In accordance with this Policy, Albourne may collect, use and process your personal data (including your sensitive personal data), together with other information, for the uses set out below. For the purposes of this policy “processing”, “transferring” “personal data” and “sensitive personal data” shall be interpreted in accordance with the UK Data Protection Act 1998.
Collection of information
Information may be collected from you in the course of your use of an Albourne website and/or in any communication between you and Albourne personnel. If you are an Albourne client, prospective Albourne client or a fund manager we may also collect information about you from company and trade registers, and other publicly available sources.
Sensitive personal data
To the extent we have a business need to collect your sensitive personal data for the purposes set out above, and are permitted to do so by local laws, we may collect and use your sensitive personal data. If we do so, and are required by local laws, we will contact you to obtain your consent for this collection and use in advance.
Uses of personal data
Albourne may use your personal data for any of the following purposes:
- In the course of carrying out client due diligence and achieving a sufficient knowledge and understanding of a prospect or client and its business, management and employees.
- In the course of carrying out fund manager due diligence and achieving a sufficient knowledge and understanding of a fund manager and its business, management and employees.
- To provide investment advisory, due diligence and risk advisory services to its clients.
- To prevent fraud.
- To check the identity of prospects and new clients and to prevent money laundering.
- To disclose it to its service providers, professional advisers and agents, where necessary.
- If you have registered for this purpose, to review whether you are a suitable candidate for any job opportunities within Albourne.
- Occasionally, to trace debtors.
- To record and monitor for internal Albourne purposes your use of Albourne websites. For internal administrative or training purposes.
- For responding to subpoenas, court orders or regulatory or legal requirements.
- For the marketing of Albourne’s investment advisory services. See more details below.
Please note that we use session cookies where necessary to keep you logged into an Albourne website for the duration of the session, and these cookies are deleted when you close the web browser.
Albourne may contact you by mail, telephone, fax, e-mail or other electronic messaging service with offers of Albourne’s services, materials, news or training that may be of interest to you. Options to opt-in or opt-out of such communication are offered to you when you register with an Albourne website. By opting-in and providing Albourne with your contact details, you consent to being contacted by those means for those purposes. If you do not wish to receive such information from Albourne, or you have changed your mind, please click visit the Site Preferences page to change your privacy settings. Albourne will never pass your contact details on to a third party.
Albourne operates as a global business and may have a business need to transfer your personal data to countries outside the European Economic Area (EEA) which do not provide the same level of data protection as the EEA. This includes transfers the object of which is (i) to enable information to be accessed by Albourne personnel located outside the EEA who need to know the information in order to do their jobs; and/or (ii) to enable information to be accessed by Albourne clients located outside the EEA. We have put terms in place to ensure that your information is adequately protected and your privacy respected in the case of such a transfer.
Monitoring of communications
To ensure that Albourne follows your instructions correctly and to improve our service through training of its staff, Albourne may monitor any communication between you and Albourne.
How We protect your Personal Information
People. We educate our employees to treat personal information and personal data with care. They are required to limit their access to information that they need to perform their jobs, such as to conduct our business, operate our websites, service your account or help you pursue your financial objectives. All our employees are required by contract and Albourne’s policies to keep all personal information secret, confidential and secure, and must take particular care not to disclose it to any other person (whether inside or outside Albourne) unless there is a legitimate Albourne business need and they are authorised to do so.
Procedures. In compliance with applicable laws and regulations, we maintain physical, electronic and procedural safeguards to protect your personal information. In addition, we have put in place Data Transfer Agreements (based on approved EEA model clauses) between those Albourne companies located in the EEA and those located outside the EEA to govern the transfer of data outside the EEA. These terms ensure that personal data and information is adequately protected within Albourne and that individuals’ privacy is respected.
Security. We take such security measures as we deem appropriate and proportionate to keep all information (including personal data) confidential and secure against unlawful processing and to prevent loss, destruction or damage.
Amendments and queries
If your personal details change please amend them by editing your details within the website, or contact email@example.com.
If you have any questions about how Albourne uses your personal information, please email firstname.lastname@example.org.
Singapore Individuals – for the purpose of Personal Data Protection Act in Singapore, please contact Debra Ng at +65 6536 9541.
Under local laws, you may be entitled to ask for a copy of your personal data (for which we may charge a small fee) and to correct any inaccuracies. Please also address any such requests to email@example.com.