We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from May 25th, 2018.
- What data do we collect and process on this website?
We may collect and process the following data about you:
- Details of your visits to this site for traffic overview. No personal data is tracked, stored or collected. This information is collected in line with our Cookies Policy.
- Information that you provide by filling in forms on this site. This includes information provided when subscribing to our newsletter, when inquiring for information or subscription details, and when filling in your details in the Contact Page.
- Information that you provide when you communicate with us by any means.
- Why do we collect this data?
We may use your personal information for the following purposes:
- We may use personal information collected about you from any applications or forms you may complete for the purposes of establishing a client relationship with you.
- We may also use the information we collect in order to inform you about changes to this website.
- We may also use the information to respond to your inquiries or comments submitted through the website.
- Your information may be used for legal and regulatory compliance purposes, including as necessary: to respond to governmental or regulatory entities requests; to comply with our legal obligations under current Anti-Money Laundering Laws and Regulations and current local and international tax Laws including the Common Reporting Standards and the Foreign Account Tax Compliance Act in relation to the exchange and automatic forwarding of tax related information; to ensure the continuing security and integrity of our systems, business dealings, reputation or the security and reputation of FMG Funds and its staff; to identify misuse of our systems and any fraud or other illegal or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations.
- We may also use the information as may otherwise be necessary for responsible corporate governance or as otherwise required or permitted by applicable laws and/or regulations.
- Data retention
Personal data will be retained for as long as it is necessary for the purposes set out above and in accordance with our legal and regulatory obligations.
- Where we store your personal data
We will not transfer or store your personal data outside the EU.
- Disclosure of Information
The data that we collect from you may be transferred to and stored in the USA by third party service providers. Such transfers are covered by the EU-U.S. and the Swiss-U.S. Privacy Shield Certification Framework which ensures a lawful transfer of personal data overseas. We shall enter into contracts with such third parties which require them to handle your personal data in a manner which is consistent with applicable data protection laws and regulations.
We may disclose your personal data to internal or external service providers for operational and compliance purposes, for example, if it is necessary to provide you with something which you have requested (e.g. newsletter subscription) then we may share your personal information with a service provider for that purpose. These service providers include:
- Email Newsletter Platforms; We use MailChimp as Email Newsletter Platforms; and
- IT Service Providers
We shall enter into contracts which such third parties which require them to use personal information only for the provision of such services to us and in a manner that is consistent with applicable data protection laws and regulations.
We may also transfer your data if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Third Party Links
We are committed to ensuring that your information is secure. We have implemented measures and procedures to prevent unauthorized access or disclosure. Likewise, we seek to keep confidential all information you send to us.
- What are your rights?
Right of Access to Information – you have the right to request confirmation from us whether personal data relating to you is being processed and if so to access such personal data.
Right to Rectification – you have the right to request from us the rectification, without delay, of any inaccurate personal data pertaining to you.
Right to Be Forgotten – you have the right to request from us the erasure of all personal data pertaining to you without delay, where the data has been processed with your consent as the basis for processing and/or where the processing is no longer lawful.
Right to Restrict Processing – you have the right to request from us the restriction of processing if: processing is unlawful; you are contesting the accuracy of data; the data is no longer required by the controller but you require us to keep it in order to establish, exercise, or defend a legal claim; or if you have previously objected to the processing. Once data is restricted, we cannot process it in any way other than to store it unless: we have your consent; or if it is required for the establishment, exercise, or defence of legal claims; or if it is for the protection of the rights of other persons; or if it is for reasons of important public interest.
Right to Data Portability – you have the right to receive from us personal data which you have provided to us and to transmit that data to another controller without hindrance from us. This right applies where the data is being processed with your consent, or for the performance of a contract, and when processing is carried out by automated means.
Right to Object – you have the right to object at any time to the processing of personal data pertaining to you where the processing is based: on our legitimate interest; or the performance of a task in the public interest/exercise of official authority; or on direct marketing (including profiling); or on processing for purposes of scientific/historical research and statistics.
You also have the right to object to profiling based on our legitimate interests or on the performance of a task in the public interest/exercise of official authority.
You also have the right to object to automated decision making, including profiling, and therefore to not be subject to a decision which is based solely on automated processing, including profiling, which produces legal effects or significantly affects you.
Any requests or objections are to be made in writing by mail or email to our Data Protection Representative.