March 29, 2020

Privacy Policy

We maintain strict security standards, policies and procedures for the prevention of unauthorized access to Personal Information. We require our directors, officers and employees and third parties we share Personal Information with in connection with our Service to observe and comply with this policy and the applicable laws and regulations in connection with this policy.

We collect personal information about you from a variety of sources, including from you directly (e.g. when you contact us or complete a form), information we generate about you in the course of our relationship with you (e.g. data collected from cookies and other similar technologies which is described in our Cookie Policy, and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law).

Information you provide to us:

  • personal details (e.g. name, professional title)
  • contact details (e.g. phone number, email address, postal address, mobile number, country location
  • account details (e.g. user name and password)
  • professional information (e.g. company name, industry sector, type of business)
  • We may collect, hold, use, disclose and process your Personal Information from you for any of the following purposes, as applicable:
  • ensuring the material on this website is presented to you in an effective manner;
  • providing you with alerts, bulletins, newsletters and other information which you have requested or signed up to;
  • taking steps to enter and entering into any business agreement between you and us;
  • performing obligations under any business agreement between you and us;
  • providing you with and improving our Service;
  • to the extent permitted by law and regulation and subject to your preferred mode(s) of contact, informing you about any investment opportunities with or alongside us, ensuring the protection of your vital interests;
  • complying with any laws and regulations applicable to us;
  • for our or a third party’s legitimate interests and where your interests do not override such legitimate interests;
  • in connection with any legal or regulatory proceedings or investigations; and
  • any other legitimate business purposes ancillary to the above or which you have specifically consented to. 

Due to legal and regulatory obligations applicable to us, you may be required to provide us with your Personal Information or Personal Information of your legal and beneficial owners, directors, officers, employees and agents, failing which may prevent us from dealing or entering into a business agreement with you.

If you have given us consent to inform you of any investment opportunities with or alongside us and would like to withdraw such consent, please send us a written request at the contact mentioned at the end of this policy. If you have not, or are unsure if you have, given us such consent and would like to give such consent, please send us a written request at the contact mentioned at the end of this policy with your explicit consent. 

Where a right of objection is available under the applicable laws and regulations, you have a right to object to us processing your Personal Information where such processing is done for our legitimate interests or direct marketing, as applicable.

Personal Information Disclosure and Transfer

Except as specified below, we do not disclose to any other person your Personal Information, unless we have received your permission to do so.  We may disclose and transfer Personal Information to any of us and any third party anywhere in the world:

if we consider it necessary for our business purposes, including without limitation, to enter into a business agreement with you, to facilitate the review, acceptance, administration and management of your investment with or alongside us, to perform our Service on our behalf and, to the extent permitted under the applicable laws and regulations, provide marketing services on our behalf; and/or facilitate the compliance with or comply with any law, regulation, judgment, order, requirement, guideline, code, standard, policy, circular, notice or any other document of a similar nature issued by any legal, regulatory, statutory, listing, supervisory, law enforcement, prosecuting, tax or any other authority or body of a similar nature in any jurisdiction.


Such third parties may include, without limitation:

  • our officers, directors and employees;
  • our banks, securities brokers, auditors, attorneys and other service providers;
  • our business partners and counterparties;
  • persons to whom we are required to make disclosure under applicable laws and regulations; and
  • actual or prospective transferees or participants of our Service.

Your Rights in relation to Personal Information
You may have a right to access your Personal Information held by us, a right to amend and/or rectify any inaccuracies in your Personal Information held by us, a right to erase the Personal Information held by us, a right to cease processing or a right to obtain your Personal Information in a structured, commonly used and machine-readable format, by writing to us with your request. You may also have the right to lodge a complaint with a national data protection authority. These rights are subject to availability, exceptions and conditions under the applicable laws and regulations. 
If you wish to exercise your rights or have any queries on your Personal Information held by us, please send us a written request at the contact mentioned at the end of this policy.

Personal Information Security
We are committed to the safety and security of your Personal Information. We use a world class cloud information storage system.
We employ appropriate physical, electronic and procedural safeguards to ensure your Personal Information remains confidential and secure under our control or in our possession.
We restrict access to your Personal Information to the relevant and required parties on a need-to-know basis for the purposes specified above.Where required by applicable data protection laws, we will notify you of any data breach incidents.

Definitions

Capitalized terms in this Policy have the meaning given to them below:

“Personal Information” means any information relating to your identity, or the identity of another person, which could be used to directly or indirectly identify you or such person, which you, or another person on your behalf, provides to us. Such information includes, without limitation, names, addresses, dates of birth, identification numbers, telephone numbers, nationalities, tax residencies, assets, incomes, bank account details, details of regulatory registrations, details of legal and/or regulatory actions and any other information by which you or such person may be personally identified.

“Service” means any advisory, asset management and/or other service(s) provided by us to you.

“We” means any entity advised or managed by or affiliated with Nabsons Management Consultants Inc. and any of its delegates and agents, including without limitation, Nabsons Management Consultants Inc., and their respective delegates and agents, and the phrases “us” and “our” have corresponding meanings.

“You” means any person accessing our website, including without limitation, in its capacity as our actual or potential investor, customer or user, and the phrase “your” has a corresponding meaning.