Privacy Notice - Investors

Electronic versions of the materials you are seeking to access are being made available on this website in good faith and are for information purposes only.

These materials are not directed at or accessible by persons in the United States or persons resident or located in the United States, Australia, Canada, Japan, New Zealand, the Republic of South Africa, any EEA jurisdiction other than professional investors in Ireland, or any other jurisdiction where the extension of availability of the materials to which you are seeking access would breach any applicable law or regulation.

Users of this website are responsible for observing all applicable laws and regulations in their relevant jurisdictions before proceeding to access the information contained herein. By proceeding to access the information, users are deemed to be representing and warranting that the applicable laws and regulations of their relevant jurisdiction allow them to do so.

By accessing this website you are representing to International Public Partnerships Limited (the "Company") and its advisers that the applicable laws of your relevant jurisdiction allow you to access this website and the material contained herein and in particular that you are not: (i) a US Person (within the meaning of Regulation S under the US Securities Act of 1933, as amended the "Securities Act") 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, New Zealand, the Republic of South Africa, any EEA jurisdiction other than Ireland, 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, renounce, transfer or deliver, directly or indirectly, Shares subscribed for by you in (A) the United States, or (B) Australia, Canada, Japan, New Zealand, the Republic of South Africa, any EEA jurisdiction other than Ireland, or in any jurisdiction in which such offers or sales are unlawful ("Excluded Territories") or to any US Person or resident of any Excluded Territories, or: (ii) release or otherwise forward, distribute or send any materials on this website in or into the United States or any Excluded Territories.

Shares offered by the Company have not been and will not be registered under the Securities Act 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 any Excluded Territories and, accordingly, unless an exemption under any relevant legislation or regulations is applicable, none of the Shares may be offered, sold, renounced, transferred or delivered, directly or indirectly, in any Excluded Territories.

Unless expressly indicated otherwise on a particular document or section of this website, the contents of this website are not a UK financial promotion and none of the contents of this website constitute an invitation or inducement to engage in investment activity. If and to the extent that this website or any of its contents are deemed to be a financial promotion, the Company is relying on the exemption provided by Article 69 of the UK Financial Services and Markets Act 2000 (Financial Promotions) Order 2005/1529 in respect of section 21 of the UK Financial Services and Markets Act 2000.

In particular, any information in respect of past performance (including without limitation past performance of the Company, its group, shares in the Company and/or the Company’s portfolio) cannot be relied upon as a guide to future performance. None of the contents of this website are intended to be nor may they be considered as an investment recommendation nor personal advice.

The Company is a closed ended FTSE 250 listed investment company which is incorporated in Guernsey and is recognised as a third country self- managed AIF in very limited EEA jurisdictions under the EU Alternative Investment Fund Managers Directive and in the UK under the UK Alternative Investment Fund Managers Regulations 2013 (SI 2013/1773). The Ordinary Shares of the Company are excluded from the UK FCA restrictions on promotion that are applicable in the UK to non-mainstream investment products, due to its current investment company structure.

This website and the information contained herein does not and is not intended to constitute a direct or indirect offering or placement of shares in the Company or the provision of investment management, advisory or other services to any person in any jurisdiction in which such solicitation is not authorised or to any person to whom it would be unlawful to make such solicitation.

Save for the United Kingdom no action has been taken or will be taken in any jurisdiction by the Company that would permit a public offering of the Company's ordinary shares (the "Shares") in any jurisdiction where action for that purpose is required.

The Shares have not been, and will not be, registered under the US Securities Act of 1933, as amended (the ‘‘US Securities Act’’), or under the securities laws or with any securities regulatory authority of any state or other jurisdiction of the United States. The Shares may not be offered, sold, resold, transferred or delivered, directly or indirectly, within the United States or to, or for the account or benefit of US Persons (as defined in Regulation S under the US Securities Act (‘‘Regulation S’’)). The Company has not been, and will not be, registered under the US Investment Company Act of 1940, as amended (the “US Investment Company Act”), and investors will not be entitled to the benefits of that Act. No offer, purchase, sale or transfer of the Shares may be made except under circumstances which will not result in the Company being required to register as an investment company under the US Investment Company Act.

The Shares have not been approved or disapproved by the US Securities and Exchange Commission, any State securities commission in the United States or any other US regulatory authority, nor have any of the foregoing authorities passed upon or endorsed the merits of the offering of the Shares or the accuracy or adequacy of the Company's prospectus. Any representation to the contrary is a criminal offence in the United States.

The content of this Site is general in nature. The Site is not intended to provide specific investment advice including, without limitation, investment, financial, legal, accounting or tax advice, or to make any recommendations about the suitability of the Company for the circumstances of any particular investor. If you do require investment advice, please consult a suitably qualified professional adviser. You should take appropriate advice as to any securities, taxation or other legislation affecting you personally prior to investing.

Any person accessing the website should carefully review the Terms of Use of the website. By using the website, you indicate that you accept the Terms of Use and that you agree to abide by them. If you do not agree to the Terms of Use, please refrain from using the website.

The information, material and content provided in the pages of the website may be changed at any time. Changes may be made to these Terms of Use at any time without notice by updating this posting. You agree to review the Terms of Use regularly and your continued access to or use of the website will mean that you agree to any changes.

Other than the warranties and representations contained in these Terms of Use, all other warranties and representations by the Company or its advisers, whether express, implied or statutory are, to the fullest extent permitted by the law, excluded. The Company and its advisers do not exclude or restrict our liabilities or duties to you where or to the extent that this is prohibited by law or regulation. Use of this website is at your sole risk.

If any part of these Terms of Use is found by any court or other competent authority to be invalid, unlawful or unenforceable then such part shall be severed from the rest of the Terms of Use which shall continue to be valid and enforceable to the fullest extent permitted by law.

To the extent permitted by law, the Company and/or its advisers shall not be liable for any damage, loss or liability (whether arising in contract, tort, including negligence, or otherwise) arising out of or in connection with (i) your use of this website, (ii) your reliance on or your inability to use the information on this website, or (iii) any failure or performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure to this website or your use or attempted use of it.

The above exclusions apply to any damage which is direct, indirect, special, incidental or consequential or consists of loss of profits, business, opportunity or data. All of the above exclusions apply even if you have advised the Company of the possibility of the above types of damage, loss or liability.

No delay or failure by you or the Company to exercise any of the Company’s or your powers, rights or remedies under these Terms of Use shall operate as a waiver of them, nor shall any single or partial exercise of any such powers, rights or remedies preclude any other or further exercise of them. Any waiver to be effective must be in writing. The remedies provided in these Terms of Use are cumulative and not exclusive of any remedies provided by law.

The terms are governed by and interpreted in accordance with the laws of England and Wales and the courts of England will have non-exclusive jurisdiction in respect of any dispute, which may arise.

Please check the box below to confirm that:

You have read, understood and agree to the above;
You are not in the United States nor in any other jurisdiction where accessing this website may be prohibited by law or regulation;
You are not a US person or otherwise a resident of any Excluded Territory; and
You are not investing or otherwise acting for the account or benefit of a US person or a resident of any Excluded Territory.

I have read and accept the above terms and conditions

I have read the above and do not wish to access the website

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This Privacy Notice sets out how investors personal data is collected, processed and disclosed in connection with International Public Partnerships 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, Ocorian Administration (Guernsey) Limited (the "Administrator"), Link Market Services (Guernsey) Limited (the "Registrar") and Amber Fund Management Limited (the "Investment Manager") and certain other services providers to the Company or other third parties the Company authorises to process data for lawful purposes (the "Processors"). The Registrar will act as an independent data controller where processing data to comply with their own regulatory obligations (e.g. in relation to satisfying anti-money laundering/countering terrorist financing requirements) or otherwise where they, alone or jointly with others, determine the purposes and means of processing that personal information. The Processors may process your personal information or such data in respect of your directors, officers, employees or beneficial owners.

The Fund is obliged to comply with the provisions of The Data Protection (Bailiwick of Guernsey) Law, 2017 (the "DP Law").

This Privacy Notice should be read in conjunction with our website terms and privacy policy.

Where we obtain your personal data:

Your personal data comprises the following categories:
- information obtained from identification documentation (including full name, full date of birth, residential/registered address, signature and contact details such as telephone number and e-mail address, nationality, national identity numbers and insurance numbers, passport numbers and overseas identification card numbers (where applicable));
- professional qualifications, employment history, references and other details regarding your career history such as training records;
- income and source of personal wealth;
- tax status and tax identification numbers;
- information required for payroll, benefits and expenses purposes;
- bank account details;
- shareholding in a company/ies;
- where necessary information regarding your investment activity or health;
- any information about you that you disclose to us when registering your interest via our website;
- communication method preference, and any data that is mirrored from the CREST system;
- your IP address, your browser type and language and other information about your visit to our website;
- where this is provided to the Registrar copies of documents such as death certificates and grant of probate;
- in relation to the online portal (https://www.signalshares.com/) mother's maiden name, user names combined with passwords, cookies, online identifiers, security questions and responses;
- in relation to due diligence and anti-money laundering checks, scanned or photocopied images of passports, driving licences or utility bills; and
- in relation to some of the above categories, details of the countries where tax resident.

We primarily collect your personal data from the following sources:
- from information which you or your authorised representative gives to us, including but not limited to:
  - information set out in any subscription agreement with the Fund;
  - such other forms and documents as we may request that are completed in relation to the administration/management of any investment in the Fund;
  - client due diligence documentation as part of our regulatory requirements; and
  - any personal data provided by you by way of correspondence with us by phone, e-mail or otherwise;
- personal data we receive from you or any third party sources which may include:
  - entities in which you or someone connected to you has an interest;
  - your legal and/or financial advisors;
  - other financial institutions who hold and process your personal data to satisfy their own regulatory requirements;
  - credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements; and
  - information collected via our website (including cookies and IP addresses) and email addresses.
- 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.

Why we collect your personal data:

Lawful grounds for processing:

The Processors are entitled to hold and process your personal data on the following lawful grounds:
- the processing is necessary for the legitimate interests of the Fund, provided that your interests and fundamental rights do not override those interests;
- where the applicant is a natural person, the processing is necessary to comply with our respective contractual duties to you under the terms of your investment in the Fund and all supplemental agreements thereto;
- to comply with the legal and regulatory obligations of each of the Processors;
- (on exceptional occasions) where we have obtained your consent; and
- (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

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 compliance, pursuant to automatic exchange of information agreements, or other legal requirements means that your ability to trade in or to continue to own your shares may be restricted.

Purposes of processing

Pursuant to our lawful grounds for processing, the 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 the first six bullet points below):
- conducting credit reference checks;
- communicating with you as necessary in connection with your affairs and generally in connection with your investment in the Fund;
- operating the Processors' IT systems, software and business applications;
- supporting our IT and business applications support teams, accounting, legal, reporting, internal audit and risk management, administrative, registrar, document storage, record keeping and other related functions, including but not limited to processing personal data in connection with the Fund;
- monitoring and recording telephone and electronic communications and transactions:
  - for quality, business analysis, training and related purposes in order to improve service delivery;
  - for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act); and
  - to enforce or defend the Processors' respective rights, or through third parties to whom we each may delegate such responsibilities or rights in order to comply with a legal or regulatory obligations imposed on each of us;
- 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 sanctions on an ongoing basis ("Regulatory Assessments");
- facilitating the internal administration of each of the Processors and retaining your personal data as part of our Regulatory Assessments or future services entered into by you;
- 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");
- communicating with our professional advisers for the purposes of obtaining professional advice;
- conducting business analytics and diagnostics;
- communicating with you about the performance of the Fund, including but not limited to sending the Fund’s annual and half yearly accounts, fact sheets or other marketing information on the Fund.

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.

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 a Processor 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.
INPP does not make decisions about you based on automated processing of your personal data and will procure none of the Processors make such decisions unless duly authorized under the DP Law.

Sharing personal data

The Processors may share your personal data with group companies and third parties (including banks, financial institutions 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, for example to help them in their fight against crime and terrorism.
Data processing (as described above) may be undertaken by any entity in the Bailiwick of Guernsey or the European Economic Area (the "EEA"), an entity which is located outside the Bailiwick of Guernsey or the EEA in a Third Country without Adequacy.

Any Third Country without Adequacy to which we transfer your data is legally not deemed in general 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 will put in place appropriate measures 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. Any entity having access to your personal data outside Guernsey or the EEA will be required by binding legal contract to protect and only process your data as though it were in the EEA or Guernsey and subject to the same level of protection as applies in those territories.

Retention of personal data

Your personal data will be retained for the longest of the following periods:
- for the Processors and/or 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;
- in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations;
- seven years following the Data Subject's disinvestment from the Fund or at the point from when the business relationship with the Fund has ceased; or
- any retention period that is required by data protection laws and any applicable laws or regulatory requirements.
We endeavour and require all third parties with access to your personal data, to store such data securely on computer systems in accordance with accepted market standards.
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.

Your rights

You have, under certain circumstances, the following rights in respect of personal data:
- the right to request access to or a copy of your personal data and port personal data;
- the right to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
- the right to rectify errors in personal data;
- the right to restrict the use of personal data;
- the right to request that personal data is erased;
- the right to object to processing of personal data;
- the right to request not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data;
- where the Processors have relied on consent to process the personal data, the right to withdraw consent at any time by contacting us via the contact details below;
- the right to object to processing for direct marketing purposes;
- you have the general right to object to the processing of your data where we have considered this to be necessary for the purposes of our legitimate interests.
Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.
You also have the right to lodge a complaint with the Guernsey Data Protection Authority if you consider that the processing of your personal data carried out by the Fund, the Administrator of any other service provider to the Fund, has breached data protection laws. You may also have similar rights to complain to equivalent authorities in your jurisdiction of residence in the EU or the United Kingdom. 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.
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 your consent, please contact the Administrator. 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.

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

Gill Harradine
Tel: + 44 1481 742742
Email: inppteam-GG@ocorian.com

or write to:
International Public Partnerships Limited
c/o Ocorian Administration (Guernsey) Limited
PO Box 286
Floor 2
Trafalgar Court
Les Banques
St Peter Port
Guernsey
GY1 4LY

Changes to this Policy

This Privacy Notice is dated 25 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.