Privacy Policy

We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This website privacy policy is divided into the following sections:

• Who we are
• Our website
• Our collection and use of your personal information
• Our legal basis for processing your personal information
• Who we share your personal information with
• Transfer of your information out of the EEA
• Cookies and similar technologies
• Your rights
• Keeping your personal information secure
• How to complain
• Changes to this website privacy policy
• How to contact us

Who we are

This website is operated by Drakewood Capital Management Limited (hereinafter “DCM”). We are a commodity investment specialist with a complementary mix of commodity hedge funds and fabrication businesses. We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Our website

This privacy policy relates to your use of our website, www.drakewood.co.uk only. Throughout our website we may link to other websites owned and operated by certain trusted third parties. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.

Our collection and use of your personal information

We collect personal information about you when you access our website, register with us, contact us, send us feedback, or purchase products or services via our website. We collect this personal information from you either directly, such as when you register with us, contact us or purchase products or services via our website or indirectly, such as your browsing activity while on our website (see ‘Cookies’ below). The personal information we collect about you depends on the particular activities carried out through our website.

• Your name, address, and contact details
• Date of birth
• Bank account and payment details
• Details of any feedback you give us by phone, email, post or via social media
• Information about the services we provide to you
• Your account details, such as username, login details

We use this personal information to:

• Create and manage your account with us
• Verify your identity
• Provide services to you
• Customise our website and its content to your particular preferences
• Notify you of any changes to our website or to our services that may affect you
• Improve our services

This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.

Our legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.

• Consent: Where you have given us clear consent for us to process your personal information for a specific purpose
• Contract: Where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• Legal obligation: Where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
• Legitimate interests: Where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

Who we share your personal information with

With regards to the personal data we process in connection with using the Site, we will only disclose any personal data you submit to us if this is required for the purposes of service administration to enable us to maintain and operate the Site as well as to collect traffic data.

Otherwise and in connection with providing our services, we may share your personal data with the following categories of recipients:

• Representatives, agents, custodians, administrators, intermediaries and/or other third-party product providers appointed by a Fund or other client
• Third-party agents and contractors for the purposes of them providing services to us, Funds, and other clients
• Depositories, clearing or settlement systems, counterparties, dealers, and others where disclosure is reasonably intended for the purpose of effecting, managing, or reporting transactions
• Other joint account or portfolio holders (if applicable)
• Regulatory, supervisory, or governmental authorities as required by law
• Other business entities in the event of a merger, acquisition, or re-organization
• Successors in interest in the event of liquidation or administration

Transfer of your information out of the EEA

We may transfer your personal information to countries outside the European Economic Area (EEA). Such countries may not have the same data protection laws as the United Kingdom and EEA. Any transfer of your personal information will be subject to the General Data Protection Regulations designed to safeguard your privacy rights and provide remedies in case of misuse of your personal information.

Your rights

Under the General Data Protection Regulation, you have a number of important rights free of charge. These include:

• Access to your personal information and supplementary information
• Require correction of any mistakes in your information
• Request the erasure of personal information in certain situations
• Receive personal information in a structured, commonly used, and machine-readable format
• Object to processing of personal information for direct marketing
• Restrict processing of personal information in certain circumstances
• Withdraw your consent for processing (if applicable)
• Lodge a complaint with the competent supervisory authority

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used/accessed in an unauthorized way. Access is limited to those with a genuine business need. We also have procedures in place to handle any suspected data security breach and will notify you and the applicable regulator where required.

How to complain

We hope to resolve any query or concern you raise about our use of your information. However, you have the right to lodge a complaint with the supervisory authority in the European Union or EEA state where you work, live, or where the infringement occurred. In the UK, this is the Information Commissioner’s Office (ICO). Visit https://ico.org.uk/concerns/ for more information.

Changes to this website privacy policy

This website privacy policy was published on 1 October 2019 and last updated on 1 October 2019. We may update this policy from time to time.

How to contact us

If you have any questions about this privacy notice or the information we hold about you, please contact us by email at [email protected] or write to us at:

Drakewood Capital Management Limited
16 Great Queen Street
London, WC2B 5AH