Privacy Policy

This Privacy Policy explains how personal data is collected, used, shared and retained when you use this website and in connection with HelmShare Prime Fund, L.P., a Cayman Islands exempted limited partnership (the Fund). It is intended to satisfy the transparency requirements of the data protection laws that may apply, namely Regulation (EU) 2016/679 (the EU GDPR), the EU GDPR as it forms part of the law of the United Kingdom (the UK GDPR), and the Data Protection Act (as revised) of the Cayman Islands (the Cayman DPA). References to data protection law are to whichever of these laws applies to the processing in question.

For personal data processed through this website, DRIFTER is the controller. For personal data processed in connection with an investment in the Fund, the controller is HelmShare Prime Fund, L.P., acting through its General Partner, HelmShare LLC (together, the Controller), which determines the purposes and means of that processing. The Administrator of the Fund processes personal data on behalf of and on the instructions of the Controller as a processor, and may itself act as a controller for limited purposes where required by law, for example for its own anti-money laundering and regulatory record-keeping obligations. Queries about this Policy and requests to exercise your rights can be sent to mike@helmshare.com.

We process the following categories of personal data: identification and contact data such as name, date and place of birth, nationality, residential and mailing address, telephone number and email address; identity-verification and due-diligence data such as passport or identity document details, proof of address and photographs where required; financial and commitment data such as bank account details, source of funds and source of wealth information, commitment amount, and capital account and distribution records; tax data such as tax residency, taxpayer identification numbers, and FATCA and CRS classifications; status and screening data such as politically exposed person status, sanctions screening results and adverse media results; technical and usage data collected through the website; and correspondence and records of dealings with us.

Personal data is collected directly from you, and may also be obtained from your authorised representatives and intermediaries, from publicly available sources, from sanctions, politically exposed person and adverse-media screening providers, from credit and identity-verification agencies, and from our service providers.

We process personal data to establish and administer an investment, including processing a subscription, maintaining the register of Limited Partners and capital accounts, issuing capital calls, paying distributions and providing reports; to comply with legal and regulatory obligations, including anti-money laundering and counter-terrorist-financing requirements, sanctions screening, and FATCA and CRS reporting; to manage our relationship with investors and respond to enquiries; to establish, exercise or defend legal claims and to manage risk, audit and governance; and to send electronic communications and deliver documents electronically. We rely on the legal bases of performance of a contract, compliance with a legal obligation, legitimate interests, and, where required, consent, with the equivalent conditions applying under the Cayman DPA. Where we rely on legitimate interests, we have assessed that those interests are not overridden by your interests or fundamental rights and freedoms.

Personal data may be shared with the General Partner and the Investment Manager; the Administrator; the Auditor, being Deloitte (Cayman Islands office); legal, tax and other professional advisers; banks and paying agents; sanctions, politically exposed person and identity-verification screening providers; information technology and communications service providers; placement agents and intermediaries to the extent relevant to a particular investor; and competent regulatory, tax and governmental authorities, including the Cayman Islands Monetary Authority, the Cayman Islands Tax Information Authority, the Dubai Financial Services Authority, and per-market distribution regulators, where disclosure is required or permitted by law.

Personal data may be transferred to, and processed in, jurisdictions outside the European Economic Area, the United Kingdom and the Cayman Islands, including the Dubai International Financial Centre and the jurisdictions of our service providers and target distribution markets. Some of these jurisdictions may not provide a level of data protection equivalent to that of the originating jurisdiction. Where personal data is transferred internationally, we rely on an applicable lawful transfer mechanism, which may include an adequacy decision or determination, standard contractual clauses or equivalent contractual safeguards, or another permitted basis under the applicable data protection law. Further information about the safeguards applied to a particular transfer is available on request.

Subject to and in accordance with the applicable data protection law, you have the right to be informed about the processing of your personal data, the right of access, the right to rectification, the right to erasure in certain circumstances, the right to restrict processing in certain circumstances, the right to data portability where applicable, the right to object to processing carried out on the basis of legitimate interests, the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects, and, where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of processing before withdrawal. Certain rights may be limited where we are required to retain or process personal data to comply with a legal or regulatory obligation, or to establish, exercise or defend legal claims. To exercise any right, contact mike@helmshare.com.

Personal data is retained for as long as necessary for the purposes for which it was collected, and thereafter for the periods required to comply with applicable legal, regulatory, tax and anti-money laundering record-keeping obligations and to establish, exercise or defend legal claims. Anti-money laundering records are generally retained for at least five years after the end of the business relationship, or for such longer period as applicable law requires. After the applicable retention period, personal data is securely deleted or anonymised. We maintain a retention schedule, available on request.

This website uses cookies and similar technologies to operate the website, to remember your preferences, and to understand how the website is used. For detailed information about the cookies we use and how to manage them, please refer to our Cookie Policy.

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, affected individuals, in accordance with the applicable data protection law.

If you are concerned about the processing of your personal data, you may complain to the relevant supervisory authority. In the Cayman Islands the supervisory authority is the Office of the Ombudsman. In the United Kingdom it is the Information Commissioner's Office. In the European Union and European Economic Area it is the data protection supervisory authority of the member state of your habitual residence, place of work, or the place of the alleged infringement. We ask that you raise any concern with us first at mike@helmshare.com so that we may seek to resolve the matter.

We may update this Policy from time to time. The current version is identified by the updated date at the top of this page. Material changes will be notified to investors.

If you have any questions or requests regarding this Policy or our data processing practices, please contact us at mike@helmshare.com.