PRIVACY STATEMENT

 

This statement describes how Adamas Asset Management group and its affiliates (“we”) processes your personal data.

‘Personal data’ means any information relating to an identified or identifiable individual. It includes, for example, your name, your contact information, your date of birth, details from your passport, photographic or video images, communication records and, within the context of providing our services to you, any information we may be legally required to obtain from you in the context of our customer due diligence.

We treat your personal data with care and in accordance with the applicable legislation, including the EU General Data Protection Regulation (GDPR). Keeping personal data secure is one of our most important responsibilities. We maintain physical, technical, electronic, procedural and organizational safeguards and security measures to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure or access. Our employees are bound by internal policies that require confidential treatment of personal data.

 

Use of our website

When you use our website, various data is registered. For example, the type of connection, the browser used, your computer's operating system, your IP address and, when relevant, the details filled out on contact or other forms.

 

Processing of personal data

The paragraphs below describe the processing of personal data by us, other than through the use of our website.

We process data of private and institutional clients and potential clients, including personal data of contact persons, employees, directors, representatives, shareholders, ultimate beneficial owners and other associated persons (“Investors”, or, within this paragraph, “you”).

We may process your personal details, such as your name, gender, (business) contact details, title or position, and any other information you have provided to us during our conversations, meetings, by e-mail or by any other means. We store this information in a contact management system and e-mails received are stored in personal or shared e-mail boxes. We process this data to maintain contact with you, to provide you with our services, to maintain and optimize the quality of our services and our relationship with you, to provide you with relevant information about your investment(s), to provide you with updates and newsletters about us and our services, to provide you with any other information that may be of interest to you and to verify any agreements made with you.

Pursuant to anti-money laundering and counter terrorist financing legislation as well as know-your-customer legislation applicable to us, we have to conduct customer due diligence before we provide our services to Investors and periodically afterwards during our relationship with Investors. We collect data from our Investors directly, indirectly, or through a world-check database, sanction lists, or publicly accessible sources. Failure to provide certain requested data may result in the impossibility to invest or stay invested with us.

Information gathered in context of our customer due diligence include personal data, such as your full name, place and date of birth, a copy of your passport, information about your regulatory listings, information about investigations or sanctions you are or may have been subject to and information in relation to the source of wealth of Investors. Personal data may also be included in promotional material, certificates, any other know-your-customer and anti-money laundering related information we need to obtain from you and in documents we process for the purpose of recording and verifying our agreements with Investors, such as authorized signatories lists, contracts and related documents.

We process your data because this is necessary for compliance with legal obligations to which we are subject, or with our legitimate interest, each as described above. When we provide you with newsletters and updates, this may be based on your consent. You have the right to withdraw your consent and you can unsubscribe from our mailing list at any time.

We will store your personal data as long as relevant within the context of our relationship. Personal data gathered pursuant to our customer due diligence will be kept on file for at least six years after termination of our relationship. Personal data contained in contracts and related documents will be kept on file as long as necessary to exercise or defend actual or potential legal claims. Any data may be archived or backed up.

 

Recording of communications

We may record communications, including telephone conversations or communications by any other means. We record several of our telephone lines, including those of our traders and our Investor Relations team. We do this to comply with a legal obligation. Pursuant to applicable regulation, we have to record communication that, among others, result in transactions. Communications may also be recorded with the legitimate interest for record keeping as proof of a transaction or related communication in the event of a disagreement, for verification of agreements or instructions, and for investigation and fraud prevention purposes.

Communication records will be retained for a period of seven years from the date of the recording. Communication records other than telephone recordings may be archived or backed up.

 

Transfers to third parties

In addition to what is described above in relation to specific data transfers, we may also share data with our affiliates, professional advisors and auditors to the extent required. Any such party will be subject to obligations of confidentiality. Where possible and appropriate, any personal data transferred will be anonymized.

We may also have to transfer data to any court, governmental or supervisory authorities, at the (authorized) request of a regulator, when this may be required pursuant to applicable regulations or pursuant to any court order. Should this be the case, we will use reasonable endeavors to notify you in advance of such transfer, to the extent we are allowed to do so.

We may need to transfer personal data to parties that are located in countries outside of the European Economic Area (EEA) that are not recognized to provide an adequate level of data protection according to EEA standards. We will adopt safeguards to ensure an appropriate level of protection of your personal data. In particular, we may transfer personal data to affiliates with offices around the world.

 

Requests related to personal data

You can contact us if you have any of the following requests:

  • Access to your personal data: if you wish, we can provide you with an overview of your personal data processed by us.
  • Rectification: you can request us to rectify any inaccurate personal data.
  • Erasure: you can request us to erase any personal data that we hold of you.
  • Restriction of processing: in certain circumstances, you may request us to restrict the processing of your personal data.
  • Data portability: in certain circumstances, you can request us to provide you, in a structured, commonly used and machine-readable format, with the personal data that you provided to us earlier. You can request us to transmit this data to another party.

 

Contact

If you have any questions about this privacy statement, please contact us as at info@adamasam.com or + 852 3793 6200.