Privacy Policy

Introduction

This is a privacy policy of Signet Capital Management Limited (“Signet” or “the Firm”), a company registered in England and Wales with a company number 04644944. Signet is authorised and regulated by the Financial Conduct Authority (“FCA”) with firm reference 222755.

Your privacy is very important to us and Signet is committed to ensuring that your personal information is used in accordance with the current data protection.

This privacy notice sets out the basis on which personal data about you will be processed by Signet. Please take the time to read and understand this privacy notice which sets out our policies with respect to the collection, sharing and use of personal information.

How is your data collected?

We may collect personal data about you through:

  • information provided directly to us by you, or another person on your behalf, through our website, by email or post, or in person;
  • information that we obtain in relation to any transactions between you and us;
  • recording and monitoring of telephone conversations and electronic communications with you as described below.

We also may receive your personal information from third parties, such as service providers, fund administrators, your advisors, regulatory or law enforcement agencies and credit reference agencies and from publicly or privately available records.

What personal data do we collect and why?

In order for Signet to provide services to its clients, run its business and discharge regulatory and legal obligations it needs to process personal data of its clients and other third parties. Without processing this personal data, we may not be in a position to provide our services and administer the business.

The personal data we need to collect will depend on the service(s) that we provide to you and the purpose of which information is being collected.

In general Signet commonly collects:

  • Photographic ID & documents to verify both your identity and residential address in order to satisfy anti-money laundering regulations; failure to provide these may mean that we are unable to establish or continue in a business relationship with you or an entity connected to you.
  • Your contact details, including but not limited to, telephone numbers, address and email address in order to communicate with you.
  • We may conduct criminal background checks as part of our anti-money laundering screening process to comply with anti-money laundering legislation at or around the time we take on a client and periodically thereafter.
  • We may also collect proof of age and location, in order to ensure that we may legally provide you with the relevant product or service.
  • Where, as part of our services to you, we are remitting funds we will take your bank details.
  • Where we collect additional personal data, you will be informed of that at the time we collect it, together with the reasons why.
  • Where we later process your personal data for reasons not already communicated to you, we will notify you in advance.

How do we use your personal information?

We process personal data primarily for the purpose of providing a contracted service(s) to you or an entity to which you are connected (or, where you provide a service to Signet we will process contact details of your representatives, agents or employees in order to communicate with you/them) but in addition to this we may use your information for the following purposes:

  • To meet a legal or regulatory requirement;
  • To communicate with you regarding the services we provide to you (for example any changes);
  • To advise you of changes that may affect you that we feel are in your best interests;
  • For reasonable administrative and accounting purposes in the normal course of managing our business;
  • If we believe that we have a legitimate interest or;
  • We believe that you have a legitimate interest and to not use your personal data could have a negative impact on you;
  • Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in your subscription in the applicable Fund being rejected or compulsorily redeemed or withdrawn, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority;
  • For marketing purposes, we will contact you by email, telephone or post with regard to your activities with us. Signet has a monthly fund reports which we circulate by email. You may unsubscribe from this at any time by writing to reporting@signetmnagement.com. In such case, Signet will continue to contact you in regard to your account but unsubscribe you from marketing communications.

Do we use automated decision-making processes?

No

How long do we retain your data?

We will not retain personal data for longer than necessary in relation to the purpose for which it is collect, or such longer period if required under applicable law or necessary for the purposes of our legitimate interests.

The applicable retention period will depend on various factors, such as regulatory requirements which requires us to keep information about you for a longer period as well as a legal obligation to which our service providers are subject as well. Personal data will be retained for the entire duration of any business relationship we may have with you, for a minimum period of five years after the termination of such relationship. We will securely delete your personal data once it is no longer required for the processing purposes for which you consented.

From time to time, we will review the purpose for which we have collected information about you and decide whether to retain or delete it if the information is no longer required.

We have strict security and confidentiality procedures covering the storage and disclosure of your personal information in order to safeguard it, prevent unauthorised access and to comply with data protection laws.

Recording & monitoring of communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of:

  • ensuring compliance with our regulatory obligations; and/or
  • detecting and preventing the commission of financial crime.

Transfer of personal information to countries outside the European Economic Area (EEA)

Due to the international nature of our fund management business, personal data may be transferred to countries outside the EEA (“Third Countries”), such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the Data Protection Law in the EEA. In such cases, we will take steps to ensure that the recipient agrees to keep your information confidential and that it securely held in the Third Countries in accordance with the requirements of the Data Protection Law, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries.

Who do we share your information with?

We may (to the extent relevant to the purpose for which we collect your information), disclose information about you with third parties such as:

  • our affiliates or other entities that are part of our group;
  • any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
  • service providers including our fund administrators, prime and executing brokers, custodians, depositories and banks;
  • any person, as directed by you;
  • IT service providers including accountants and legal advisors; or
  • any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

What are your rights in relation to our use of your information?

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

  • request access to your personal information that we hold on you;
  • update or amend your information if it is inaccurate or incomplete;
  • object to certain uses of your personal data such as where is have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
  • request the erasure of your information;
  • to restrict the processing of your information in certain circumstances;
  • withdraw any consents you have provided in respect of our use of your information;
  • where the legal basis for processing is consent or that it is necessary for the performance of a contract with you, the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller; and
  • lodge a complaint with the Information Commissioner’s Office (https://www.ico.org.uk/global/contact-us/email/) if you are not happy with the way that we manage or process personal data.

If you would like to exercise any of these rights please contact compliance@signetmanagement.com.

Changes to this Privacy Policy

We will place any update to this privacy policy on this page of our website.

How to contact us

If you have any questions or concerns about personal data or this privacy policy or you wish to make a complaint about how we have processed your personal data, you may contact our Compliance Officer by email at compliance@signetmanagement.com or by writing to 1st Floor, 11-12 Pall Mall, London, SW1Y 5LU, United Kingdom

For more specific information or requests in relation to the processing of personal data by fund administrators, prime brokers and custodians or any other service providers of the Funds, you may also contact the relevant service provider directly at the address specified in the Directory section of the relevant Memorandums or by visiting their website.