    1. Where we obtain your personal data:
      1. Your personal data comprises the following categories:
        1. information obtained from identification documentation (including name, contact details, nationality and national identity numbers (where applicable));
        2. employment history, income and personal wealth;
        3. tax status and tax identification numbers; and
        4. bank account details.
      2. We primarily collect your personal data from the following sources:
        1. from information which you or your authorised representative gives to us, including but not limited to:
          1. information set out in any subscription agreement with the Fund;
          2. such other forms and documents as we may request that are completed in relation to the administration/management of any investment in the Fund;
          3. client due diligence documentation as part of regulatory requirements in respect of the Fund; and
          4. any personal data provided by you by way of correspondence with us by phone, e-mail or otherwise
        2. personal data we receive from you or any third party sources which may include:
          1. entities in which you or someone connected to you has an interest;
          2. your legal and/or financial advisors;
          3. other financial institutions who hold and process your personal data to satisfy their own regulatory requirements;
          4. credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements; and
          5. information collected via email (e.g. traffic headers for analysing patterns of network traffic and managing client relationships).
      3. We may also collect and process your personal data in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act.
    2. Why we collect your Personal data:
      Lawful grounds for processing:

      1. The Fund and its Processors are entitled to hold and process your personal data on the following lawful grounds:
        1. the processing is necessary for the legitimate interests of the Fund provided your interests and fundamental rights do not override those interests;
        2. the processing is necessary to comply with our contractual duties to you under the terms of any subscription agreement with you and all supplemental agreements thereto;
        3. to comply with the Fund’s legal and regulatory obligations;
        4. (on exceptional occasions) where we have obtained your consent; and
        5. (on rare occasions) where it is needed in the public interest.

        Some of the grounds for processing described above will overlap and there may be several grounds which justify our use of your personal data.

        Inaccurate or Amended Information


      2. Please let us know if any of your personal data (including correspondence details) changes as soon as possible. Failure to provide accurate information or to update changed information may have a detrimental impact upon your investment, including
        the processing of any subscription or redemption instructions or the suspension of your account.  Failure to provide information where the same is required for anti-money laundering, pursuant to automatic exchange of information agreements, or
        other legal requirements means that the Fund may not, or may no longer, be able to accept you as an investor in the Fund.Purposes of processing
      3. Pursuant to paragraph 2.1 the Fund and its Processors may process your personal data for the purposes set out below (“Purposes“). Those based wholly or partly on our legitimate interests are set out in paragraphs 2.3.1 to 2.3.11

        1. communicating with you as necessary in connection with your affairs and generally in connection with your investment in the Fund;
        2. operating the Fund’s IT systems, software and business applications;
        3. supporting our IT and business applications support teams, accounting, legal, reporting, internal audit and risk management, administrative, transfer, document storage, record keeping and other related functions, including but not limited to
          processing personal data in connection with the Fund;
        4. monitoring and recording telephone and electronic communications and transactions:
          1. for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act); and
          2. to enforce or defend the Fund’s respective rights, or through third parties to whom we each may delegate such responsibilities or rights in order to comply with any legal or regulatory obligations imposed on each of us
        5. facilitating the internal administration of the Fund and retaining your personal data as part of our Regulatory Assessments or future services entered into by you;
        6. communicating with our professional advisers for the purposes of obtaining professional advice;
        7. detecting and preventing crime such as fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanction on
          an ongoing basis (“Regulatory Assessments“); and
        8. liaising with or reporting to any regulatory authority (including tax authorities) with whom the Fund is either required to cooperate or report to, or with whom it decides or deems appropriate to cooperate, in relation to an investment, and
          which has jurisdiction over the Fund or its investments in a third country without the same or similar data protection laws as Guernsey or any EU member state (a “Third Country without Adequacy“)

        We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal
        information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  Please note that we may process your personal information without your knowledge or consent, in compliance with the above
        rules, where these are required or permitted by law.


      4. To the extent that such personal data contains special category data such as, for example: data relating to racial or ethnic origin, political opinion, religious or philosophical belief, trade union membership or criminal data then the processing
        of such data shall solely be for the purpose of complying with any duty imposed on the Fund and its Processors by an enactment including, but not limited to, legislation and regulatory obligations relating to Anti-Money Laundering and Combatting
        the Financing of Terrorism and all other related legislation.
      5. The Fund and its Processors do not make decisions about you based on automated processing of your personal data
    3. Sharing personal data
      1. The Fund and its Processors may share your personal data with group companies and third parties (including bank, financial institution or other third party lenders, IT service providers, auditors and legal professionals) under the terms of any appropriate
        delegation or contractual arrangement. Those authorised third parties may, in turn, process your personal data abroad and may have to disclose it to foreign authorities to help them in their fight against crime and terrorism.
      2. Data processing (as described above) may be undertaken by any entity in the Bailiwick of Guernsey, the European Economic Area, an entity who is located outside the European Economic Area in a third country in respect of which the EU Commission has
        issued a decision in respect of the adequacy of that jurisdiction’s data protection laws. Data processing (as described above) may also be undertaken by any entity in a jurisdiction outside the European Economic Area and in respect of which the
        EU Commission has not issued a decision as to the adequacy of that jurisdiction’s data protection laws.  This means that certain of the countries to which we transfer your data are not deemed to provide an adequate level of protection for your
        personal information.  However, to ensure that your personal data receives an adequate level of protection we put in place measures such as EU model contract clauses to ensure that your personal information is treated by those third parties in
        a way that is consistent with and which respects the EU laws and the laws of the Bailiwick of Guernsey on data protection. If you require further information about these protective measures, you can request it by using the contact details in paragraph
        6 below.
    4. Retention of personal data
      1. Your personal data will be retained for the longest of the following periods:
        1. for the Fund, its Processors and any authorised third parties to carry out the Purposes for which the data was collected or as long as is set out in any relevant agreement you enter into with us);
        2. in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or
        3. any retention period that is required by Data Protection Laws and any applicable laws or regulatory requirements.
      2. We endeavor to store your personal data securely on the computers of our Processors (as applicable for a given processing function) and/or manually in accordance with accepted market standards.
      3. Whilst we have taken every reasonable care to ensure the implementation of appropriate technical and security measures, we cannot guarantee the security of your personal data over the internet, via email or via our websites nor do we accept, to
        the fullest extent permitted by law, any liability for any errors in data transmission, machine, software or operating error or any other cause.
    5. Your rights
      1. You have, under certain circumstances, the following rights in respect of personal data:
        1. the right to access and port personal data;
        2. the right to rectify personal data;
        3. the right to restrict the use of personal data;
        4. the right to request that personal data is erased;
        5. the right to object to processing of personal data; and
        6. where the Fund/its Processors has relied on consent to process the personal data, the right to withdraw consent at any time by contacting us via the contact details below.
      2. You also have the right to lodge a complaint with the Guernsey Data Protection Authority and/or a supervisory authority in the EU member state of your usual residence or place of work or of the place of the alleged breach if you consider that the
        processing of your personal data carried out by the Fund, its Processors or of any other service provider to the Fund, has breached data protection laws. You may also appeal to certain courts against (i) any failure of the Guernsey Data Protection
        Authority to give written notice of whether the complaint is either being investigated or not being investigated and where applicable, the progress and the outcome of the investigation and (ii) a determination of the Guernsey Data Protection Authority
        not to investigate the complaint or a determination that a controller or processor has not breached or is not likely to breach an operative provision in connection with the complaint.
      3. In limited circumstances we may approach you for your written consent to allow us to process certain particularly sensitive data or to use data for another purpose. Where you may have provided your consent to the collection, processing and transfer
        of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw such consent, please contact us at the contact details listed in paragraph 7 below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
    6. Data protection manager We have appointed a data protection manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the data privacy manager. You have the right to make
      a complaint at any time.
    7. How to contact us:If you have any questions about our use of your personal data, our retention procedures or our security processes, please contact Jonathan Burt at Alternatively, please contact the Fund or Administrator at Ground Floor, Dorey Court, Admiral Park, St Peter Port, Guernsey, GY1 2HT.
    8. Changes to this Policy This Privacy Notice is dated 24 May 2018.We reserve the right to amend this Privacy Notice at any time without notice, in which case the date of the policy will be revised.



By accessing this website you are representing to Phaunos Timber Fund Limited (the “Company”) and its advisers that you are not: (i) a US Person and are not acting on behalf of a US Person, nor purchasing with a view to re-sale in the US or to or for the account of a US Person, and that you are not an employee benefit plan subject to the United States Employee Retirement Income Security Act of 1974 and the regulations promulgated thereunder (in each case as amended) (“ERISA”) or similar US laws or an individual retirement account as defined in section 408 of the US Internal Revenue Code; or (ii) a resident of Australia, Canada, Japan, the Republic of South Africa or a jurisdiction where the extension of availability of the materials to which you are seeking access would breach any applicable law or regulation, and that you will not: (i) offer, sell, pledge, renounce, distribute, transfer or deliver, directly or indirectly, Shares subscribed for by you into or within the United States, Australia, Canada, Japan, the Republic of South Africa or in any jurisdiction in which such offers or sales are unlawful (“Excluded Territories”) or to any US Person or resident of Australia, Canada, Japan, the Republic of South Africa or any Excluded Territories, or: (ii) release or otherwise forward, distribute or send any materials on this website into or within the United States, Australia, Canada, Japan, the Republic of South Africa or any Excluded Territories.

Shares offered by the Company have not been and will not be registered under the United States Securities Act of 1933 or with any securities regulatory authority of any State or other jurisdiction of the United States and, subject to certain exceptions, may not be offered or sold within the United States or to, or for the account or benefit of, US Persons (within the meaning of Regulation S under the Securities Act). The Company has not been and will not be registered as an “investment company” under the United States Investment Company Act of 1940 and investors will not be entitled to the benefits of that Act. In addition, relevant clearances have not been, and will not be, obtained from the securities commission (or equivalent) of any province of Australia, Canada, Japan, the Republic of South Africa or any Excluded Territories and, accordingly, unless an exemption under any relevant legislation or regulations is applicable, none of the Shares may be offered, sold, pledged, renounced, distributed, transferred or delivered, directly or indirectly, into or within Australia, Canada, Japan, the Republic of South Africa or any Excluded Territories.

Use of the Company’s website and the Materials are at your sole risk. The Company will not be liable to any person for any direct, indirect, special or consequential losses, damages, or awards of any kind, howsoever caused, as a result of the use of or inability to use, or reliance on, the Company’s website or any of the Materials. To the maximum extent permitted by law, the Company excludes all warranties, conditions, terms, undertakings, and representations (excepting fraudulent misrepresentation) of any kind, express or implied, statutory or otherwise in connection with the Company’s website and the Materials. Nothing in these terms and conditions shall be taken to limit or exclude any liability which may not otherwise be limited or excluded under applicable law.

Nothing in this website should be construed as investment, tax, legal, or other advice, nor is it to be relied upon in making an investment decision. Those accessing the website should consult their financial advisers regarding the suitability of any of the products referred to on this website. The value of investments and the income from them may go down as well as up and an investor may receive back less than the original investment; past performance is not necessarily a guide to future performance.

The Materials and the Company’s website are provided on an “as is” and “as available” basis and do not purport to be full or complete. The Company gives no warranties (express, implied, or statutory) as to satisfactory quality or fitness for purpose of the Materials, including, without limitation, as to the accuracy, validity, timeliness, merchantability, or completeness of any information or data contained therein (whether prepared by the Company or by any third party), or that any of the Materials or the Company’s website will be provided uninterrupted or free from errors or that any identified defect will be corrected. The Company has the right to suspend or withdraw the provision of all or any of the Company’s website or the Materials without prior notice at any time. You are entirely responsible for your use of the website and for the consequences of relying on any content. Further, no warranty of any kind is given that the Company’s website and the Materials are free from any virus or other malicious, destructive, or corrupting code, program, or macro. The Company does not warrant that the Company’s website or the server(s) that make(s) them available are free of any virus or other harmful elements.

To the maximum extent permitted by law, the Company disclaims all liability to you arising out of your use of the website. In particular, the Company shall not be liable for any direct or indirect loss or damage to you, any loss of profits, loss of business, revenue, data, goodwill, or anticipated or consequential loss or damage.

Reference in the Company’s website or the Materials or the Company’s website and the Materials to any hypertext link, product, process, or service does not imply the Company’s support for, or endorsement or recommendation of the provider thereof or the product, process, or service to which reference is made. The Company’s website may contain hypertext links to other websites, resources, or other third parties. The Company is not responsible for the availability of, and accepts no liability in relation to, these external websites or their contents. The Company is not a sponsor, partner, promoter, or publisher of any such website.

Shares in the Company are meant only for non-retail investors. As such, in accordance with the guidance published by the European supervisory authorities, the Company is not required to prepare a “key information document” for this product pursuant to Regulation (EU) 1286/2014 of the European Parliament and the Council on key information documents for packaged retail and insurance-based investment products.

The agreement between you and the Company relating to your use and browsing of the Company’s website is governed by and shall be construed in accordance with the laws of England and Wales and you agree that the Courts of England shall have exclusive jurisdiction over any disputes arising in relation to such use and browsing. These terms and conditions may not be modified unless the Company agrees in writing.

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