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We will collect and process all personal data that you provide us, be that or by corresponding with us via email or post. This includes information you provide us when you subscribe to any of our services or respond to a promotion or survey. If you contact us, we will keep a record of that correspondence.
By entering your details in the fields requested, you enable us and our service providers to provide you with the services you select. Whenever you provide such personal information, we will treat that information in accordance with this Privacy Notice. When using your personal information we will act in accordance with the law.
We are a data controller, which means we are responsible for the personal data that we hold about you. Additionally, Altarius is a joint data controller of Altarius Funds S.A. SICAV-RAIF that actually means the following policy fully applies for the purpose of assuming such responsibilities that Altarius holds under this agreement.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
This privacy notice was last updated on 25th February 2020.
1. THE DATA WE COLLECT ABOUT YOU
2. HOW WE COLLECT AND USE INFORMATION
3. WHO WE SHARE INFORMATION WITH
4. HOW WE APPLY OUR POLICY
5. HOW THE LAW PROTECT YOU
6. COOKIES
7. INTERNATIONAL TRANSFERS
8. YOUR LEGAL RIGHTS
9. MARKETING
10. CHANGES TO OUR PRIVACY POLICY
11. OUR REGULATOR
12. CONTACTING US
1. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity and Biographical Data including first name, maiden name, last name, username or similar identifier, title, date of birth, gender, nationality, marital status, and national/identity card numbers (or other details), your country of domicile, your employment and employment history, job title and role, educational profile, interests and other information relevant to our provision of professional services.
• Contact Data includes your home address, delivery address, email address, telephone numbers and ID for Skype or other social media and communication platforms.
• Transaction Data includes details about payments/transfers to and from you and other details of products and services you have purchased or contracted through us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version and other technology on the devices you use to access this website.
• Profile Data includes your username, password and any unique identifier assigned by us.
• Usage Data includes information about how you use and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
| Type of personal information | Description |
|---|---|
| Contact | Your name, where you live and how to contact, you |
| Socio-Demographic | This includes details about your work or,profession, nationality, education and where you fit into general social or,income groupings |
| Transactional | Details about payments to and from your, accounts with us, and insurance claims you make |
| Contractual | Details about the products or services we,provide to you |
| Locational | Data we get about where you are. This may,come from your mobile phone or the place where you connect a computer to the,internet. It can also include shops where you buy something with your card |
| Behavioural | Details about how you use products and,services from us and other organisations |
| Technical | Details on the devices and technology you,use |
| Communications | What we learn about you from letters and,emails you write to us and conversations between us |
| Social Relationships | Your family, friends and other relationships |
| Open Data and Public Records | Details about you that are in public,records, such as the ectoral Register, and information about you thatis,openly available on the internet |
| Usage Data | Other data about how you use our products,and services |
| Documentary Data | Details about you that are stored in,documents in different formats, or copies of them |
| Special types of data | The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so: • Racial or ethnic origin • Religious, political or philosophical beliefs • Trade union membership • Genetic and bio-metric data • Health data • Lifestyle information, including data related to sex life or sexual orientation • Criminal records of convictions and offences • Allegations of criminal offences |
| Consents | Any permissions, consents or preferences,that you give us.This includes things like how you want us to contact you, whether you get paper statements, or prefer large-print formats |
| National Identifier | A number or code given to you by a, government to identify who you are, such as aNational Insurance number or, social security number, or Tax Identification Number (TIN) |
2. HOW WE COLLECT AND USE INFORMATION
When you are a client, most of the information we collect is obtained from you. You may, for example, provide us with personal information when you initially request us to provide our services and otherwise during the normal course of providing our services. You may also provide us with personal information when you complete client engagement formalities and when responding to our KYC (“know your customer”) requirements.
We collect personal information from you in different ways, including:
- When you use (or get in touch with us via) our website
- When you apply for our financial products and services
- When you talk to us on the phone or at the office branch
- When you provide us with documentation we may require for compliance with our “know your customer” obligations
- When you research or request forms and in writing or through any other medium
- From financial reviews and interviews
- When you complete any of the forms which we may require you to complete to assist us with our compliance with our “know your customer” obligations
- When you complete customer surveys
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Receiving your personal data from others:
We may also receive or obtain personal data about you from public registries, public sources and from various third parties (including your organisation, agents, advisers, intermediaries or custodians of your assets).
3. WHO WE MAY SHARE INFORMATION WITH
To provide you with our services, we share your personal data with a small number of trusted third-party service providers. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
4. HOW WE APPLY OUR POLICY
In order to put our policy into practice, we use our best endeavours to follow the following seven guidelines:
- We will ensure our systems are secure to protect your Personal Information from misuse and follow appropriate physical, electronic and managerial procedures to safeguard it;
- We will respect your privacy in the way that we contact you, whether by post, telephone, email or text message;
- We will not hold your personal for longer than is necessary to effectively provide you with our services and comply with applicable legislation;
- We will not sell, trade or rent your Personal Information.
- We will comply promptly with any instructions from you to update your Personal Information or requests from you to see the Personal Information that we hold on you;
- We will comply with lawful requests to disclose personal information to certain authorities (e.g. the police);
- We may monitor and record any telephone calls to ensure we follow your instructions correctly and to improve our service
5. HOW THE LAW PROTECTS YOU
Under the Data Protection Act 2004, we are only allowed to process personal information if we have a lawful basis for doing so. These include circumstances where we process the personal data:
- To comply with our contractual obligations to you;
- To comply with a legal obligation (outside of the contract);
- In our legitimate interest or your legitimate interest;
- In limited circumstances where it is in the public interest;
- With your consent.
When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.
The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be with your consent when it is necessary:
- For reasons of substantial public interest, or
- To establish, exercise or defend legal claims.
Our basis for processing: how and why we use your personal data
| WHAT WE USE YOUR PERSONAL INFORMATION FOR | OUR REASON | SOUR LEGITIMATE INTERESTS |
|---|---|---|
| • To manage our relationship with you or your business• To develop and carry out marketing activities• To study how our customers use pr oducts and services from us andother organizations• To communicate with you about our products and services• | Your consent• Fulfillingcontracts• Our legitimateinterests• | • Keeping our records up to date, working out which of our products and services may interest you and telling you about them • Developing products and services, and what we charge for them • Defining types of customers for new products or services • Seeking your consent when we need it to contact you • Being efficient about how we fulfil our legal and contractual duties |
| Business improvement | ||
| • To test new products • To manage how we work with other companies that provide services to us and our customers • To develop new ways to meet our customers’ needs and to grow our business | • Fulfilling contracts • Our legitimate interests • Our legal duty | • Developing products and services, and what, we charge for them • Defining types of customers for new, products or services • Being efficient about how we fulfil our, legal and contractual duties |
| Managing our operations | ||
| • To deliver of our products and services • To make and manage customer payments • To manage fees, charges and interest due on customer accounts • To collect and recover money that is owed to us • To manage and provide treasury and investment products and services | • Fulfilling contracts • Our legitimate interests • Our legal duty | • Being efficient about how we fulfil our, legal and contractual duties • Complying with rules and guidance from, regulators |
| Managing security, risk and crime prevention | ||
| • To detect, investigate, report, and seek to prevent financial crime • To manage risk for us and our customers • To obey laws and regulations that apply to us • To respond to complaints and seek to resolve them | • Fulfilling contracts • Our legitimate interests • Our legal duty | • Developing and improving how we deal with, financial crime, as well as doing our legal duties in this respect • Complying with rules and guidance from, regulators • Being efficient about how we fulfil our, legal and contractual duties |
| • To run our business in an efficient and, proper way. This includes managing our financial position, business, capability, planning, adding and testing systems and processes, managing, communications, corporate governance, and audit | • Our legitimate interests• Our legal duty• | Complying with rules and guidance from, regulators• Being efficient about how we fulfil our, legal and contractual duties |
| • To exercise our rights set out in, agreements or contracts | •Fulfilling contracts | |
| For processing special categories of personal data | ||
| • Substantial public interest• | Using criminalrecords data to help prevent, detect, and prosecute unlawful acts andfraudulent behaviour• Using criminal and health information as needed to provide insurance products | |
| • Responding to regulatory requirements• | Showing whetherwe have assessed your situation in the right way• Passing information to the regulator as neededto allow investigation into whether we have acted in the right way | |
| • Legal claims | • Using any special categories of data as, needed to establish, exercise or defend legal claims | |
| Consent | • Telling you that we need your consent to, process special categories of personal data, when that is what we rely on for, doing so | |
6. COOKIES
To optimize your experience at our website, we use cookies. Cookies are small computer files that get sent down to your PC, tablet or mobile phone by websites when you visit them. They stay on your device and get sent back to the website they came from, when you go there again.
Cookies store information about your visits to that website, such as your choices and other details. Some of this data does not contain personal details about you or your business, but it is still protected by this Privacy notice.
You may elect to disable cookies and as a result some of the services may not operate the same as if you were to have the cookie function enabled.
7. INTERNATIONAL TRANSFERS
In circumstances where we need to transfer any personal data outside of the EEA will ensure that the recipient of the personal data provides that personal data the same level of protection that we apply to it.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. They are as follows:
- Right to be informed you have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights; this is why we are providing you with the information in this privacy notice.
- Request access to your personal data you can request access to your personal data.
- Request correction of your personal data where we hold information about you that is inaccurate or incomplete, you have the right to ask us to correct inaccuracies, or complete it
- Request erasure of your personal data in certain circumstances you may require us to erase and/or destroy the information.
- Object to processing of your personal data you can object to us processing your personal information in certain circumstances, including where we are using it for the purpose of the Company’s legitimate business interests as set out above.
- Request restriction of processing your personal data in certain circumstances you have the right to restrict some processing of your personal information, which means that you can ask us to limit what we do with it.
- Request transfer of your personal data you have the right to obtain from us and re-use your personal data for your own purposes. This only applies, however, where the processing is carried out by automated means, to personal data that you have provided to us yourself (not any other information) and where the processing is based on your consent or for the performance of a contract
- Right to withdraw consent where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
- Right to complain – you are able to submit a complaint to the Gibraltar Regulatory Authority about any matter concerning your personal information, using the details below. However, we take our obligations seriously, so if you have any questions or concerns, we would encourage you to raise them with us first, so that we can try to resolve them.
All of these rights can be applied at any time at the request of the interested subject contacting us.
Access Requests
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please contact us.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Depending on the extent of the request, we may make a small charge for this service. We may refuse to comply with your request in circumstances where your request is clearly unfounded, repetitive or excessive.
We try to respond to all legitimate requests as soon as reasonably practicable and, in any event, within 30 days of receipt of the request except in cases of complex or multiple requests.
- How long we keep your personal information
We will keep your personal information for as long as we continue to provide services to you. We may keep your data for up to 10 years after you stop being a customer.
The reasons we may do this are:
- To respond to a question or complaint, or to show whether we gave you fair treatment
- To study customer data as part of our own internal research
- To obey rules that apply to us about keeping records
We will only use your personal information where we have a lawful basis for doing so.
9. MARKETING
We would like to send you information about our services that will be of interest and benefit to you.
We use mailing lists to manage how we contact you. This enables us to record and manage how we contact you, and to manage your preferences and bookings for our events.
This data helps us to ensure our mailing list remains up to date; it also provides us with some basic information about your interests and to personalise our communications with you.
- Opting out
You have a right to stop us from contacting you for marketing purposes.
10. CHANGES TO OUR PRIVACY NOTICE
We keep our privacy notice under regular review to keep it up to date according legislation and best practices. We will inform you as soon as possible any update, as well as we will placed it on this web page.
11. OUR REGULATOR
You have the right to make a complaint at any time to the Gibraltar Regulatory Authority (the “GRA”), the supervisory authority for data protection issues in Gibraltar (www.gra.gi). We would, however, appreciate the chance to deal with your concerns before you approach the GRA so please contact us in the first instance
The GRA’s contact details are:
Gibraltar Regulatory Authority
2nd floor, Eurotowers 4. 1 Europort Road
Gibraltar, GX11 1AA
Tel: (+350) 20074636
Email: info@gra.gi
12. CONTACTING US
If you have any questions about our privacy notice or information we hold about you, you can contact us by the following ways:
- Contact by email, please contact us at dataprotection@altariuscapital.com
- Contact by post mail:
Altarius Capital Ltd.
Suite 5.26 World Trade Center, 6 Bayside Road
Gibraltar, GX11 1AA
