This privacy notice (“British Virgin Islands’ Privacy Notice”) explains the manner in which PHD Capital Ltd  and its Affiliates (“Group”) collect, process and maintain personal data about you. 

The Group is committed to processing personal data in accordance with applicable law, including the British Virgin Islands’ Data Protection Act, 2021.   In its use of personal data, certain members of the Group will be characterised under applicable law as a data controller, whilst certain of the Group’s service providers, affiliates and delegates may act as data processors under applicable law.  

Personal Data:
By virtue of acquiring Participating Shares, the Group and certain other service providers and their respective affiliates and delegates (“Authorised Processors”) may collect, record, store, transfer and otherwise process personal data by which individuals may be directly or indirectly identified. We may combine personal data that you provide to us with personal data that we collect from or about you. This may include personal data collected in an online or offline context including from our anti-money laundering checks and other available public databases or data sources, such as news outlets, websites and other media sources and international sanctions lists. It may also include data which, when aggregated with other data, enables an individual to be identified, such as an IP address and geolocation data. 

Why is your personal data processed:
The storage, processing and use of personal data by the Group will take place for lawful purposes, including: 

(1) to comply with any applicable legal, tax or regulatory obligations on the Group or another Authorised Processor under any      applicable laws and regulations;
(2) to perform a contract to which you are a party or for taking pre-contractual steps at your request;  
(3) to operate the Group;
(4) to verify the identity of the Group to third parties for any purpose which the Group considers necessary or desirable;
(5) to assist the Group in improving and optimising advertising (including through marketing material and content) its services; 
(6) for risk management and risk control purposes relating to the Group; 
(7) to pursue the Group’s or a third party’s legitimate interests: (i) for direct marketing purposes; or (ii) to help detect, prevent,      investigate, and prosecute fraud and/or other criminal activity, and share this data with legal, compliance, risk and managerial      staff to assess suspicious activities;
(8) and/or where you otherwise consent to the processing of personal data for any other specific purpose. 

As a data controller, we will only use your personal data for the purposes for which we collected it as set out in this British Virgin Islands’ Privacy Notice. If we need to use your personal data for an unrelated purpose, we will contact you. In certain circumstances, we may share your personal data with regulatory, prosecuting and other governmental agencies or departments, and parties to litigation (whether pending or threatened), in any country or territory.  

We may transfer your personal data outside of the British Virgin Islands, as permitted under applicable law. We will not sell your personal data. 

How we protect your personal data:

We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
All our employees and any third parties we engage to process your personal information are obliged to respect the confidentiality of your personal information. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted via our website – any transmission is at your own risk.
In the event of any data breach, we will act promptly to identify the cause and take the necessary steps to contain and mitigate the consequences of the breach. Where appropriate, we will also notify you of the breach in accordance with any applicable law which requires us to notify you of the breach.

Your rights:
You may have certain rights under applicable law, including: 

(1) the right to be informed as to how we collect and use your personal data;
(2) the right to access your personal data;
(3) the right to require us to stop direct marketing; 
(4) the right to have inaccurate or incomplete personal data corrected; 
(5) the right to withdraw your consent and require us to stop processing or restrict the processing, or not begin the processing, of      your personal data;  
(6) the right to be notified of a data breach (unless the breach is unlikely to be prejudicial); and 
(7) the right to require us to delete your personal data in some limited circumstances.  

We are required to obtain your personal data to fulfill our legal obligations and note that if you do not wish to provide us with requested personal data or subsequently withdraw your consent, you may not be able to hold or otherwise deal with the Participating Shares or remain as a holder of the Participating Shares as it will affect our ability to provide our services to you as a Participating Shareholder. 

Retention of Personal Data:
The personal data shall not be held by the Group for longer than necessary with regard to the purposes of the data processing. 

Changes to Privacy Notice:
We encourage you to regularly review this and any updated British Virgin Islands’ Privacy Notice to ensure that you are always aware of how personal data is collected, used, stored and disclosed.  

Contact Us:
Please contact the Group on if you have any questions or complaints about this British Virgin Islands’ Privacy Notice, the personal data we hold about you or to discuss your rights under applicable law.  


(1) If you are a corporate entity, this British Virgin Islands’ Privacy Notice will be relevant for those individuals connected to you and you should transmit this document to such individuals for their awareness and consideration

(2) Examples of personal data include: name, title, date of birth, age, gender, nationality, national identification number, usernames, email address, residential address, postal address, telephone / mobile / fax number, personal assets, bank account numbers and income details, financial and investment qualification, payment details, job titles, employment history, employer details, personal data contained in emails, personal data obtained pursuant to standard criminal record checks, and data obtained further to standard anti-money laundering and client due diligence checks.  

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