May 2025
Who we are?
We are Alis Biosciences Limited, a closed ended investment scheme incorporated and registered in Guernsey with limited liability under the Companies (Guernsey) Law, 2008 (registered number: 71713) of Les Echelons Court, St. Peter Port, Guernsey GY1 4AN. We, or any third-party service provider, functionary or agent appointed by us and acting on our behalf are referred to under this policy as “Alis”, “we”, “us” and “our”.
This policy sets out how we process your personal data which is either provided by you directly or is collected via our website. In the event we process your personal data under any other circumstances we will ensure that a privacy policy is provided to you prior to processing your personal data.
We take appropriate technical and organisational measures to ensure the security of the data and to prevent unauthorized access or disclosure of your personal data. For more information, please contact us at: [email protected].
| What data? | Why do we process it? | What’s our lawful basis? |
| Investors and Authorised Representatives | ||
| Personal data including your name, age, marital status email address, postal address, and telephone number as well as your professional title, occupation and details of your employment (“Investor Data”). | We collect and process this via application forms or other materials you or your authorised representative submits to us during the course of your relationship with us. | We do this as necessary for our legitimate interest to respond appropriately to you in a timely manner. |
| Identification information such as your social security number, national insurance number, tax file number, IP address or our internal electronic identifiers as well as financial information, tax status, account details and evidence of ownership of financial assets (“Identification Data”). | We collect and process this where we undertake our know-your-client (“KYC“) checks | We process this personal data to comply with our legal obligations to understand our investors including their source of wealth as well as complying with our credit and money laundering checks. |
| Any additional information as well as additional personal data provided other information you provide in the course of your dealings with us (“Additional Data”). | We do this in order to respond quickly and effectively to your comments. | We do this as necessary for our legitimate interest to process your request and respond appropriately to you. |
| Information obtained via recorded telephone calls. | We do this where we are required under relevant financial regulations. | We do this as necessary to comply with our legal obligations. |
| We may process your name and email address to send you marketing communications in line with your specified preferences (“Marketing Data”). | We do this in order to keep you up to date with our services and latest news in line with your preferences. | We do this under our legitimate interest to provide you with updates relevant to you and your requirements. |
| Website Users | ||
| Online identifiers (including IP address), device information and information about your visit to our website (including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page) (individually and together “Tracking Data“). | To ensure that the content on our website is presented in the most effective manner for you and your device. | We do this as necessary for our legitimate interest to ensure your user experience is suitable for your requirements. |
| To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. | Where you have provided us with your consent to do so. | |
| We do this as necessary for our legitimate interest to ensure your user experience is suitable for your requirements. | ||
| Contact data including your name, email address, postal address, social media handle, and telephone number (“Website Contact Data”). | We collect and process this where you contact us with any enquiries or queries you may have about Alis and our services including via our webform or on social media. | We do this as necessary for our legitimate interest to respond appropriately to you in a timely manner. |
| Any contact information as well as additional personal data provided in in the free text zones provided for this purpose in the webform(s) (“Additional Website Data”). | We do this in order to respond quickly and effectively to your comments. | We do this as necessary for our legitimate interest to process your request and respond appropriately to you. |
| We may process your name and email address to send you marketing communications in line with your specified preferences (“Website Marketing Data”). | We do this in order to keep you up to date with our services and latest news in line with your preferences. | We do this where you have provided us with your consent for us to contact you. |
| Where you are a business professional or an investor, we do this under our legitimate interest to keep you updated. | ||
Who do we share your personal data with?
| What personal data? | Who do we share it with? | Why do we share it? | What’s our lawful basis? |
| Investors and Authorised Representatives | |||
| Investor Data. | Service providers which may include Alis’s investment manager, investment adviser, administrator, custodian and registrar, as well as the website’s host and Alis’s IT and technical providers. | To ensure any enquiries or applications are processed by the appropriate party in accordance with your reasonable expectations. | We do this as necessary for our legitimate interest to process your application. |
| Where we are required to do so to fulfil our contractual obligations to you. | |||
| Lawyers and accountants and other similar external advisors. | Where we need to take steps to defend ourselves in respect of a legal claim or to comply with our legal obligations. | Where we share personal data in order to comply with our legal obligations or to defend legal claims made against us. | |
| Regulators, authorities and governmental bodies. | |||
| Identification Data. | Regulators, authorities and governmental bodies. | Where we are required to do so to comply with our legal obligations. | Where we share personal data in order to comply with our legal obligations or to defend legal claims made against us. |
| Additional Data. | Service providers which may include Alis’s investment manager, investment adviser, administrator, custodian and registrar, as well as the website’s host and Alis’s IT and technical providers. | To ensure any enquiries or applications are processed by the appropriate party in accordance with your reasonable expectations. | We do this as necessary for our legitimate interest to respond to your application or any requests made to us. |
| Where we are required to do so to fulfil our contractual obligations to you. | |||
| Regulators, authorities and governmental bodies. | Where we are required to do so to comply with our legal obligations. | Where we share personal data in order to comply with our legal obligations or to defend legal claims made against us. | |
| Information obtained via recorded telephone calls. | Regulators, authorities and governmental bodies. | Where we are required to do so to comply with our legal obligations. | Where we share personal data in order to comply with our legal obligations or to defend legal claims made against us. |
| Website Users | |||
| Tracking Data. | Third party analytics providers. | To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. | Where you have provided us with your consent to do so. |
| We do this as necessary for our legitimate interest to ensure your user experience is suitable for your requirements. | |||
| Website Contact Data. | Service providers which may include Alis’s investment manager, investment adviser, administrator, custodian and registrar, as well as the website’s host, Alis’s IT and technical providers. | To ensure your request is processed by the appropriate party in accordance with your reasonable expectations. | We do this as necessary for our legitimate interest to process your request and ensure the appropriate party responds appropriately to you. |
| Additional Website Data. | |||
| Website Marketing Data. | Third party service providers. | Where you have indicated that you wish for us to receive communications from third party service providers. | Where we have obtained your consent to do so. |
Automated processing
We do not carry out automated decision-making or profiling.
Where is your personal data stored?
Your personal data is stored in Guernsey and/or the United Kingdom and where we transfer your personal data outside of Guernsey, the UK/EEA we will ensure that it receives additional protection as set out under data protection laws.
EU data subjects: Personal data may be transferred to, and stored at, destinations outside the European Economic Area (“EEA“) and the Bailiwick of Guernsey (“Guernsey“). Some of these destinations may not have data protection laws that are similar to those in the EEA and Guernsey and may not be regarded by the European Commission or Guernsey’s Data Protection Authority (as applicable) as providing an adequate level of data protection. When we, or our permitted third parties, transfer personal information outside the EEA or Guernsey, we will ensure that the transfer is subject to appropriate safeguards in accordance with Data Protection Legislation.
UK data subjects: Personal data may be transferred to, and stored at, destinations outside the United Kingdom and Guernsey. Some of these destinations may not have data protection laws that are similar to those in the United Kingdom and Guernsey and may not be regarded by the UK Government or Guernsey’s Data Protection Authority (as applicable) as providing an adequate level of data protection. When we, or our permitted third parties, transfer personal information outside the United Kingdom or Guernsey, we will ensure that the transfer is subject to appropriate safeguards in accordance with Data Protection Legislation.
How long do we hold onto your data for?
We will only hold onto your personal data for as long as we need it and in connection with the purpose we initially collected it for unless we must hold onto it for longer to comply with our legal, accounting or regulatory requirements.
In certain circumstances we may anonymise the personal data we hold about you so that you can no longer be identified. This information may then be used indefinitely.
What rights do you have?
Under data protection laws you have a number of rights available including the right to:
- access your personal data;
- correct incomplete/ inaccurate data;
- erase the personal data we hold about you;
- restrict how we handle your personal data;
- ask us to transfer your personal data to a third party;
- object to how we process your personal data; and
- withdraw your consent at any time.
You also have the right to complain to us and/or the applicable supervisory authority including the Guernsey Data Protection Authority whose address is St Martin’s House, Le Bordage, St Peter Port, Guernsey GY1 1BR and for England and Wales the Information Commissioner’s Office (“ICO“). You can make your complaint via the ICO’s website here. Alternatively, a full list of Supervisory Authorities in the EU can be found here.
How can you contact us?
If you have any questions or comments about this policy please do not hesitate to reach out to [email protected].
