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Privacy Notice

1.Introduction

This privacy notice (“notice”) applies to the processing of personal data by Blue Horizon in connection with any:

  • client services: the offering or provision of services by Blue Horizon to actual and prospective clients (including marketing thereto);
  • supplier services: the provision of products and services to Blue Horizon by suppliers or service providers;
  • visitor services: the provision by Blue Horizon of facilities, including local area networking (for instance, WiFi) and other relevant facilities and services to visitors to any Blue Horizon offices or other facilities; 
  • recruitment activities: the provision of the personal data of a candidate or individual for a position at Blue Horizon (whether by such candidate or individual directly or by a third party, such as a recruitment agency); and
  • investment opportunities: the collection and use of personal data in connection with existing and potential investments.

References in this notice to “you” or “your” are references to individuals whose personal data Blue Horizon processes in connection with client services, supplier services, visitor services or recruitment activities. “Blue Horizon”, “our”, “we”, or “us” refers to the Blue Horizon Group entity processing your personal data. “Blue Horizon Group” means Blue Horizon Corporation and its affiliates. For the avoidance of doubt, any reference in this notice to our “clients” or “suppliers” includes their employees or other staff whose personal details we process.

This notice describes the context in which we process your personal data and it explains your rights and obligations. It is important that you read this notice together with any other notices we may provide on specific occasions when we are collecting or processing your personal data, so that you are fully aware of how and why we are using your personal data. This notice supplements other notices and is not intended to override them.

This notice is not our website privacy notice or cookie policy. Our website privacy notice and cookie notice are accessible from the Legal Disclaimer section of our website. 

2. The personal data we collect about you

Personal data includes any information about an individual from which that person can be identified. It does not include personal data where the identity has been removed (anonymised data).

Special categories of personal data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. In limited circumstances, we collect special categories of personal data about you. Please see below in this section for details of these circumstances and Section 4 (How we use your personal data) for further details.

In limited circumstances, we will collect information about your criminal convictions and offences. This happens where we are required to do so for legal or regulatory purposes (for example, where required pursuant to anti-money laundering laws) or where you have provided us with such information as it is necessary for a specific service we are providing.

We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us: 

  • Identity data: including your first name, middle names, maiden name, last name, date of birth, passport number, photographic identification and gender; 
  • Contact data: including your address, email address and telephone number; 
  • Professional data: information about your employer (e.g., name of your company and your title and position) as well as your previous positions and professional experience;
  • Financial data: including your bank account details; 
  • Services data: including details about payments to and from you and other details of services you have obtained from us or we have obtained from you; 
  • Profile data: including your usernames and passwords, your interests, feedback and survey responses; 
  • Usage data: includes information about your use of our website, other electronic platforms and portals which we offer and our local area networking facilities (including WiFi) and similar electronic services. Additional information about personal data we process based on your usage of our website is available in the privacy notice for our website (which can be accessed from the Legal Disclaimer section of our website);
  • Marketing and communications data: including your marketing and communication preferences. We also track when you receive and read marketing communications from us and which of our events you attend, which information we use to improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials; 
  • Special categories of personal data: includes personal data listed above in this Section 2, which we process in limited circumstances, for example, where required to do so for legal or regulatory purposes or where you have provided us with such information as it is necessary for a specific service we are providing to you. We will process this personal data for the following reasons: 
  1. for legal and regulatory purposes, for example, we may need to run “know your customer” checks including by verifying whether you are a politically exposed person; and
  2. we may ask you whether you are vegetarian or vegan in order to (i) better tailor our marketing and service offering to you and (ii) for the purposes of our own data analytics (e.g. to assess the impact that our strategy has on reducing animal product consumption).

3. How your personal data is collected

We use different methods to collect personal data from and about you, including through the channels set out below. 

  1. Direct interactions: You give us your personal data in your direct interactions with us, including (i) by filling in forms on our website or through other electronic platforms and portals which we offer or which we have agreed with you to use, (ii) by corresponding with us by email or post, (iii) by speaking to us in person or over the telephone, or (iv) whilst visiting our offices. 

Such direct interactions include, for example, instances when you: 

  • enquire about or apply for our services (for instance, when you leave an inquiry online or subscribe to our newsletter or otherwise ask for our marketing) or approach us with an investment opportunity; 
  • market or provide your supplier services to us; 
  • give us personal data necessary for a specific client service we are performing for you, or for the purposes of our “know your customer” processes and other background checks. In the certain limited circumstances, for example to enable us to comply with anti-money laundering and terrorism purpose we may also collect this information about suppliers; 
  • give us your business card at an event or a meeting (including a lunch or dinner) with one or several of our staff, or otherwise personally give us your personal data (for example, by leaving your contact details at the reception of one of our offices or with our switchboard); 
  • give us your personal data via an electronic platform which we make available or which we have agreed with you to use in connection with our client services (for instance, any e-billing system or client portal) or in connection with your supplier services (for example, an electronic platform that you supply to us); or
  • give us feedback (for example, by completing a survey). 
  1. Third-party sources: We receive personal data about you from third parties, when we:
  • provide our client services or other parties send us your personal data to enable the provision of those services; 
  • conduct our “know your customer” and other background checks; 
  • you provide your personal data to a third party for the purpose of sharing it with us, for instance recruitment agencies, placement agents, your advisers and consultants in connection with the provision of our services.
  1. Publicly available sources. We may collect personal data from: 
  • public registers of individuals (for instance, electoral registers); 
    • public registers of companies, charities, law firms, chartered accountants, stock or commodities exchange participants, mutuals and other entities (for instance, Companies House in the United Kingdom); 
    • public registers of sanctioned persons and entities (such as, HM Treasury in the United Kingdom or the Office of Foreign Assets Control of the United States department of the Treasury); and 
    • other public sources including any services accessible on the Internet which you are using for professional networking purposes for example Linked-In. 

4. How we use your personal data

We will only process (i.e. use) your personal data when the law allows us to, that is, when we have a legal basis for processing. We use your personal data in the following circumstances: 

  • performance of a contract: where we need to perform a contract which we are about to enter into or have entered into with you as a party or to take steps before entering into such a contract;
  • legal or regulatory obligation: where we need to comply with a legal or regulatory obligation that we are subject to;
  • legitimate interests: where necessary for our interests (or those of a third party), provided that your fundamental rights do not override such interests. This can mean, for instance:
    • sending you marketing communications (including newsletters) in order to make you aware of our investment strategy, track record and impact and our service offering;  
    • liaising with and evaluating a prospective investment and/or monitoring and managing investments made;
    • monitoring how you are using any client portals and platforms or access to systems to ensure that the security of such portals or systems is maintained and to prevent fraud or criminal activity, misuse of our products or services, and to protect the security of our IT systems, architecture, and networks; or
    • to meet our corporate and social responsibility objectives.
  • We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests; we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law); and
  • consent: where you have provided your consent to processing your personal data. 

We may process your personal data for more than one legal basis depending on the specific purpose for which we are using your personal data. 

With limited exceptions (for instance, in relation to some of our electronic marketing or existing client relationships), generally we do not rely on consent as the legal basis for processing your personal data. 

You are under no obligation to provide Blue Horizon with your personal data. However, if you fail to provide personal data when requested which is necessary for us to manage our relationship with you or your employer as a service provider or supplier (e.g., information necessary to evaluate you qualifications or meet our regulatory and legal obligations), we may not be able to retain your services. 

5. Purpose of the processing 

We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process your personal data to: 

  • market our services to you and make you aware of our investment strategy, track record and impact;
  • select, retain and manage our suppliers and service providers; 
  • evaluate prospective investments and managing existing ones;
  • implement tasks in preparation of, or to perform existing contracts; 
  • monitor our facilities to ensure compliance with applicable policies and laws; 
  • grant you access to our facilities and/or certain technologies to allow you to perform services; 
  • manage our technology resources (e.g., cyber-risk management, infrastructure management and business continuity); 
  • preserve our economic interests and ensure compliance (e.g., complying with our policies and legal requirements, tax and deductions, managing alleged cases of misconduct or fraud, conducting audits and participating in litigation); 
  • preserve our legal interests (e.g., enforcing or defending our legal rights); 
  • archiving and record-keeping; 
  • billing and invoicing; 
  • in order to contact you about recruitment and other opportunities; and


  • any other purposes imposed by applicable law and governmental authorities. 

If we need to use your personal data for any other 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Marketing and exercising your right to opt-out of marketing 

We will not use your personal data to send you marketing materials if you have requested not to receive them. If you request that we stop processing your personal data for marketing purposes, we shall stop processing your personal data for those purposes.

You have the right to withdraw consent to electronic marketing at any time. We would encourage you to make such requests via the unsubscribe forms/links provided for that purpose in the marketing materials we send you or by contacting our Media team at media@bluehorizon.com. You may alternatively make any such request to your usual contact at Blue Horizon. In any event, such request can be made at any time free of charge.

7. Who is the controller for the personal data processed?

A “controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. This notice is issued on behalf of Blue Horizon Corporation as controller. Unless we notify you otherwise Blue Horizon Corporation is the controller for your personal data.

8. Who has access to your personal data and to whom are they transferred? 

We will never sell your personal data. 

In the course of our activities and for the purposes listed in this notice, your personal data may be processed by the following categories of recipients on a need to know basis to achieve such purposes: 

  1. personnel (e.g., employees, directors, investors, interns, contractors, etc., working in various departments or whom are employed by affiliated companies); 
  2. other suppliers and services providers that provide services and products to us; 
  3. technology systems providers, including cloud and database providers, and related consultants; 
  4. any third party to whom we assign of our rights or obligations; and 
  5. professional advisors and external lawyers. 

Such recipients are obligated to protect the confidentiality and security of your personal data. In certain limited circumstances, your personal data may be accessed by or transferred to law enforcement, regulatory bodies, or judicial authorities. This will occur only when legally required. 

The personal data we collect from you may be processed, accessed, or stored by Blue Horizon in a different country than where you are located including outside of Switzerland or the European Economic Area. When we transfer your personal data for an intra-group transfer to another Blue Horizon entity located in a country that does not offer adequate protections, Blue Horizon uses the European Commission’s standard contractual clauses. Standard contractual clauses are a set of contract terms approved by certain jurisdictions and deemed to provide adequate protections for cross-border transfers. 

When we transfer your personal data to an external company in a country that does not offer adequate protections, we will make sure to protect your personal data by (i) requiring that the third party apply the level of protection required under the applicable local data protection laws, (ii) requiring that the third party act in accordance with our written instructions and our policies and standards and (iii) unless otherwise specified, only transferring your personal data on the basis of an appropriate contractual mechanism (such as the standard contractual clauses approved by the European Commission). 

You may request additional information in relation to such cross-border transfers and obtain a copy of the adequate safeguard put in place by Blue Horizon, as described in Section 12 titled “Who can I contact if I have any questions or concerns?”.

9. Data security

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing, including:

  • the pseudonymisation and encryption of personal data; 
  • the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  • the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and
  • a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing. 

We ensure that those who have permanent or regular access to personal data, or that are involved in the processing of personal data, or in the development of tools used to process personal data, are trained and informed of their rights and responsibilities in when processing personal data.

10. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. This includes for example the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to carry out legal work, for the establishment or defence of legal claims. 

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 we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

11. What are your rights? 

Your rights are based primarily on the data protection law of the country in which you are located, and may be limited by regulatory requirements or our lawful basis for processing. 

You may have one or more of the following rights: (1) to be informed whether we process your personal data and what data is processed; (2) to access your personal data; (3) to request correction of processed data, if it is incorrect or incomplete; (4) to oppose the processing and to restrict the processing of your personal data; (5) to ask for the deletion of your personal data; and (6) to request the transfer of your personal data to a third-party.

You may exercise any of your rights at any time using the contact details set out in Section 12 below. 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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

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. 

We try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer than one calendar month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. Who can I contact if I have any questions or concerns? 

If you have any questions about how your personal data is processed (including if you are unsure of which Blue Horizon entity is the controller), or if you want to exercise one of your rights, you may contact our Data Privacy Officer by email at DPO@bluehorizon.com. 

In any case, and in addition to any rights you may have, you may file a complaint with the competent data protection authority in your country. However, we would encourage you to contact us in the first instance as we aim to promptly, efficiently and satisfactorily resolve any concerns or complaints you may have in relation to Blue Horizon’s processing of your personal data.

13. How will you be informed of the changes to this notice? 

You will be informed of any changes or additions to the processing of your personal data through updates to this notice available on our website or included in any marketing communications we may send you from this to time. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you wish to update your personal data, please contact your relationship person at Blue Horizon or our Data Privacy Officer at DPO@bluehorizon.com.