Privacy Policy

1. This Privacy Policy and the terms and conditions contain herein (“Privacy Policy”) apply to the entire website found at the domain name www.havenvest.com (“Website”), including, without limitation, all contents of the Website and any correspondence by e-mail (or other electronic means) between you and Havenvest Private Equity Middle East Management II Limited (“Havenvest”, “we”, “us” or “our”) sent through the Website. References to “you”, “your” and “yours” are references to the person(s) accessing the Website.
2. This Privacy Policy, together with our terms and conditions sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
3. Our terms and conditions are hereby incorporated into this Privacy Policy as though fully set forth herein. If any provision in this Privacy Policy is inconsistent or conflicts with any part of our terms and conditions, the provision in this Privacy Policy shall prevail.
4. Your use of the Website indicates that you have read, understood and unconditionally accepted the provisions in this Privacy Policy, and such acceptance constitutes your legally binding acceptance of all terms and conditions set out in this Privacy Policy. If you do not accept the terms of this Privacy Policy, please discontinue accessing, viewing or otherwise using the Website immediately.
5. We reserve the right to change the contents of this Website, including this Privacy Policy, at any time by posting such changes on the Website.  It is your responsibility to familiarise yourself with the Privacy Policy regularly to ensure that you are aware of any changes. The current version of this Privacy Policy will supersede all previous versions. Your continued use of this Website following the posting of changes to the Privacy Policy will constitute your acceptance of the revised Privacy Policy.

2. PERSONAL INFORMATION

1. When you register on this Website you may be asked to provide some information about yourself such as (but not limited to) your name, email address, mailing address, telephone number, date of birth, gender and nationality, and in addition to this we may also record any correspondence between you and us (“Personal Information”). We will handle Personal Information in accordance with the laws of the British Virgin Islands,  please note that Personal Information may be hosted or transferred outside of this jurisdiction.
2. The provision of your Personal Information is voluntary but if you do not provide the information requested, you may not be able to take advantage of many of the features of the Website.
3. We shall not share your Personal Information with entities outside of Havenvest unless your express consent has been granted.  We maintain strict security standards and procedures with a view to preventing unauthorised access to your Personal Information by anyone, including our staff.
4. You acknowledge and agree that we may use your Personal Information at our discretion:
   1. to provide an email alert service (“Service”) allowing you to receive alerts relating to Havenvest and/or such other carefully selected third parties or matters as we may include from time to time. Your use of the Service will result in us holding the data you submit for use of the Service.  The data will be held in our cloud servers and will only be used to provide you with the information you have requested receiving via the Service or for statistical analysis.  By using the Service, you agree to us holding and using your data as indicated above.  We may at any time and at our discretion withdraw the Service and/or your use of it. If you no longer wish to be contacted in the future by us, please state the same by contacting us via email on the email address provided in the ‘Contact Us‘ page of this Website;
   2. to make available or disclose to third parties information about you in connection with providing any services to you; and
   3. for market analysis purposes and the provision of statistics to third party vendors.  Personal Information may be shared, stored and/or processed at our offices or at the offices of any of our business partners in any part of the world.
5. Subject to the terms contained within this Privacy Policy, we may use, disclose and otherwise handle your Personal Information as permitted by applicable laws.
6. Although we shall take all reasonable measures to prevent unlawful access to Personal Information, however we provide no representation or guarantee that a third party will not unlawfully access your Personal Information, we suggest that you take all necessary precautions against this.
7. We will retain the Personal Information provided by you for as long as is reasonably necessary for the purposes listed in this Privacy Policy.
8. For the avoidance of doubt, the provisions under clause 8 (Disclaimer) in our terms and conditions shall apply as if reference to “the Website” include references to the Service.

3. IP ADDRESSES

IP addresses are used by your computer every time you are connected to the internet. Your IP address is a number that is used by computers on the network to identify your computer. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

4. COOKIES

1. Similar to other commercial websites, our Website utilises a standard technology called ‘cookies’ and web server log files. Cookies are pieces of information that a website either transfers to your computer’s hard drive or stores temporarily in your computer’s memory for record keeping purposes.  We do not save Personal Information in cookies and cookies alone cannot be used to disclose your individual identity.
2. Most browsers are initially set up to accept cookies and if so, the Website’s system will issue cookies when you log on. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent.  However, if you decline to accept cookies from the Company, you may not be able to take advantage of all the features of the Website and you may be unable to access certain parts of the Website.
3. Because the information disclosed by cookies does not personally identify you, we may use such information for any purpose including, but not limited to, disclosure to third parties in accordance with this Privacy Policy, or if we are under a duty to disclose or share your personal information in order to comply with any legal obligation. For the avoidance of doubt, by continuing to browse the Website, you are agreeing to our use of this information disclosed by cookies.
4. If you follow a link to any third party websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

5. ACCESSING AND UPDATING YOUR INFORMATION

1. You are entitled at reasonable intervals to receive details, in an intelligible form, of Personal Information we are collecting about you and the source of any available information on the Website.  If you wish to do this, please contact us via email on the email address provided in the ‘Contact Us‘ page of this Website. We may charge a small fee to meet out costs in providing you with these details.
2. In certain circumstances, you may ask us to make changes to the Personal Information provided by you and/or held about you, to ensure that it is accurate and kept up to date.  You may also request that we cease processing your Personal Information and that we delete you from our database or records.  Please note that it may be impossible to completely delete your information because of back-ups and records of deletions.
3. We will only perform the activities outlined above to the extent that such activities will not compromise privacy, security or any other legal interests.

6. DATA PROTECTION LAWS

1. We shall at all times comply with any relevant privacy or data protection laws in the British Virgin Islands.
2. Under the laws (as amended), you have the right:
   1. of access to, and rectification, erasure or blocking of, your Personal Information, where the use by us of your Personal Information does not comply with this law;
   2. to be informed of, and on reasonable grounds, to object to, the processing of your Personal Information; and
   3. to make complaints, on reasonable grounds, to our Directors regarding the processing of Personal Information.
3. If you wish to exercise any of the rights contained in this clause 6, please contact us via email on the email address provided in the ‘Contact Us‘ page of this Website.

7. CONTACT

Any queries or comments about this Website or Privacy Policy should be directed via email using the email address provided in the ‘Contact Us‘ page of this Website.