Privacy Policy

General

Horizon Asset LLP ("Horizon Asset", the "firm" or "we") are committed to safeguarding the personal data which you may provide to Horizon Asset (whether through this site or otherwise) or that Horizon Asset itself may collect (including data collected when you visit our website). Horizon Asset LLP is a data controller in respect of any of your personal data which we hold for the purposes of UK data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are responsible for ensuring that we use your personal data in compliance with applicable data protection law.

This privacy policy is organised into four sections. Please read the sections applicable to your circumstances. Section 4 applies to all:

1. Prospective employees: this covers personal data you supply to the firm when you apply for a job at the firm or that the firm may collect about you in connection with such application.
2. Prospective or current investors: this covers information you supply to Horizon and its Investor Relations team as a prospective or current investor.
3. Website and office visitors: this covers information supplied or collected by Horizon from those who visit its website or offices.
4. Your rights and how to contact us — applicable to all.

In each case this policy describes how Horizon Asset collects, uses and processes your personal data, and how, in doing so, it complies with its legal obligations to you. We may amend this privacy policy from time to time and updates will be posted here.

Identity and Contact Details of Data Controller

With respect to each of the circumstances referred to above, Horizon Asset LLP is the data controller. Contact details are:

1. Privacy Notice for Prospective Employees

What kind of personal data does Horizon collect?

In order to assess your suitability for any employment opportunities that may be available, Horizon needs to process certain pieces of information about you. We will only ask for details that will assist us in this process, such as your name, contact details, education details, employment history, immigration status and references.

How does Horizon collect personal data?

Horizon may collect personal data through a range of means. These may include:

• direct interactions: where you provide personal data to us through telephone or email correspondence or other direct methods of communication, in CVs/job applications;
• from third parties: such as recruitment firms;
• other publicly available sources (such as websites (for example, LinkedIn) or publicly available registries (for example, FCA or other regulatory registers));
• your referees may share personal information about you with Horizon; and
• in some cases we may advise you that we will seek to do a background check — this will require you to sign a release form.

How does Horizon use your personal data?

Your personal details may be used by Horizon to help us: (a) contact you to discuss your application and arrange any interviews; (b) assess your suitability for the role that you have applied for; (c) carry out background checks including criminal record checks, verification and referencing on you as a candidate (however background and criminal record checks will only be carried out once you have been offered a role and with your consent); (d) carry out Horizon's obligations relating to any potential contracts entered into between Horizon and you; and (e) comply with legal or regulatory obligations applicable to Horizon.

The provision and processing of your personal data is necessary for Horizon in the context of your potential employment. Without the ability to process your personal data, Horizon would not be able to assess you for employment at the firm and therefore this is necessary for the legitimate business interests of the firm as part of its pre-employment screening.

Who does Horizon share your personal data with?

Your personal data may be shared with Horizon's affiliates for the purposes of candidate selection and appointment. Your personal data may also be shared with third party suppliers who provide screening and testing services to the firm as well as legal, tax and HR advisers and third party recruiters. If references are sought Horizon will also share your personal data with previous employers and referees.

How long does Horizon retain your personal data?

If your application does not proceed to employment with Horizon we may retain your personal details for up to six months after the position you applied for is filled. After that point Horizon's policy is to delete your personal data from its systems unless Horizon believes in good faith that the law or other regulation requires Horizon to retain it, or if Horizon considers that you may be suitable for an alternative role for which it is hiring. If you do receive an offer of employment, further details shall be provided to you on or before your start date regarding how your personal data may be used for the purposes of your employment.

Transfer of personal data outside the United Kingdom

Your personal data may be transferred to, and stored at, a destination outside the United Kingdom ("UK"). It may also be processed by individuals operating outside of the UK who work for our affiliates or for one of our suppliers.

Where we transfer your personal data outside the UK, we will ensure that it is protected by appropriate safeguards in accordance with UK GDPR. This can be done in a number of ways, for instance:

• the country that we send the data to may be subject to UK adequacy regulations, as determined by the UK Secretary of State;
• the recipient may have entered into a UK International Data Transfer Agreement (IDTA) or a UK Addendum to the EU Standard Contractual Clauses, obliging them to protect your personal data; or
• where the recipient is located in the US, it may participate in the UK-US Data Bridge.

In other circumstances the law may permit us to otherwise transfer your personal data outside the UK. In all cases, however, we will seek to ensure that any transfer of your personal data is compliant with applicable data protection law. You can obtain more details about the protection given to your personal data when it is transferred outside the UK by contacting us using the details above.

Incidental personal data processed via email

During the recruitment process, we may receive certain personal data, such as the name, address, email and/or telephone number of a recruiter or referee. In such circumstances, the personal data of that contact may be retained on a general contact database maintained by Horizon or a third party service provider, and/or in Horizon's email storage system, for as long as is necessary to process the personal data for the purpose for which Horizon is using it and to comply with our legal and regulatory obligations.

2. Privacy Notice for Prospective or Current Investors

If you invest in a vehicle Horizon manages, the vehicle or its administrator will give you a separate privacy notice covering your onboarding and the ongoing administration of your investment. That notice governs that processing. This section covers the personal data Horizon itself holds about prospective and current investors.

What kind of personal data does Horizon collect?

In order to provide you with information about Horizon and the investment vehicles and mandates it manages it may be necessary for Horizon to process certain personal information such as your name and contact details, and information required to classify you as a professional investor (under the UK FCA rules) who is located in a jurisdiction into which we are permitted to market. For current investors, this may also include records of our correspondence and meetings with you, and information about your investment that we receive from the administrator of the relevant vehicle.

How does Horizon collect personal data?

Horizon may collect personal data through a variety of means. These may include:

• direct interactions: where you provide personal data to Horizon through telephone or email correspondence or other direct methods of communication, including applications to invest in the investment vehicles Horizon manages;
• from third parties: such as intermediaries, financial advisers and banks in the case of prospective investors;
• from the administrator of the relevant vehicle, in the case of current investors; and
• other publicly available sources such as websites.

How does Horizon use your personal data?

Information about prospective investors may be used by Horizon: (a) for the purpose of reviewing a potential investment in the relevant vehicle; (b) assessing an investor's appropriateness (as a professional investor) to invest in the relevant vehicle; (c) to carry out Horizon's obligations relating to contracts to be entered into between the relevant vehicle and you; (d) for the general administration of potential investments into the relevant vehicle; and (e) to comply with legal or regulatory obligations and industry standards.

Information about current investors may be used by Horizon: (a) to provide investor relations services, including meetings and calls with you, and to keep records of them; (b) to send you investor letters, reports and updates about the relevant vehicle; (c) to answer your queries; and (d) to comply with legal and regulatory record-keeping obligations.

In order to ensure Horizon provides you with an efficient investor relations service and access to information about Horizon and the relevant vehicle, Horizon may store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of conversations, meetings and investor preferences. The provision and processing of your personal data is necessary for Horizon in the context of your potential interest in the relevant vehicle and is necessary for the legitimate business interests of the firm as part of its investor screening and investor relations activities. Processing under (d) is necessary to comply with Horizon's legal obligations.

Who does Horizon share your personal data with?

Horizon may share personal data on prospective and current investors with the relevant vehicle, its board, its administrators and their affiliates, professional advisers such as law firms and accountancy firms, as well as other third party service providers, including technology service providers. These third parties will be subject to confidentiality requirements and they will only use your personal data as specified by us in the relevant agreement and to the extent required by law.

How long does Horizon retain your personal data?

How long Horizon will hold your personal data will vary. The retention period will be determined by various criteria, including the purposes for which Horizon is using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which the relevant vehicle has to keep your personal data).

Transfer of personal data outside the United Kingdom

Your personal data may be transferred to, and stored at, a destination outside the United Kingdom ("UK"). It may also be processed by individuals operating outside of the UK who work for our affiliates or for one of our suppliers.

Where we transfer your personal data outside the UK, we will ensure that it is protected by appropriate safeguards in accordance with UK GDPR. This can be done in a number of ways, for instance:

• the country that we send the data to may be subject to UK adequacy regulations, as determined by the UK Secretary of State;
• the recipient may have entered into a UK International Data Transfer Agreement (IDTA) or a UK Addendum to the EU Standard Contractual Clauses, obliging them to protect your personal data; or
• where the recipient is located in the US, it may participate in the UK-US Data Bridge.

In other circumstances the law may permit us to otherwise transfer your personal data outside the UK. In all cases, however, we will seek to ensure that any transfer of your personal data is compliant with applicable data protection law. You can obtain more details about the protection given to your personal data when it is transferred outside the UK by contacting us using the details above.

Incidental personal data processed via email

In the process of providing our investor relations service and information about Horizon and the investment vehicles and mandates it manages, we may receive certain personal data, such as the name, address, email and/or telephone number of a financial adviser or other contact of prospective investors. In such circumstances, the personal data of that contact may be retained on a general contact database maintained by Horizon or a third party service provider, and/or in Horizon's email storage system, for as long as is necessary to process the personal data for the purpose for which Horizon is using it and to comply with our legal and regulatory obligations.

3. Website and Office Visitors

This website is designed to minimise the collection of personal data. This website does not set cookies, and no cookie banner is required. This website makes no requests to third-party services.

Our hosting provider may collect standard server log information for security monitoring, including IP addresses, browser type and version, pages visited, timestamps, and referring website. This data is used solely for security monitoring and is not used to identify individual visitors. We retain server logs for 90 days.

If you contact us via email, we may process your name and email address, the content of your correspondence, and any additional information you provide voluntarily. We retain email correspondence for 7 years.

Our website is administered by a third party service provider. We do not sell or trade personal data. We may share information with our hosting provider, professional advisers (legal, tax, compliance), and regulators where required by law.

Please be aware that if you visit Horizon's offices, CCTV is in use for security purposes and you will be recorded in public areas. Many of our telephone lines are also recorded and monitored in accordance with regulatory requirements applicable to us.

4. Your Rights and How to Contact Us

This section applies to all persons whose personal data is processed by Horizon Asset.

Your rights

You have a number of legal rights in relation to the personal data that the firm holds about you. These rights include:

• The right to obtain information regarding the processing of your personal data and access to the personal data that the firm holds about you.
• In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and the right to request that the firm transmits that data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to Horizon.
• The right to request that the firm rectifies your personal data if it is inaccurate or incomplete.
• The right to request that the firm erases your personal data in certain circumstances. Please note that there may be circumstances where you ask the firm to erase your personal data but the firm is legally entitled to retain it.
• The right to object to, and the right to request that the firm restricts, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to or ask the firm to restrict processing, but the firm is legally entitled to continue or to refuse that request.
• The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by the firm.

You can find out more information about your rights under UK data protection law by contacting the Information Commissioner's Office at ico.org.uk.

International transfers

Your data may be processed in the UK or other jurisdictions in which Horizon Asset operates. Where data is transferred outside the UK, we ensure appropriate safeguards are applied in accordance with UK GDPR.

Security

We implement appropriate technical and organisational measures to protect personal data from unauthorised access, alteration, disclosure, or destruction.

Changes to this policy

We may update this Privacy Policy periodically. Any changes will be posted on this page with an updated revision date.

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data, or to exercise any of the rights listed above, please contact us at investorrelations@horizon-asset.co.uk. You can also raise a complaint with us about how we handle your personal data by emailing complaints@horizon-asset.co.uk.