Privacy Policy

Privacy Policy – GraniteShares Limited

GraniteShares Limited”, “we”, “us” and “our” means GraniteShares Limited and we are committed to respecting your privacy.

GraniteShares Limited is registered in the UK and its registered address is 2nd Floor, 167-169 Great Portland Street, London, England, W1W 5PF. GraniteShares Limited’s company registration number is 10909672.

About this privacy notice

For the purposes of data protection law, GraniteShares Limited is a data controller in respect of your personal data. GraniteShares Limited is responsible for ensuring that it uses your personal data in compliance with data protection law.

This privacy notice applies to clients of GraniteShares Limited, investors or potential investors in GraniteShares exchange traded products (ETPs) and any other relevant persons. This privacy notice sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.

Personal data that we collect about you

We will collect and process the following personal data about you:

    • Information that you provide to us or one of our affiliates. This includes information about you that you give us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise.. This information may include, without limitation, your name, address, gender, job title, telephone number, email address and other contact details and in certain circumstances may also include information supporting any KYC (know your customer) and AML (anti-money laundering) checks we, our affiliates or delegates may be required to conduct from time to time.
    • Information we collect or generate about you. This includes:
      • information that you provide to us and which we record in our CRM (customer relationship management) systems or otherwise store in our email or file server systems and any further automated back-up of such information by our IT systems;
      • information that you provide to us and that we are required to record pursuant to our various compliance and regulatory obligations, including data (including financial information) that we are required to collect or generate to ensure compliance with local marketing laws or regulations;
      • information that is collected and stored as a result of any recording of GraniteShares Limited’s telephone lines;
      • any information we may record as a result of you accessing our website.
    • Information we obtain from other sources.
      • we may obtain information about you from third party data research sources, such personal data may include your name, role, firm name, email address, online profile, URL and business address.

Uses of your personal data

Your personal data may be stored and processed by GraniteShares Limited in the following ways and for the following purposes:

      • processing for advertising, marketing and business development opportunities, including advertising, business development or marketing of GraniteShares ETPs, including notifying you of information (including via email) about the same;
      • processing for public relations, including promoting public relations in connection with GraniteShares ETPs, including by use of GraniteShares Limited’s website;
      • in order for GraniteShares Limited and its affiliates to comply with their respective legal, regulatory and compliance obligations; and
      • any other purposes reasonably related to the above.
      We are entitled to use your personal data in these ways because:
      • we have legal and regulatory obligations that we have to discharge;
      • we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
      • the use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), such as:
        • the performance of any contract in place between you (as the data subject) and GraniteShares Limited (as data controller);
        • compliance with the legal obligations of GraniteShares Limited;
        • GraniteShares Limited’s legitimate interests which may include, without limitation, processing for direct marketing purposes and identifying business development opportunities, transmission of personal data (including data on clients, investors and potential investors in GraniteShares ETPs) within the GraniteShares’ group for internal administrative purposes, processing for ensuring cyber security and processing for reporting possible criminal acts or threats to public security to a competent authority;
      • you may, from time to time, consent to us using your personal data for one or more processing activities

Data Security and Integrity

We look to ensure that data is accurate, complete, current and reliable for its intended use. We use appropriate technical and organisational measures and safeguards to help protect your personal data from unauthorised access, misuse, alteration or loss. Our internal policies and procedures are designed to help ensure we safeguard the privacy and accuracy of all data we collect or process.

Disclosure of your information to third parties

We may disclose all or certain of your personal data to our affiliates (including, without limitation, GraniteShares Inc) in the circumstances described below:

      • where we have legal and regulatory obligations that we have to discharge;
      • we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
      • in the course of ensuring the performance of any contract in place between us;
      • for direct marketing or business development purposes;
      • for internal administrative purposes, including as a result of sharing common IT, call recording and data archiving systems; or
      • for ensuring cyber security and processing for reporting possible criminal acts or threats to public security to a competent authority.
      We will take steps to ensure that the personal data is accessed only by staff of such affiliates that have a need to do so for the purposes described in this notice. We may also share your personal data outside of GraniteShares Limited and our affiliates
      • if we sell any of our business or assets, in which case we may be asked to disclose your personal data to the prospective buyer for due diligence purposes
      • if we are acquired by a third party or are otherwise subject to outside investment, in which case personal data held by us about you will be disclosed to the third party buyer or investor;
      • to third party agents or contractors (for example, the providers of our IT and electronic data storage services) for the purposes of providing services to us. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice; and
      • to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights.

Transfers of personal data outside the European Economic Area

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for our affiliates or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

      • the country that we send the data to might be approved by the European Commission
      • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data; or
      • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA by contacting us in accordance with the “Contacting us” section below.

Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

      • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
      • legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

Your rights

You have a number of legal rights in relation to the personal data that we hold about you.

These rights include:

      • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
      • the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
      • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those 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 us;
      • the right to request that we rectify your personal data if it is inaccurate or incomplete;
      • the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
      • the right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and / or to refuse that request; and
      • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.

You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at https://ico.org.uk/.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on our website. We suggest that from time-to-time you review this privacy policy for the latest information on our privacy practices. By using our website, you are agreeing to be bound by this privacy policy. We keep this privacy policy under regular review. This privacy policy was last updated in January 2019.

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to GraniteShares Limited, 1st Floor, 71-91 Aldwych, Aldwych House, London WC2B 4HN (email: europe@graniteshares.com)

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