Data Privacy Notice

This notice is addressed to persons whose personal data is processed by the La Mancha group (comprising the entities set out in Section 15) (Group). We are required to provide you with this information under applicable data protection and transparency laws.

1. Contact Person

The lead point of contact for Group data protection matters is Matthew Fisher, the General Counsel of La Mancha Resource Capital LLP, who can be contacted at the address at the top of this page or by email to compliance@lamancha.com.

2. The data controllers

The Group member(s) responsible for determining the purposes and means of processing your personal data will depend on the circumstances in which they are collected and used. In general, where your personal data is processed in connection with:

your dealings with a particular Group entity, that entity will be the data controller;
your engagement as a staff member, the engaging entity will be the controller;
the making of filings under applicable data protection and transparency laws, the entity subject to the filing obligation will be the controller; and
the corporate affairs, governance, financing or transactions of a particular Group entity, that entity will be the data controller.

If you are unsure which Group member is the data controller for your personal data, please contact us using the contact details set out above.

3. Providing your data

In some circumstances, we must collect your personal data because the law, a contract, or entry into a contract with you requires it. Where provision of information is mandatory, we will indicate this to you. If you do not provide required information, we may be unable to enter into or continue the relevant relationship or transaction.

4. What personal data we process

Depending on your relationship with the Group, we may process some or all of the following categories of personal data:

Identity data such as full name, date and place of birth, nationality, passport and/or ID number, and signature.
Contact data such as postal address, email address, and telephone number.
Financial and transaction data such as bank account and payment details, investment amounts, holdings, account balances and transaction history.
Tax and reporting data such as tax identification number, tax residence, FATCA and CRS status or classification, FATCA or CRS self-certification data, information relating to reportable controlling persons, and other financial account information required for tax or automatic exchange of information reporting.
Regulatory and compliance data such as information required for AML, KYC and sanction-screening procedures, including source of wealth, source of funds, politically exposed person status, beneficial ownership or control information, and the results of due diligence checks.
Employment and professional data such as employer, job title and role, employment or engagement history, compensation and benefits information, professional qualifications, references, performance information, and disciplinary and grievance records.
Business and communications data such as details of your relationship or dealings with the Group, and correspondence, communications, meeting records and other records relating to those dealings.
Corporate and governance data such as information relating to directorships and other corporate offices, shareholdings and beneficial ownership, authorised signatory status, powers of attorney, statutory registers, corporate approvals and board or committee records.
Special category data such as health data, including information required to administer sickness absence, maternity leave, occupational health, workplace adjustments or employment-related benefits, and other special category personal data that we are required or permitted to process.
Criminal offence data such as information concerning criminal convictions, offences, allegations or related proceedings obtained in connection with background, AML, KYC or other checks.
Website and technical data such as information concerning your use of our website and systems, such as IP address, browser and device information, access logs and cookie information.

5. Amendments to this Policy

Depending on your relationship with the Group, we may process your personal data for some or all of the following purposes on the lawful basis indicated in the table:

Purpose	Categories of personal data we may process	Lawful basis
Fund administration and investor relations	Identity data; Contact data; Financial and transaction data; Tax and reporting data; Business and communications data.	Performance of a contract to which you are party; and/or our legitimate interests in administering La Mancha Funds, investments and investor relationships.
Investment and transaction activities	Identity data; Contact data; Financial and transaction data; Regulatory and compliance data; Employment and professional data; Business and communications data; Corporate and governance data.	Our legitimate interests in evaluating, executing, financing, managing and disposing of investments and other transactions; and/or compliance with the controller’s applicable legal obligations.
Regulatory and legal compliance	Identity data; Contact data; Financial and transaction data; Regulatory and compliance data; Employment and professional data; Business and communications data; Corporate and governance data; Special category data; Criminal offence data.	Compliance with the controller’s legal obligations; and/or our legitimate interests in meeting regulatory requirements, preventing financial crime and managing legal and regulatory risk.
FATCA, CRS and other tax reporting	Identity data; Contact data; Financial and transaction data; Tax and reporting data; Regulatory and compliance data; Corporate and governance data.	Compliance with the controller’s legal obligations.
Recruitment and management of staff	Identity data; Contact data; Financial and transaction data; Tax and reporting data; Regulatory and compliance data; Employment and professional data; Special category data; Criminal offence data; Website and technical data	Performance of a contract to which you are party; compliance with the controller’s legal obligations; and/or our legitimate interests in managing our workforce, administering our business and exercising our legal rights.
Risk management and security	Identity data; Contact data; Financial and transaction data; Regulatory and compliance data; Employment and professional data; Criminal offence data; Website and technical data.	Our legitimate interests in protecting the Group, its personnel, systems and assets, preventing and detecting fraud and other misconduct, and maintaining appropriate internal controls and security; and/or compliance with the controller’s legal obligations.
Corporate governance	Identity data; Contact data; Regulatory and compliance data; Employment and professional data; Business and communications data; Corporate and governance data.	Compliance with the controller’s legal obligations; and/or our legitimate interests in administering and governing Group entities.
Corporate registry filings, including in relation to beneficial ownership and directorships	Identity data; Contact data; Regulatory and compliance data; Employment and professional data; Corporate and governance data.	Compliance with the controller’s legal obligations.
Operation and security of our website and IT systems	Identity data; Contact data; Business and communications data; Website and technical data.	Our legitimate interests in operating, maintaining and securing our website, communications and IT systems; and consent where required by applicable law, including in relation to non-essential cookies.
Communications and direct marketing	Identity data; Contact data; Business and communications data.	Our legitimate interests in communicating with business contacts and providing information about the Group; and consent where required by applicable law.

6. Whom we share your data with

Where necessary for the purposes described in Section 5, we may share your personal data with:

other members of the Group;
the relevant La Mancha Fund’s portfolio companies or prospective portfolio companies;
counterparties and prospective counterparties in investments and other transactions;
fund administrators, transfer agents, alternative investment fund managers and other fund service providers;
banks and other financial institutions;
auditors, legal advisers, tax advisers and other professional advisers;
IT, technology, communications and information-security service providers;
HR, payroll and benefits providers;
insurers;
regulators, tax authorities and other governmental or public authorities;
corporate, beneficial ownership and other public or official registries; and
other persons where disclosure is required by law or reasonably necessary for the establishment, exercise or defence of legal rights.

Some recipients process personal data on our behalf and on our instructions as processors. Others process personal data for their own purposes and act as controllers in their own right.

7. Where we obtain your personal data

We may obtain personal data about you directly from you or from other sources, including other Group members, portfolio or prospective portfolio companies, investors, counterparties, service providers and professional advisers. We may also obtain personal data from publicly accessible sources, including corporate and other public registers, company websites and professional networking sites.

8. International Transfers

The Group operates across multiple jurisdictions, including the UK, Luxembourg, the DIFC and Malta. Some of our service providers also engage delegates in other countries. Your personal data may therefore be transferred to countries outside the jurisdiction in which it was collected.

Where a transfer is made to a jurisdiction covered by an adequacy ruling, we may rely on that ruling.

In other cases, we use an appropriate safeguard or other transfer mechanism permitted by applicable data protection and transparency laws. Such safeguards may include the European Commission’s standard contractual clauses and, for transfers subject to UK data protection law, the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s standard contractual clauses.

Further information about the safeguards applicable to a particular transfer, including information about how to obtain a copy of them, may be obtained by contacting us using the details set out above.

9. How long we keep your data

We keep your personal data only for as long as is necessary for the purpose for which it was collected, and to comply with our legal and regulatory obligations. In general, we retain:

Investor and fund administration records for the duration of your investment and 10 years after the relevant La Mancha Fund’s final winding up.
AML/KYC records for five years from the end of the business relationship or transaction.
CRS/FATCA records for 10 years from the end of the calendar year in which the relevant information is required to be reported.
Employment records for the duration of employment and for seven years thereafter.
Other records including corporate and transaction records in accordance with applicable legal or regulatory requirements and our internal retention policy.

We may retain data for longer where required by applicable legal or regulatory requirements, to respond to an investigation or legal hold, or for the establishment, exercise or defence of legal claims.

Personal data will be deleted or anonymised when no longer required.

10. Your right to object to processing

Subject to applicable law and certain exceptions, you have the right to object to processing where it is based on legitimate interests and/or conducted for direct marketing purposes.

11. Your other rights

Subject to applicable law and certain exceptions, you have the right to:

access your personal data and obtain a copy of it;
rectify inaccurate or incomplete personal data;
erase your personal data in certain circumstances;
restrict the processing of your personal data in certain circumstances;
receive your data in a structured, machine-readable format, where processing is automated and based on consent or a contract; and
withdraw consent at any time, where we rely on consent, without affecting processing carried out before withdrawal.

To exercise these rights or your right to object to data processing, please contact us using the contact details set out above.

We do not currently make solely automated decisions about you that produce legal or similarly significant effects.

12. Complaints

In case of complaints relating to data processing, you may contact the relevant data controller using the details set out above. Alternatively, you have the right to lodge a complaint with your local data protection authority. In the UK, this is the Information Commissioner’s Office (www.ico.org.uk). In Luxembourg, this is the Commission nationale pour la protection des données (www.cnpd.lu). In Malta, this is the Information and Data Protection Commissioner (www.idpc.org.mt). In the DIFC, this is the DIFC Commissioner of Data Protection (www.difc.com).

13. Changes to this notice

We review and update this notice from time to time. Where required by applicable law, we will bring material changes to your attention before they take effect. The most recent version will always be available on request.

14. Terms used in this notice

AML: anti-money laundering.
Applicable data protection and transparency laws: the data protection, privacy and transparency laws applying to the Group member processing your personal data, including (as applicable) the UK GDPR and the Data Protection Act 2018, the EU GDPR and applicable national implementing legislation, the DIFC Data Protection Law, and applicable legislation implementing or relating to DAC7, FATCA and CRS.
CRS: the OECD Common Reporting Standard for the automatic exchange of financial account information.
FATCA: the US Foreign Account Tax Compliance Act.
Group: the La Mancha group, comprising the entities set out in Section 15.
KYC: know-your-customer.
La Mancha Fund: any fund managed or advised by a Group member.
UBO: ultimate beneficial owner.

15. La Mancha Group entities

Entity name	Jurisdiction	Registered address
La Mancha Resource Capital LLP	United Kingdom	14 Grosvenor Street, London W1K 4PS
La Mancha Services UK Ltd.	United Kingdom	14 Grosvenor Street, London W1K 4PS
La Mancha Holding S.à r.l.	Luxembourg	31 Avenue Pasteur, L-2311 Luxembourg
La Mancha Precious Metals S.à r.l.	Luxembourg
La Mancha Investments S.à r.l.	Luxembourg
La Mancha Capital Management GP S.à r.l.	Luxembourg
LMH Explorers S.à r.l.	Luxembourg
La Mancha Resource Fund SCSp	Luxembourg
La Mancha Carry SCSp	Luxembourg
La Mancha Treasury Ltd.	Malta	B2, 5 Industry Street, Zone 5, Central Business District, Qormi CBD 5030
La Mancha Resource Management Services Middle East Ltd	DIFC	Premises 814, Level 8, Burj Daman