Investment Manager Privacy Notice

Aurum may collect and process the personal data of natural persons who are directors, officers, partners, shareholders, employees, agents, trustees, consultants, contractors and/or service providers of funds (the “Funds”), managers of Funds or investment managers of Funds in which an Aurum Fund is invested, or is considering an investment (“Individuals”) and other information relating to the dealings of Individuals with Aurum and/or its service providers. This Privacy Notice explains how Aurum will manage the personal data of such Individuals, why Aurum uses it and how Individuals may contact Aurum in relation to the use of personal data.

Aurum comprises the Aurum group, which includes Aurum Fund Management Ltd. located at Aurum House, 35 Richmond Road, Hamilton HM 08, Bermuda, Aurum Research Limited located at 37 Ixworth Place, London SW3 3QH, Aurum Funds Limited located at 37 Ixworth Place, London SW3 3QH, Aurum Funds Management (Pty) Limited located at Unit 20 & 21, Second Floor, 1 Melrose Boulevard, Melrose Arch, South Africa and the various Aurum Funds. An Aurum Fund is any collective investment scheme managed or advised directly or indirectly by Aurum (the “Aurum Funds”).

Personal data means any information which Aurum has or obtains, or which an Individual provides to Aurum or its service providers, from which that Individual can be directly or indirectly personally identified such as his/her name, address, email address, date of birth, signature, nationality, place of birth, credit history, source of wealth, country of residence, education, work history and experience, areas of expertise, qualification details and contact details and may include information such as identification and account numbers, tax identifiers and residency information, and online identifiers.

We may also collect and process personal data of Individuals from other sources as part of Aurum’s usual due diligence processes which may include information from referees and intermediaries.

Such personal data will be held in confidence and processed in accordance with relevant data protection legislation or regulation, and with effect from the 25th of May 2018, insofar as relevant, the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016) (GDPR), including any amendments thereto.

Uses of your personal data

Your personal data may be stored and processed by us in the following ways and for the following purposes:

to effectively and efficiently administer and manage the operation of our business;
management of risk;
to enable communication between us and yourselves;
to facilitate the investment, redemption and allocation of investments;
fund management;
for analytical purposes, to contribute to informed decision-making.

We are entitled to use your personal data in these ways because:

we need to in order to perform our obligations and exercise our rights in connection with a contract with us; or
we have legal and regulatory obligations that we have to discharge; or
we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
the use of your personal data as described may be necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates or that of one of the Aurum Funds), such as:
- undertaking initial and ongoing due diligence and monitoring of Funds, where an Aurum Fund is invested or in which it is proposing to invest in; or
- maintaining compliance with internal policies and procedures; or
- the effective administration of the Aurum Funds; or
- the prevention of fraud or financial crime; or
- statistical mapping to attribute relative performance.

Disclosure of your information to third parties

We may disclose your personal data to our affiliates and to the Aurum Funds for the purposes of:

the management and administration of our business, our affiliates’ business and the business of the Aurum Funds;
complying with the functions that each of them may perform relating to regional or global investment decisions;
assessing compliance with applicable laws, rules and regulations, and internal policies and procedures across our business and our affiliates’ businesses;
where your personal data is held as part of an internal directory, enabling adequate communication with you;
the administration and maintenance of databases which store personal data relating to you;
reporting to the Aurum Funds on their current or proposed investments in the Funds.

We will take steps to ensure that the personal data is accessed only by staff of our affiliates and those of the Aurum Funds that have a need to do so for the purposes described in this notice.

We may also share your personal data with third parties outside our corporate group for the following purposes:

if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
to third party agents and contractors for the purposes of providing services to us, including, IT and communications providers, law firms, accountants and auditors. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice; and
to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights.

Transfers of personal data outside the European Economic Area

The disclosure of personal information between Aurum and third parties as set out above may involve the transfer of personal data to foreign jurisdictions that do not impose the same level of data protection as that to which the relevant Aurum entities are subject. Any such transfers will only be made where permitted by law and, in all cases, where Aurum is able to ensure appropriate data protection mechanisms are in place.

What about personal data about other people that you provide to us?

If you provide personal data to us about someone else (such as one of your co-workers or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Investment Manager Privacy Notice.

In particular, you must ensure the individual concerned is aware of the various matters detailed in this Investment Manager Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices (including disclosure to overseas recipients), the individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided (such as our inability to provide services).

Keeping personal data up to date

We will use reasonable efforts to keep your personal data up to date and free from error. However, you will need to notify us without delay in the event of any change in your personal circumstances, or of any erroneous data so that we can keep the personal data up to date.

Sensitive data

We may collect and process sensitive personal data in connection with our obligations to you. Any sensitive personal data will only be used and disclosed, as necessary, for specified purposes.

Retention Period

Aurum is obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal, regulatory, fraud prevention and legitimate business purposes.

Other information will be retained for no longer than is necessary for the purpose for which it was obtained by Aurum or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes. In general, Aurum (or its service providers on its behalf) will hold this information for a period of seven years from the termination of the relevant business relationship, unless it is obliged to hold it for a longer period under law or applicable regulations.

Data Subject Rights

You have the following rights, in certain circumstances, in relation to your personal information: the right to access your personal information, the right to rectify your personal information, the right to restrict the use of your personal information, the right to request that your personal information be erased, the right to object to processing of your personal information, the right to data portability and the right to lodge a complaint with a supervisory authority.

Contacting Us

Any queries or complaints regarding the use of the personal data by Aurum and/or the exercising of individual rights should be either emailed to data.privacy@aurum.com or a letter sent to Aurum House, 35 Richmond Road, Hamilton HM 08, Bermuda or to 37 Ixworth Place, London SW3 3QH, in each case for the attention of the Compliance Officer.