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Privacy Policy

Last Revised: December 13, 2022
Last Reviewed: December 13, 2022

Our Commitment to You

As a Sygnus Group investor, prospective investor or business partner, we understand that it is extremely important that your personal data is protected. Our offices are located in countries with laws that govern the protection and processing of personal data so we take our responsibility to you very seriously.

In this Privacy Policy, references to “Sygnus Group”, “we”, “us” or “our” means Sygnus Capital Limited and its affiliated companies. References to “you” or “your” refers to individuals whose personal data is processed by Sygnus Group, including clients with direct or indirect relationships (such as those who invest through an intermediary); employees, contingent workers, officers, agents (together “Representatives”); and beneficial owners of an organization or entity in connection with:

  • the provision of services to potential and actual clients;
  • transactions to which we are a party (including those which we effect on behalf of clients); or
  • services provided to us by a third-party vendor.

The Sygnus Group entity you contract with is the controller of your personal data. If your contract with the Sygnus Group is in connection with an investment in a Sygnus Group managed vehicle, the management company, together with the fund entity and, in circumstances where the investment manager is part of the Sygnus Group, that investment manager, will be the controller.

The Sygnus Group is committed to managing and processing personal data (including sensitive personal data) privately, securely, and in a manner that upholds all applicable privacy and data protection laws.

This Privacy Policy provides information on:

  • the personal data we collect from you and from third parties about you;
  • the purposes for which personal data is processed and our reasons for doing so;
  • your rights in relation to our processing of your personal data, and how you can exercise these rights.

Additional terms, conditions, and commitments may also govern how we collect, use, and disclose your personal data, which should be read in conjunction with this Privacy Policy.

Personal Data Definition

Personal data is information relating to an individual who is alive or who has been deceased for less than 30 years, which can be used either alone or with other sources of information in our possession or information which is likely to come into our possession to identify that individual.

Personal data also includes any expression of opinion about an individual and any indication of our intentions or those of any other person about an individual. Personal data does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous.

Where you have consented, we may process Sensitive Personal Data (“SPD”) which is a sub-category of personal data that consists of data relating to genetic or biometric data, filiation, race or ethnicity, political opinions, religious or philosophical beliefs, or other beliefs of a similar nature, sex life, trade union membership or the alleged commission of any offence or any proceedings for any offence alleged to have been committed.

Information we may collect

The nature of the information that we collect will depend on the nature of our relationship with you. We categorize the personal data we process as follows (the personal data listed for each category are non-exhaustive examples):

  • Identification data:
    Your full name, phone numbers, title, address, email, gender, signature, country of birth, country of residence, nationality, and marital status, government-issued identifiers, such as your tax-payer registration number, national identification number.
  • Financial data:
    Your banking details, taxpayer information, source of funding, source of wealth, income and assets.
  • Electronic Monitoring data:
    To the extent permitted by law, we may record and monitor your electronic communications with us.
  • Marketing and Communications data:
    Marketing and communication preferences and tracking data relating to whether you have read marketing or social media communications from us.
  • Professional Information data:
    Your employment information including your employer/business information, profession/job title, work address, telephone number and email address.
  • Services Data:
    Payment details to and from you; details of services you have provided to us, or we have provided to you.
  • Security Recordings:
    Records of visits to our premises including CCTV recordings.
  • Technical data:
    Your use of and interaction with our online services; your IP address; geographic location; browser type and version; browser plug-in types and versions and operating system.
  • Personal data:
    In limited circumstances, and where allowed by law, we may collect information about criminal convictions and offences, when legally required, and political affiliations for us to determine whether you are a politically exposed person.

How we collect Personal Data

We collect personal data in relation to you in several ways, including:

  • When you provide it to us in connection with our products or services, for example by completing an application or registration form.
  • if you are a representative of an organization or entity that is a client or vendor of Sygnus Group and that organization or entity provides us with your personal data.
  • throughout the course of our relationship with you, including where you change your details, provide additional personal data, or where the services we are providing to you change.
  • from public sources including through the media and public profiles on social media.
  • from third parties such as credit reference agencies and through organizations that provide background verification services.
  • from visits to our websites, social media pages or through logging into any of our online services.

We may also create or derive personal data such as creating records of your interactions with us, subject to applicable law.

Unless we otherwise indicate that the provision of specific personal data is optional, any personal data we request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the personal data requested, we may not be able to provide those products and services.

Purpose and legal basis for processing your Personal Data

The below table sets out the purposes and basis for which we process personal data. We will not collect or process personal data which is excessive, or which is not required for a specific purpose.

Processing Purpose

Category of personal data

Basis of Processing

To consider opening an account, or entering into a relationship at your request, including performing anti-money laundering, anti-terrorism, sanction screening, fraud, and other due diligence checks.

· Identification data

· Contact data

· Financial data

· Professional Information data

· Services data

· Personal data

· Performance of a contract
· Legal or regulatory obligation
· Legitimate interests: ensuring we do not accept the proceeds of criminal activities or assist in fraudulent or any unlawful activities, such as terrorism or proliferation financing.

To deliver the services you have requested, including liaising with third parties (e.g. dealers and brokers for the purposes of executing transactions).

· Identification data
· Contact data
· Financial data
· Services data
· Technical data
· Marketing and Communications data
· Professional Information data

· Performance of a contract
· Legal or regulatory obligation
· Legitimate interests: ensuring that you are provided with the best client services and visitor services we can offer, and securing a prompt payment of any fees, costs, and debts in respect of our services

To manage payments, fees and charges and to collect and recover money owed to us.

· Identification data
· Contact data
· Financial data
· Professional Information data
· Services data

· Performance of a contract
· Legitimate interests: ensuring we can manage payments, fees, and charges and collect and recover money owed to us.

To manage our relationship with you which will include notifying you about changes to our terms of business or this Privacy Policy.

· Identification data
· Contact data
· Marketing and Communications data
· Professional Information data

· Performance of a contract
· Legal or regulatory obligation
· Legitimate interests: ensuring we can notify you about changes to our terms of business or this notice.

To ensure the physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems).

· Identification data
· Contact data
· Profile data
· Technical data
· Communications data
· Professional Information data
· Security data

We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business premises, and assets (to the extent that such legitimate interest is not overridden by your interests or fundamental rights and freedoms).

To interact with governmental or regulatory bodies or other competent national authorities.

· Identification data
· Contact data
· Financial data
· Services data
· Professional Information data

· Legal or regulatory obligation
· Public interest

To detect, investigate or prevent fraud and/or other criminal activity and to protect our employees and assets.

· Identification data
. Security data
. Contact data
· Electronic Monitoring data
· Financial data
· Professional Information data
· Profile data
· Services data
· Technical data

· Legal or regulatory obligation
· Public interest
· Legitimate interests: protecting Sygnus Group and client assets; detecting, and protecting against breaches of our policies and applicable laws; protecting Sygnus Group employees

To conduct market or customer satisfaction research; engage with you for the purposes of obtaining your views on our products and services.

· Identification data
· Contact data
· Financial data
· Professional Information data
· Services data
· Personal data

· Legitimate interest: Understanding the use of our products or services or gathering information to help us to tailor or products and services; or

· Consent

To manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, data hosting, managing our offices and other facilities.

· Identification data
· Contact data
· Profile data
· Technical data
· Marketing and Communications data
· Professional Information data

· Legal or regulatory obligation
· Legitimate interests: ensuring the efficient and secure running of our business, including through office and facilities administration, maintaining information technology services, network and data security and fraud prevention

To invite you to take part in market insight or other events, or client seminars or similar events, and to manage your participation in them.

· Identification data
· Contact data
· Profile data
· Technical data
· Marketing and Communications data
· Professional Information data

· Consent
· Legitimate interests: ensuring our client records are up to date; promoting our client services; receiving feedback; improving our services; identifying ways to expand our business

To send you marketing (including by paper and electronic channels) communications and service updates.

· Identification data
· Contact data
· Profile data
· Technical data
· Marketing and Communications data
· Professional Information data

· Consent
· Legitimate interests: reviewing how clients use, and what they think of, our services; identifying ways to improve and expand our business

In relation to vendor services:

Purpose and/or activity

Type of data

Legal basis for processing

To engage you or the organization or entity you work for as a new supplier, including performing anti-money laundering, anti-terrorism, sanctions, fraud, and other background checks.

·Identification data
· Contact data
· Financial data
· Services data
· Professional Information data

. Performance of a contract
· Legal or regulatory obligation
· Legitimate interests: ensuring we do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities for example terrorism

To manage payments, fees, and charges and to collect and recover money owed to us.

· Identification data
· Contact data
· Financial data
· Professional Information data
· Services data

· Performance of a contract
· Legitimate interests: ensuring we can manage payments, fees, and charges; to collect and recover money owed to us

Where we provide you access to our systems we need to manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, and data hosting.

· Identification data
· Contact data
· Profile data
· Technical data

· Legal or regulatory obligation
· Legitimate interests: ensuring the efficient and secure running of our business, including maintaining information technology services, network, and data security

Information we disclose

In connection with one or more of the purposes outlined in the section ‘Purpose and Legal basis for processing your personal data above, we may disclose personal data in any jurisdiction to:

  • other members of the Sygnus Group in connection with the provision of products and services to you or;
  • professional advisors, third parties, agents, or independent contractors that provide services to any member of the Sygnus Group (such as IT systems providers, platform providers, financial advisors, brokers, consultants (including lawyers and accountants);
  • goods and services providers (such as providers of marketing services where we are permitted to disclose your personal information to them); intermediaries, brokers, and other individuals and entities that partner with us;
  • competent authorities (including any national and/or international regulatory or enforcement body, agency, court or other form of tribunal or tax authority) or their agents where Sygnus Group is required or allowed to do so under applicable law or regulation;
  • a potential buyer, transferee, merger partner, or seller and their advisers in connection with an actual or potential transfer or merger of part or all of Sygnus Group’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it;
  • credit reference agencies or other organizations that help us to conduct anti-money laundering and anti-terrorist financing checks and to detect fraud and other potential criminal activity; or
  • any person to whom disclosure is allowed or required by law, regulation, or Order of a Court.

International transfers and transfers to service providers

We may transfer personal data to a location outside of the country where you reside or where services are provided to you or the organization or entity you work for, if we do so, we will apply the same level of security and organizational controls to the processing of personal data wherever it is processed. We require by contract that our third-party service providers who may process personal data on our behalf to comply with Sygnus Group’s criteria for personal data processing and protection.

Where we transfer your personal data to other countries, we do so based on:

  • adequacy decisions;
  • our Binding Corporate Rules;
  • suitable Standard Contractual Clauses; or
  • other valid transfer mechanisms.

Marketing and exercising your right to unsubscribe from marketing

We will not process your personal data for marketing purposes without your consent if you have informed us that you do not wish to receive marketing materials. If consent is given, we may process your personal data to contact you, primarily by mail and email and also on occasion by telephone, so that we can provide you with information concerning products and services that may be of interest.

If you do not wish to receive marketing communications from us you can opt-out at any time by electronically unsubscribing from emails we have sent to you, by making a request to your usual Sygnus Group contact, or by using the contact details set out in the “Contacting Us” section of this Privacy Policy. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

Third-party marketing/sale of personal data

We do not share or sell your personal data to third parties for the third party to use for their own marketing or other purposes.

Personal Data Retention

We will process your personal data for as long as is necessary to fulfill the purpose for which it was collected or comply with legal, regulatory, accounting, reporting, and internal policy requirements or for the establishment or defense to legal claims.

Data security

We have implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law. We specifically use a range of physical, electronic, and managerial measures to ensure a level of security appropriate to the risk of personal data processing. These measures include:

  • education and training of relevant staff to ensure they are aware of our privacy obligations when collecting and processing personal data;
  • the ability to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
  • the ability to restore the availability and access to personal data promptly in the event of a physical or technical incident;
  • administrative and technical controls to restrict access to personal data;
  • technological security measures, including fire walls, encryption (industry standard SSL encryption with 128-bit key lengths), and anti-virus software;
  • external technical assessments, security audits and vendor due diligence;
  • physical and perimeter security measures, including building access controls, intrusion prevention and detection systems and security camera systems;
  • segregation of networks;
  • application security;
  • endpoint security; and
  • security incident reporting and management.

The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries the risk of access and interception. You should not send us any personal data by open/unsecured channels over the internet. You are responsible for ensuring that any personal data you send to us are sent securely. We endeavour to protect personal information but cannot guarantee the security of data transmitted to us or by us.

Data Subject Rights

In certain circumstances you may have the following rights in relation to the processing of your personal data:

  • Access: To request a copy of the personal data we process in relation to you (including in electronic form) and to be informed about how we use and share your personal data.
  • Object: To object to the processing of your personal data if (i) we are processing your personal data on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling), or (ii) if we are processing your personal data for direct marketing purposes
  • Rectification of Inaccuracies: To request that we update the personal data we process in relation to you, or to correct personal data that you think is incorrect or incomplete.
  • Erasure: To ask that we delete personal data that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.
  • Restriction: To request that we restrict the way in which we process your personal data, for example, if you dispute the accuracy of your personal data or have raised an objection that is under consideration.
  • Automated decision making: To request that we ensure that no decision is based solely on automated processing if you will be significantly affected.
  • Direct Marketing: To request that we do not process your personal data to engage in direct marketing without your explicit consent to do so.
  • Complaints: To lodge complaints to the relevant Data Protection Authority regarding the processing of your personal data by us or on our behalf.

You may exercise your rights at any time by using the details set out in the Contacting us section. To the extent permitted by applicable law or regulation, we reserve the right to charge an appropriate fee in connection with you exercising your rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access to the personal data requested or to exercise any of your other rights. This is to ensure that personal data is not disclosed to any person who does not have the authority to receive it. We may also request further information in relation to your request to help us to locate the personal data processed in relation to you, including, for example, the nature and location of your relationship with us.

We will respond to all legitimate requests in accordance with applicable law.

Contacting us

If you wish to exercise any of your rights, have any comments, questions, or concerns about any of the information in this Policy, or any other issues relating to the processing of personal data by the Sygnus Group, please contact your Sygnus Group client service specialist, or:

The Sygnus Group
Unit 28, 80 LMR,
80 Lady Musgrave Road
Email: privacy@sygnusgroup.com

If you would like to contact the Sygnus Group Data Protection Officer, please send an email to:

Email: dpo@sygnusgroup.com

Cookies

We use “cookies” on this website. Cookies allow us to store information about the computer device you use to access our website so that you can conduct business with us easily. They allow us to recognise when you revisit the website. Cookies can also enable us to track and target the interests of our users to enhance the experience on our website. Usage of a cookie is in no way linked to any personally identifiable information on our website. You may modify your browser so that it will not accept cookies. To enable or disable cookies, follow the instructions provided by your browser. However, please note that should you choose to set your browser to disable cookies, you may not be able to access secure areas of our website, for example, any online accounts you may hold with us or through any of our service providers.

Linked websites

This Privacy Policy is not applicable to third-party websites that we do not own or control, or to any third-party website where Sygnus Group advertisements are displayed.

What you can do

For your protection, you should not provide your account information, username, or password to anyone. If you become aware of any suspicious activity relating to your account, it is your responsibility to contact us immediately.

Changes to this Privacy Policy

This Privacy Policy may be modified or amended this Privacy Policy from time to time and you are advised to visit our website regularly to check for any amendments. From time to time, we may change the content or services found on our website without notice, and consequently, our Privacy Policy may change at any time in the future. Your continued access to or use of our website after any change will mean that you agree to the policy that applies when you use www.sygnusgroup.com or any affiliated Sygnus Group company domains.

Effective Date

This policy was made effective September 19, 2022