Privacy and data protection policy
Personal information is subject to certain legal safeguards specified in the General Data Protection Regulation (2016/679) (“GDPR”) and any secondary and domestic legislation implementing the GDPR (together, the “Data Protection Legislation”). Optis Investment Management (“Manager” or “we”) is a ‘controller’ of your personal information for the purposes of the GDPR.
1. We will use the following reasons for processing your personal information:
- We are processing your information in the operation or performance of our services to you
- We have a legal obligation to do so
- We have a legitimate reason to process your information
- You have given your consent for us to do so
2. What kinds of personal information about you do we process?
OIM and its associated companies may collect the following information:
- Date and country of birth
- Current domicile and address as well as proof of address
- Contact information including full name, surname, telephone numbers, e-mail address and gender
- Identification documents such as passports and national identity documents
- Tax domicile and tax identification number
- Bank account details, source of wealth information, accounts and bank statements;
- Information relating to regulatory status or eligibility to make investments
- Any other information necessary for us to perform our services to you
- Log in information if you have been granted access to certain information on our website
- You are not required to submit any personal information on our website unless you voluntarily wish to do so to access certain information on the website.
3. Where do we collect your Personal Information?
We may collect personal data via direct interactions (where a person provides personal data to us through correspondence or other direct methods of communication, including communications relating to investments) and from third-party or publicly available sources (where we receive personal data through a publicly available source such as a website or publicly-available registry).
4. What do we use your personal data for?
We collect and use your personnel data for the following purposes:
- in the operation or performance of our Services to you
- to communicate to you any updates, market outlook and research materials in relation to the Services;
- any other purpose specified in any form or document that requests your Personal Data.
- For meeting our legal and regulatory obligations including meeting our legal and regulatory obligations in relation to checking identification of our clients and taking steps to avoid money laundering and terrorist financing; and meeting the requirements to make disclosures under any law, regulation or court order.
- Optis Investment Management will never sell your personal data.
5. When do we share your personal information with other organisations?
Personal Data held by us will be kept confidential but we may provide such information to any associated company within the OIM group as well as the service providers of the OIM group including the registrar, transfer agent, custodian, administrator, distributors, securities and investment service providers and the auditors. Where we share your personal information with a third party, we generally take steps to ensure the recipients of that personal information will process it appropriately.
6. Is your personal information transferred outside the UK or the EEA?
Your personal information is held by Optis Investment Management and the administrator of the funds, and may be shared with advisers, service providers, and disclosed to regulatory, tax or other governmental or public authorities outside the UK and EEA, as described above. Such transfers may be made at least to the following jurisdictions: South Africa, British Virgin Islands. Where we share your personal information with persons outside the EEA we will, to the extent practicable, take appropriate steps to ensure your personal information is subject to safeguards in compliance with the requirements of Data Protection Legislation.
7. For how long is your personal information retained by us?
We will not retain your personal information for longer than is necessary in relation to the purposes for which your personal information is processed and in accordance with regulatory requirements. Generally, we will retain your personal information concerning your investments for  years after the end of any relevant contractual relationship. Personal information may be retained for longer if it is required by law, or by a tax or regulatory authority, a law enforcement agency or other governmental or public body, or considered necessary to allow us to act in accordance with a specific set of circumstances, for example, in the event of an actual or a potential legal action or a regulatory investigation.
8. Security of your personal data
OIM have physical, electronic and procedural safeguards in place to protect your personal data against unauthorised access, disclosure or loss.
9. What are your rights under data protection laws?
You have various rights under Data Protection Legislation in relation to the personal information relating to you. These include:
- the right to request access to your personal information;
- the right to have your personal information rectified;
- the right to have your personal information erased in certain circumstances;
- the right to request that your personal information is only used for restricted purposes;
- (if the lawful basis for processing your personal information is the legitimate interest of the Fund/ the Investment Manager) the right to object to your personal information being processed, for example, for marketing purposes;
- (in some circumstances) the right to require certain of your personal information to be transferred to you or a third party; and
- the right to lodge a complaint with the relevant data regulator in your jurisdiction.
- You can seek to exercise any of these rights by contacting us at:
27 Oak Road
10. Questions or complaints
- If you wish to provide us with any feedback regarding this policy, have a complaint or wish to exercise any of your rights listed above, please contact us via e-mail at firstname.lastname@example.org
- Alternatively, if you are not satisfied with our response, you can contact our supervisory authority, which is the United Kingdom, Information Commissioner’s Office (ICO) who can be contacted directly on 0303 123 1113 or by visiting: https://ico.org/concerns