The General Data Protection Regulation (EU) 2016/679 (GDPR) is an EU regulation on personal data protection and privacy, which has also been adopted in large part by the UK.

GDPR seeks to achieve uniformity in the data protection rules applicable to all individuals within the European Union. GDPR relates to Personal Data which includes essentially any information relating to a natural person including name, location data, ID number or factors specific to the subject's physiological, economic and social identity (the GDPR also includes online identifiers such as cookies).

Hellebore Capital SAS (HCSAS) is a regulated financial services provider and a member of the Hellebore group of companies (HG). As part of the services it can provide, whether intra-group or to external third parties, it may be obliged to collect and process the Personal Data of, or related to, any parties corresponding with it or any other a member of HG, whether located in the EU or otherwise, in order both to perform its services and to meet regulatory KYC (Know Your Client), AML (Anti-Money Laundering) and other anti-corruption obligations, both initially and on an on-going basis. Further, HCSAS may be similarly required to use such information collected and processed to provide on a regular basis a range of information relating to the performance of its services and to retain for its records such information collected and processed for certain periods as required from time to time for the purposes of regulatory audit.

Notwithstanding the legal and contractual necessities of collecting Personal Data by HCSAS we should like to restate below a summary of such actions:

  1. Method(s) of collection of Personal Data

    Personal Data may be collected by a member of HG such as HCSAS via

    1. online registration questionnaire(s) and, as appropriate, receipt by a member of HG of additional information (whether in physical or electronic form)
    2. on-going communication between a member of HG and prospects and clients, for example, via its Investor Relations function.

  2. Use/processing of Personal Data

    Personal data is used/processed for the purposes of

    1. pre-screening prospective suitability of potential investors expressing interest in the Hellebore Credit SICAV fund/its sub-funds (the Fund) and continuing to validate such suitability.
    2. sending to those potential investors that have been accepted as investors ongoing communications reporting on the Fund’s performance, status and corporate actions.

  3. Storage and Deletion

    Personal Data collected and used/processed as per 1 and 2 above will be stored unless the provider of that information (the Provider) requests a member of HG to delete it.

    HCSAS and other members of HG are unable to delete the information referred to if the Provider is an investor in the Fund or if the Provider has redeemed such investment less than 7 years prior to receipt of such request being received.

  4. Security

    HCSAS and other members of HG take reasonable and appropriate technical and organizational security measures to store Personal Data in secure databases or systems with restricted access and to protect them against loss, accidental or intentional misuse, alteration, destruction and access by unauthorized persons. Some of the databases or systems used by HCSAS may be hosted and/or maintained by third party service providers located inside or outside of the European Union.

  5. Disclosure

  6. Your personal data will be only disclosed where HCSAS is obliged to do so under financial services regulations or orders by financial services regulators or where ordered or otherwise required to do by other government agencies or under court order.

  7. Right to Access and Correction

  8. You have the right to access, modify and correct your personal data at any time.

  9. Contact

  10. Any queries or requests related to the processing of your personal data by HCSAS should be sent to