The protection of personal privacy is an important concern to Volta Finance Limited. Any personal data collected will be treated in accordance with current data protection legislation.

In this privacy notice, Volta Finance Limited may be referred to as “Volta”, "we", "our" or "us". This privacy notice describes Volta’s policies and procedures regarding how personal data is used, stored, transferred or otherwise processed, together with related matters.

What is this Notice?

In the course of providing various services to you or in the course of providing services to or dealing with an entity by which you are employed (or in which you have an interest) or someone by whom you are employed or engaged, we may process your personal data - personal information relating to you from which you may be identified, as further described below.

When we receive personal data, we will act as a "data controller" in relation to some or all of such personal data. The data controller determines how the personal data is used and for what purposes. We are required to comply with The Data Protection (Bailiwick of Guernsey) Law 2017, as amended, along with other similar applicable laws in other countries around the world, including the European Union General Data Protection Regulation (“GDPR”). This Privacy Notice forms part of our obligation to be open and fair with all individuals whose personal data we process and to provide full information on how we process such personal data and what we do with it.

If you receive services or products from us, or you have specific interactions with us (for example, as an existing or prospective investor), you may be provided with further privacy notices or statements which may be contained in a separate supplemental policy or within our terms and conditions of business. These additional privacy notices or statements shall supplement this Privacy Notice.

What personal data do we collect and process about you?

GDPR defines personal data as the following:

‘Any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;’

‘Special categories’ of personal data (sensitive personal data) relate to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation and criminal data. 
We will collect and process all or some of the following personal data about you:

Information that you provide to us
This includes information that you provide to us or by communicating with us (or our Service Providers), whether by phone, e-mail or otherwise, including in relation to an investment in Volta or any services that we may provide to you. This information may include the following personal information about you or other connected individuals:
•    full name, date of birth, place, district and country of birth, nationality, home or work address and telephone number, mobile telephone number, bank account details, tax details;
•    National Insurance number, passport details, and proof of identification for anti-money laundering (“AML”) and counter terrorism financing (“CTF”) checks (e.g. driving license, utility bills); and
•    personal data that we collect through your communication with us (or our Service Providers) via email (including but not limited to your full name, email address and the content, date and time of your email correspondence) and through call recording.

Information we generate about you
This may include details such as your investment in Volta.

Information we obtain about you from other sources
•    personal data, that may include special categories data such as political affiliation in the case
of a politically exposed person, criminal conviction for the person listed on the terrorism sanctions list, negative media,  that we obtain through any AML, CTF and general “know your customer”
checks that we undertake to comply with applicable laws and regulations ; and
•    Where you have invested in Volta via a third party financial adviser, broker or consultant, personal data described above may be provided to us by such third parties.

Where you have notified us of your financial adviser, broker or consultant, the personal information that you have provided may be shared with that financial adviser, broker or consultant for the purposes outlined below. You must notify us if you no longer want us to share your personal information with, or if you have appointed a different, financial adviser, broker or consultant.

How do we use your personal data?

We comply with our obligations under GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by having appropriate technical measures in place to protect your personal data.

Your personal data may be stored and processed by us or our Service Providers in the following ways and for the following purposes:

(a)  Facilitating the holding of an investment in Volta and administering your holding on an ongoing basis including without limitation processing your personal data for transfer requests and distribution payments;

(b)  Complying with any applicable legal, tax or regulatory obligations imposed on us and requests from regulatory, governmental, tax and law enforcement authorities, including, without limitation, with respect to compliance with the US Foreign Account Tax Compliance Act (“FATCA”) and the OECD common reporting standard (“CRS”) or any legislation, regulations or guidance enacted in any jurisdiction that seeks to implement a similar tax reporting or withholding tax regime, including legal obligations arising from Volta’s shares being listed on one or more EU regulated stock exchanges, tax rules and guidance, AML and CTF legislation and to ensure compliance with sanctions, including but not limited to:

1.   Fund related legislation : in order to comply with laws or regulations applicable to Volta, we may process your personal data for a variety of reasons including but not limited to sending you notices or other communications relating to Volta, convening investor meetings and related purposes;
2.   AML and CTF legislation: in order to carry out AML and CTF checks and related actions, which we consider appropriate to meet any legal obligations imposed on us or our Service Providers, or the processing in the public interest or to pursue our legitimate interests, in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with our and our Service Providers’ AML and CTF procedures;
3.   Tax  regulations:  we  may  be  obliged  to  collect  certain  information  about  your  tax
arrangements. Please note that in certain circumstances we may be legally obliged to share this information, and other financial information with respect to your interests in Volta, with relevant tax authorities;
4.   Market abuse: taking appropriate steps to identify and prevent late trading and market timing practices or any other controls relating to the prevention of market abuse.
5.   Fraud: in order to undertake investigation, surveillance and audit checks and to prevent and
detect fraud.
6.   Statutory registers: in order to maintain statutory registers.

(c) Pursuing our and/or the Service Providers’ legitimate interests which include:
1.   carrying out statistical analysis and market research;

2.   disclosures to third parties such as auditors, regulatory, tax authorities and technology providers in the context of the day-to-day operation of Volta;

3.   recording, maintaining, storing and using recordings of telephone calls that you make to and receive from us, our Service Providers and their delegates or duly appointed agents and any of their respective related, associated or affiliated companies for processing and verification of instructions, management and administration of your account(s) and any other matters related to your investment in Volta, dispute resolution, record keeping, protection against fraud, security and/or training purposes; and

4.   complaints handling;

5.   sharing information on Volta’s services and upcoming events;

6.   tailoring and personalizing the information we distribute, by combining and analysing the data we collect, to give a more seamless, consistent and bespoke experience.

Where personal data is processed for purposes of legitimate interests, you have a right to object to such  processing  and  we will  no  longer  process  the  personal  data  unless  we  can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. However, where you fail to provide such personal data we will not be able to provide you with investment services or to the extent that we do provide investment services to you and the required personal data is not provided by you within the specified timeframe, we may be required to discontinue our relationship with you.

Your consent is not required to process your personal data for the purposes referenced above.

How do we use your personal data for communications?

Where you have separately confirmed to us that you are willing to receive communications relating to Volta, we may also process your name, address, email address and IP address for these purposes. You may withdraw your consent at any time. Instructions on how to withdraw such consent will be provided in the marketing  communications you receive or you can withdraw  such consent by contacting us via the contact details provided within this Notice.

For us to be able to send you information that is relevant to you or your business, we may undertake some behavioural data analysis based on your past behaviour (for example, your attendance at events or opening of emails sent by us or on our behalf).

AXA IM Paris, in the context of its asset management activities for Volta,  is responsible for personal data collected in respect of newsletter subscriptions, for the AXA IM Paris GDPR Policy visit Politique de protection des données personnelles | AXA IM FR (axa- im.fr)

How do we use cookies?

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.

Like many sites, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit  www.aboutcookies.org or www.allaboutcookies.org.

How do we share your personal data?

Your personal data may be handled by us and the Service Providers (organisations providing financial or technology services to us) or any of our or their respective related, associated or affiliated companies for the purpose as specified above. The Service Providers will act in the capacity of a Data Processor or in some cases as Data Controller (for our Asset Manager AXA IM Paris)  and will handle your information in accordance with GDPR and your personal data will be treated as strictly confidential.

We may disclose your personal data to other third parties where required by law or for legitimate business interests. This may include disclosure to third parties such as, but not limited to, auditors, financial regulators and taxation authorities.

Do we transfer your personal data abroad?

In limited and necessary circumstances, your information may be transferred outside of the
UK or the European Economic Area (“EEA”) to comply with our legal or contractual requirements. It
may also be processed by individuals operating outside of the UK, Bailiwick of Guernsey or the EEA who work for our affiliates or for one of our Service Providers.

Where we (or our Service Providers) transfer your personal data outside the UK or the EEA, we have in place safeguards including:

•    we have policies and procedures applicable to transfer of personal data, which address the storage and processing of personal data;

•    the country that we send the data to might be approved by the European Commission as offering a sufficient level of protection; 
•     the recipient might have signed up to a contract based on “model contractual clauses”
approved by the European Commission, obliging them to protect your personal data; or

•     where the recipient is located in the US, it might be a certified member of the EU-US Privacy Framework.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases we will only transfer your personal data in accordance with relevant data protection law.

Where applicable, you can obtain a copy of our safeguards given to your personal data when it is transferred outside the EEA (including a copy of any standard data protection clauses which we have entered into with recipients of your personal data) by contacting us using the contact details provided in this Notice.

How long do we keep your personal data for?

We and our Service Providers only retain your personal data for no longer than is reasonably necessary to fulfil the purpose with which we are using your personal data and as required by legal and regulatory requirements.

What are your rights?

Under GDPR you have a number of rights with regard to your personal data, including:
•         The right to request access to personal data;
•         The right to obtain information about the use of personal data;
•         The right to require rectification (correction) of errors in personal data without undue delay;
•         The right to have personal data erased without undue delay in certain circumstances;
•         The right to restrict the processing of personal data in certain situations;
•    The right to receive personal data in a structured, commonly used and machine-readable format and transmit that data to a third party;
•         The right to data portability;
•         The right to object to the processing of personal data in certain situations;
•         The right not to be subject to a decision based solely on automated processing in certain situations;•         The right to be notified of rectification, erasure and restrictions; and,
•         The right to lodge a complaint and the right to judicial review in certain situations.

If an individual wishes to exercise any of these rights and we have transferred that person’s data to a third party, we will communicate that request to the relevant third party unless it would be impossible or involve disproportionate effort for us to do so.

If you have provided consent for the processing of your personal data, for example receipt of marketing communications, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

You have the right to lodge a complaint to the Data Protection Authority if you believe that we have not complied with the requirements of GDPR with regard to your personal data. You 
can contact the Office of the Data Protection Authority by telephone on +44 (0)1481 742074 or via email at  enquiries@odpa.gg or at the Office of the Data Protection Authority, St Martin's House, Le Bordage, St Peter Port, Guernsey, GY1 1BR.

You can exercise your rights by contacting us using the contact details provided within this

Notice. What happens if you fail to provide us with your personal data?

Where you fail to provide personal data that is required by us in order to administer your holdings in Volta or otherwise provide you with services, we will not be able to provide you with such services or, where applicable, we may be required to discontinue our relationship with you.

We also encourage you to inform us as soon as possible where your personal data changes.

Will changes be made to this Notice?

This Notice was last updated on 16 July 2020 and it may change from time to time and is available via our website. Please check back frequently to see any updates or changes to this Notice. We reserve the right to amend this Privacy Notice at any time without notice, in which case the date of the policy will be revised.

How can you contact us?

If you have any questions about our collection, use, retention, disclosure, transfer or processing of your personal information or if you wish to exercise your rights listed above, please contact us either at the following email address:

guernsey.bp2s.volta.cosec@bnpparibas.com or in writing to:
Volta Finance Limited
BNP Paribas House St Julien’s Avenue
St Peter Port Guernsey GY1 1WA Channel Islands

We will respond to your request in writing, as soon as practicable and in any event within one month of receipt of your request, subject to the provisions of GDPR. We may request proof of identification to verify your request.