1. Privacy and data protection

HSDP Funds (we, us or our) are committed to respecting your privacy, while providing you with the opportunity to receive products and services that enhance your business activities and to receive benefits from our website. This online privacy policy (the ‘policy’) describes the ways in which we collect information from you when you use the Website and what we may use it for.

This Policy applies solely to information collected by the Website. The Website may contain links to other sites. HSDP Funds is not responsible for the content or practices of other sites and we recommend that you check their own privacy policies. Use of the Website by you constitutes acceptance of this policy. If you do not agree to this policy then please refrain from using the Websites.

2. Confidentiality

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. We will maintain the confidentiality of and protect your personal data in accordance with this policy and to the extent required by U.S  law.

3. Collection of information

We collect data from you in various ways: when you register on any of the Websites to use our services; by our use of ‘cookies’ (see below); while participating in surveys or contests; during the course of your use of our services, and when we request further information from you from time to time following on from your registration.

The Data we collect:

Personal Data

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:

Identity Data includes first name, middle name, last name, maiden name, username or similar identifier, title, and country.
Contact Data includes billing address, home address (if different), email address and telephone numbers.
Financial Data includes bank account and payment card details (if needed).
Transaction Data includes details about payments from you and other details of services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, data about your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password feedback and survey responses.
Usage Data includes information about how you use this website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and third parties (i.e. any external partners) and your preferences when receiving communications.

4. How your personal data is used

We will only use your Personal Data as permitted by law. Most commonly, we will rely on the following types of lawful basis to process your Personal Data: Providing our products and services to you; Administration of Membership Records, Advertising, Advertising, marketing and public relations for others, Education in general to improve our services to you, for example, to notify you of any updates and changes to our products and services; To process payments from you, including registration fees, subscription payments and exam fees; Internal purposes, including Websites and system administration; Internal research, analysis and reporting for the purposes of improving our services.

We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your express consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract: processing your Personal Data is necessary for the performance of the contract of carriage to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation: processing your Personal Data may be necessary for compliance with a legal or regulatory obligation to which we are subject.
Consent: in certain circumstances, we may ask for your express consent to collect, process or transfer your Personal Data, for example in relation to opting into receiving our newsletter or other direct marketing. You have the right to withdraw your consent at any time simply by contacting us.

Change of purpose

We will only use your Personal Data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you to explain the legal basis which allows us to do so or, where required by law, to seek your consent.

Third-party links

This website may include links to third-party websites, plug-ins and applications which are not maintained or controlled by HSDP . Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you look at other websites, we encourage you to read the Privacy Policy of every website you visit.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

5. Monitoring

We may use personal data obtained about you from monitoring your use of the Websites solely for internal purposes including site performance, evaluating site use and creating our marketing reports to aid future marketing of information about us and our products. Personal data collected by monitoring will be aggregate and no personal data will be used other than for the purpose for which it was originally obtained.

6. Processing of information

Your personal data may be controlled and processed by any of our offices. You acknowledge and agree that the location of our offices may change from time to time and that we may acquire other offices in any number of other countries or territories, including outside the European Economic Area (EEA), at any time, any one or more of which may act as a data controller of and/or data processor for the purpose of applicable data protection laws.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. Remember to close your browser when you have finished your user session. This will help to ensure that others do not access your personal information if you share your computer or use a computer in public places such as a library or internet café.

7. Disclosure

Other than as set out in paragraphs 4 and 11 of this policy, we will not disclose your personal data to any third party without your prior permission, unless we are required to do so by any applicable law or regulators (in the U.S or elsewhere).

If you consent, we may use your email address to contact you by email to provide you with further information about us, our products/services and to promote our Websites. This may involve disclosing your personal data to our other offices or to our affiliates, agents or appointed representatives. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

8. Transfer of personal data overseas

A transfer of personal data to a recipient located in a jurisdiction outside the EU or the DIFC may take place only if that jurisdiction is deemed to have an adequate level of protection for that personal data. The Commissioner of Data Protection applies the same adequacy standards with regards to third countries as set out by Article 29 Working Party of the European Commission on Data Protection.

Data Security: We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Collection of information through use of cookies

As part of our quality control and with the objective of providing you with enhanced services we may monitor the use of the Websites and record, where available, your IP address and/or email address.

This information is collected for our internal purposes only and shall not be disclosed to any other organisation except as required by law. For the same reason, we may obtain information about your general internet usage by using a ‘cookie’ file.

10. Subject access

You have the right to access and the right to amend your personal data by sending us an email to:

Email:  hsdpfunds@gmail.com

11. Use of third party services

Please note that third parties may require access to your personal data where such third parties provide services to us, for example, website hosting services. In those circumstances those third parties shall be required to enter into an agreement with us containing terms no less stringent than found in this policy and to process your personal data solely in accordance with our instructions. You consent to your personal data being provided to such third parties for these purposes.

12. Data Retention

How long we retain your Personal Data

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure in the “YOUR LEGAL RIGHTS” section for further information. In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you and you can no longer be identified by it) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

13. Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:

Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes (and you will always be able to opt-out via the “unsubscribe” link on an email from us). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following situations: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it because you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to information which was originally collected electronically and which you either consented to us using or was used to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we may charge a reasonable fee (taking into account the administrative costs of providing the information) if we consider your request to be unfounded, repetitive or excessive. Alternatively, in these circumstances, we may refuse to comply with your request but we will provide you with a full explanation of this at the time.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We will respond to all legitimate requests within one calendar month. If your request is particularly complex, or you have made a number of requests, it may take us up to 3 calendar months to respond (instead of the 1 calendar month mentioned earlier), but we will notify you of this and keep you updated.

14. Questions

If you have any questions or need further information about our privacy practices, please contact us 
Email: hsdpfunds@gmail.com

15. Changes to privacy policy

We reserve the right to change this Privacy Policy at any time. This version of the Privacy Policy was last updated on 24 May 2018. Historic versions of this Privacy Policy can be obtained by contacting us.