Our Privacy Statement will help you understand the information we collect, how we use it, and what choices you have.  This privacy statement applies only to the www.bflexion.com website (the Website) provided by B-FLEXION ("we", "us", "our").

What personal information do we collect when you visit our website?

The Website collects standard internet log and technical data to measure and improve the effectiveness of this website, to help diagnose problems with our server, to administer the Website, to see where website traffic is coming from, and to identify our users.

When you visit the Website, we may collect technical information such as your IP address, details of the pages you visit on the Website, and which browser you used to view our website with.

We may also use your name and email address to assist you in any questions you have if you complete the contact us form.

How is your personal data collected when you visit our website?

Personal data may from time to time, be collected about you from direct interactions with you, including by you filling in our “contact us” forms and any email or other correspondence you send us. This includes personal information you provide when you request information to be sent to you.

Cookies

Cookies are small data files stored on your computer’s hard drive by a website. Among other things, cookies make the Website work, and help us improve our Website and your experience. We use cookies to see which areas and features are popular, and to count visits to the Website. Like many Websites, we may automatically collect information using “cookies”.

Cookies in themselves do not identify you, just the computer or device you are using through your Internet Protocol address (IP address).

We may use the following types of cookies:

“Session based” cookie. This is essential for parts of the Website to operate and has already been set. It is used to maintain the state of a user’s actions so as not to constantly request the same information from them within a “session”.

“Essential” cookie. This is essential for parts of the Website to operate – for example, it lets us know that you have clicked on a link to a new page and that we should now serve that new page to you.

“Analytics” cookie. This is used to collect information about how you use our site, such as where you have come to the Website from and which Website pages you have visited. We use the information to help us improve the Website.

We do not collect other information, such as website usage activity and preferences (also known as demographic or profile data) via the Website, and do not have Advertising cookies.

With most Internet browsers, you can erase or block cookies or ask to receive a warning before a cookie is stored. The “Help” function within your browser should tell you how. Alternatively, you may wish to visit https://youronlinechoices.eu/ which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies.

Restricting cookies will not have an impact on the functionality of our website, but it will not remember any preferences (such as language) that you have chosen, and you will have to change the settings each time you visit our site.

Sharing of personal information

Your personal data may be processed by us or our sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

• To send you any information you have requested, which may include updates on the performance of a fund, newsletters from our Foundation, or invitations to events
• To comply with legal and regulatory requirements
• To scan emails sent to us (including attachments)

We will take steps to ensure that the personal data is accessed only by such sub-processors that have a need to do so for the purposes described in this notice.

International transfers of your personal data

Our website servers are based at our headquarters in Geneva, Switzerland.  We may from time to time disclose your IP address to our third-party website support partners, also located in Switzerland, to help with the maintenance and diagnostics of any technical issues we may experience with the Website.

Where we transfer your personal data to another country we will ensure it is protected by the appropriate safeguards. Please contact us at DPPC@bflexion.com for more information.

Storage of your personal information

We will keep IP address information for approximately 12 months from the date on which you last use the Website, after which this information will be permanently and securely deleted from both the Website and any records maintained by our third party support partners.

We will only retain any other personal data you have provided to us for as long as necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

Your Rights

You have several 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; and
• 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.

You can exercise your rights by contacting DPPC@bflexion.com.

Subject to the jurisdiction in which we operate, you have the right to complain to a data protection authority about our collection and use of your personal information, for example – 

i) B-FLEXION Jersey entities you can contact the Jersey Office of the Information Commissioner, or by searching their website at https://oicjersey.org.
ii) B-FLEXION UK entities, you can contact the UK Information Commissioner Office, or by searching their website at https://ico.org.uk/
iii) B-FLEXION Irish entities, you can contact the Irish Information Commissioner Office, or by searching their website at https://www.oic.ie/en/
iv) B-FLEXION Swiss entities, you can contact the Federal Data Protection and Information Commissioner, or by searching their website at https://www.edoeb.admin.ch/edoeb/en/home.html

Changes to this privacy statement

This statement is subject to the occasional revision, and if we make any substantial changes to the way we collect information via the Website, we will prominently post a notice of the change on the Website's home page.

Questions

If you have any questions about this privacy statement please contact us at DPPC@bflexion.com.