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Data Privacy Statement

DATA PROTECTION NOTICE

EPIC Investment Partners (Ireland) Limited Privacy Policy

EPIC Investment Partners (Ireland) Limited, (“EPIC Ireland”), is a company incorporated in Ireland with private limited liability (registered no. 609802, registered office: Level 3, River House, Blackpool Retail Park, Cork T23 R5TF) and is authorised by the Central Bank of Ireland as a financial service provider under the Investment Intermediaries Act, 1995 (as amended) and/or approved under the relevant collective investment scheme legislation as appropriate; UCITS Management Company under the European Communities (Undertakings for Collective Investment in Transferable Securities; and Alternative Investment Fund Manager.

EPIC Ireland is part of the EPIC group of companies (EPIC group), which comprises a number of separate companies undertaking business in various jurisdictions. For further details of companies within the group, please see our website www.epicip.com

EPIC Ireland is committed to safeguarding and handling your personal data with care and protecting your privacy. This Privacy Policy explains how your Personal Data will be handled by EPIC Investment Partners (Ireland) Limited (EPIC Ireland, the Firm, "we", "us" and "our") and sets out the information including the personal information detailed below relating to you ("Personal Data") that will be collected and processed by EPIC Ireland and/or on its behalf by its third party service providers in the context of your dealings with us.

1. Who is responsible for your personal data?

EPIC is the controller of and responsible for your personal data
EPIC Ireland has established procedures in place to ensure that your Personal Data is protected. If you have any questions or concerns about this notice, please email the EPIC Ireland’s Data Protection Officer at DPO@epicip.com

2. Application of this notice

IMPORTANT: please note that this Notice, while intended to be as complete and accurate as reasonably possible, is not exhaustive and may be updated from time to time in accordance with section 10 of this Notice.

This Notice is separated into a number of sections, some or all of which may be relevant to you depending on the nature of your relationship with EPIC Ireland. In all cases, you have certain rights under data protection law which are set out in section 9. In particular, you have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.

Marketing & Business Contacts: if you have signed up to receive marketing communications from us, you can read about how we will use your Personal Data for this purpose at section 4.1.

Website Users: if you use our website, [www.epicip.com], (the "Website"), you can read about how we use your Personal data as a website user at Section 4.2. Please also refer to our Cookie Policy, which explains how we use cookies and other web tracking devices via our website.

Social Media Users: if you use our social media accounts, you can read about we use your Personal data as a social media user at section 4.2.

Existing Customers: if you are an existing customer of EPIC Ireland, you can understand how we process your Personal Data for administrative and business purposes at section 4.3.

3. What personal data do we collect?

The personal data that we collect depends on how you interact with us and our products and services. The following are the specific types of personal data or information we may collect:

  • If you are a marketing/business contact, your name, your employment details, your contact details, your business activities and interests and information relating to your subscription to, receipt of or interest in any of our mailing lists or newsletters,
  • If you use this website, technical data including internet protocol (IP) address, your login data, information about how you use our website, the browser software you use and the date and time you access the Website,
  • If you interact with our social media accounts, we collect Personal Data about you such as name, location, country, employment details, business activities, area of interest, provided that these types of personal data are publicly visible from your social media accounts,
  • If you are a customer: name, contact details, bank details, tax details, investment details, transaction details, identification and verification documents, details of your visits to our premises and your correspondence and communications with members of our staff, how you use our products and services, information collected from publicly available resources, and any information which is provided to us by you or on your behalf.

This personal information may, from time to time, include personal data about your membership of a profession or trade association and details of any criminal record you may have.

4. How and for which purposes will we use your personal data ?

4.1 Marketing and Business Contacts

If you are a marketing/business contact we may obtain, collect, and process your Personal Data for the following purposes:

  • To promote EPIC Ireland's business activities;
  • To invite you to events;
  • To develop and maintain relationships with you;
  • To manage and administer our relationship with our business contacts and with our customers;
  • To send you marketing material, newsletters, and other information;
  • To monitor and analyse your interest in the material we send to you;
  • To send you marketing information by post provided you have not objected to this; and
  • To take, collect, store and post photographs from EPIC Ireland events.

In these circumstances we generally rely on your consent to provide you with information about our products and services through direct marketing. In all other circumstances, including where we are already in contact with you, we rely on our legitimate interest to continue to contact you about products which we think may be of interest to you.

You will always have the opportunity to stop receiving marketing communications. With postal communications you can opt out using the contact details in section 10. [You can always opt out of email marketing from us by clicking the "unsubscribe" link at the bottom of marketing emails which we send you.]

4.2 Website users

If you visit our Website we may obtain, collect, and process your Personal Data for the following purposes:

  • To provide, improve, test, and monitor the effectiveness of the Website;
  • To monitor metrics such as total number of visitors, traffic data and demographic patterns;
  • To ensure content on the website is presented in the most effective manner for you and to enhance your use of the website; and
  • To notify you of any changes to the Website and/or our services.


We obtain, collect, and process this personal information based on our legitimate interest in ensuring that the Website is operating smoothly and in order to analyse which content is of most interest to visitors. This helps us to keep the Website available and to improve your experience when you visit the Website.

4.3. Existing customers

As an existing customer, we may obtain, collect, and process your Personal Data for the following purposes:

  • To conduct administrative, billing, and operational processes;
  • To review and respond to any correspondence or queries you send us;
  • To monitor sales levels and review sales patterns;
  • To conduct due diligence checks;
  • To fulfil orders and comply with our obligations under any contract of sale we may have with you;
  • To process any financial payments and manage your customer account;
  • To enter into contractual relations with the organisation with which you are connected;
  • To send you marketing information. Please see section 4.1 of this Notice for further information.
  • To comply with applicable Member State and European Union company law;

We obtain, collect, and process your Personal Data for the above purposes based on the following legal bases:

  • our legitimate interest to ensure the operation of our business and the maintenance of our customer relationship with you;
  • a necessity in order to enter into and perform a contract with you;
  • a necessity to process your Personal Data in order to comply with a legal obligation under applicable Member State and European Union law to which we are subject. In the event that you do not wish to provide us with your Personal Data so that we can process it for the purposes outlined above, we will not be able to provide services or sell products to you.

5. With whom will we share your personal data ?

Depending on your dealings with us, we may disclose some or all of the Personal Data we collect from and obtain about you to the following parties: other companies in the EPIC group, acting as processors, where required for the purposes of providing products or services to you and for administrative, billing and other business purposes, members and shareholders of EPIC Ireland, service providers who provide support services, IT & website service providers, marketing companies, PR agencies, printers, advertising agencies and other suppliers, other people in your organisation, third parties involved in hosting or organising events or trade fairs, professional advisors such as tax or legal advisors, consultants and accountants, regulatory authorities (e.g. enforcement agencies and public bodies) and third parties in connection with the sale or purchase of EPIC Ireland or assets owned by EPIC Ireland.

When engaging with third party service providers (intra EPIC group or external party), we will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers.

We will otherwise only disclose your personal data when you direct us or give us permission to do so, when we are required by applicable law or regulation to do so, or as required to investigate actual or suspected criminal or fraudulent activities. We will not share your personal data with any company outside EPIC Ireland for marketing purposes unless we first obtain your express opt-in consent.

6. International transfers of your personal data

We may transfer your Personal Data outside of the European Economic Area ("EEA") to other members of EPIC Ireland and other recipients. Certain Recipients (our third party service providers and other EPIC connected companies) who process your Personal Data on our behalf may transfer your Personal Data outside the EEA to a country that does not provide an adequate level of protection to your Personal Data. Where such transfers occur, it is our policy that: a) they do not occur without our prior written authority; and b) that an appropriate transfer agreement is put in place to protect your Personal Data. If you would like to find out more about any such transfers, please contact our Data Protection-Officer whose details are set out in Section 10 of this notice.

7. How do we protect your data?

We take the appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal policies and procedures covering the storage, disclosure of, and access to personal data.

8. For how long will we retain personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements, or until you withdraw your consent (where applicable), and provided that in each case we are not legally required or otherwise permitted to continuing storing such data. If you would like to know more about how long we will retain your Personal Data, please contact our Data Protection Officer whose details are set out in Section 10 of this notice.

9. What are your rights and how do you exercise them?

You have a number of specific rights in relation to your Personal Data, to keep you informed and in control of the processing of your personal data. In particular these rights include the right to object to processing of your Personal Data where that processing is carried out for our legitimate interests. It is important to note that these rights are not absolute, and are subject to a number of limitations and restrictions.

Right to Object to processing of Personal Data
You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests and the right to object to direct marketing. When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by Member State or European Union law).

Right of Access
You have the right to request a copy of the Personal Data held by us about you and to access the information which we hold about you. EPIC Ireland will action the request without undue delay, subject to certain limitations or where the right may “adversely affect the rights or freedoms of others”.


Right to Rectification
You have the right to have any inaccurate Personal Data which we hold about you updated or corrected, without undue delay.

Right to Erasure
In certain circumstances, you may also have your personal information deleted, for example, if you exercise your right to object and we do not have an overriding reason to process your Personal Data or if we no longer require your Personal Data for the purposes as set out in this notice. (consider retention periods)


Right to Restriction of Processing
You have the right to ask us to restrict processing your Personal Data in certain cases, including if you believe that the Personal Data we hold about you is inaccurate or our use of your information is unlawful. If you validly exercise this right, we will store your Personal Data and will not carry out any other processing until the issue is resolved.

Right to Data Portability
You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible. This right only arises where: (1) we process your Personal Data with your consent or where it is necessary to perform our contract with you; and (2) the processing is carried out by automated means.

If you wish to exercise any of the rights set out above, please submit a request to our Data Protection Officer in writing to River House, Blackpool Retail Park, Cork, T23 R5TF, Ireland.

We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within 1 month of receiving your request. We may extend this up to 2 months if necessary, however we will inform you if this arises. Please note that we may ask you to verify your identity when you seek to exercise any of your data protection rights, in order to prevent the unauthorised disclosure of your personal data.

You will not usually have to pay a fee to access your personal data, but we reserve the right to charge you a reasonable administrative fee for (or we may refuse to comply with) any manifestly unfounded or excessive requests or any additional copies of the personal data you request from us.
You also have the right to lodge a complaint with the Data Protection Commission. For further information see www.dataprotection.ie.

10. Changes to this notice and questions

We may amend this Notice on occasion, in whole or part, at our sole discretion. Any changes will be effective immediately upon communicating the revised notice to you. If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail or post, and you will have a choice as to whether or not we use your Personal Data in the new manner.

If you have any questions, comments or concerns about the way your Personal Data are being used or processed by the Company, please submit your question, comment or concern in writing to our Data Protection Officer at DPO@epicip.com or by post to River House, Blackpool Retail Park, Cork, T23 R5TF, Ireland.