Swiftsure Partners Limited - Website Disclaimer

The contents of this document are communicated by, and the property of, Swiftsure Partners Limited.

Products and Services

The information contained herein is current at the date of publication, but is subject to change without notice. Swiftsure Partners Limited has expressed its own views and opinions on this website, and these may change without notice. This website is not directed at you if Swiftsure Partners Limited is prohibited by any law of any jurisdiction from making the information on this site available to you and is not intended for any use that would be contrary to local law or regulation. None of the information contained on this website is intended to constitute any offer to sell or an invitation or solicitation of an offer to buy any product or service by Swiftsure Partners Limited and must not be relied upon in connection with any investment decision. Products or services mentioned on this site are subject to legal and regulatory requirements in applicable jurisdictions and may not be available in all jurisdictions. Accordingly persons are required to inform themselves of and observe any such restrictions. Nothing in this website should be construed as investment, tax, legal or other advice.

Risk Warning

Past performance is not necessarily a guide to future performance. The value of investments and the income of any financial instruments mentioned in the website may fall as well as rise, and investors may get back less than the amount originally invested. Fluctuations in exchange rates may have a positive or an adverse effect on the value of foreign-currency denominated securities and financial instruments. Certain investments involve an above-average degree of risk and should be seen as long-term in nature. The investment products and services described in the website may have tax consequences. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. You acknowledge that levels and bases of taxation may change, and that Swiftsure Partners Limited does not provides tax advice. You should consult your own tax advisor in order to understand the tax consequences of the products and services described in the website.

Disclaimer

I certify that I am not a US person. Swiftsure Partners Limited is not registered as an investment advisor with the SEC and therefore this document is neither directed at nor intended for US investors.

 

Privacy Notice

This notice describes how Swiftsure Partners Limited(“Swiftsure”) uses personal data. It outlines Swiftsure’s data protection obligations and your data protection rights under the regime introduced by the EU General Data Protection (Regulation 2016/679, the "General Data Protection Regulation").

The GDPR applies to “personal data” meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

Swiftsure needs to use your personal data to provide its services to you, so this notice outlines the following points about the processing of your personal data:

  • which data items are used, how they are used and who they are shared with;
  • why this is done and the lawful basis;
  • your rights and Swiftsure’s obligations.

Why Swiftsure needs to process personal data

Your Data are collected to effectively and properly manage your account(s) with us. Data is stored for specific purposes and only data that is relevant to that purpose will be stored. We will use the Data for several different purposes, including;

  1. to provide you with information that you request from us (including through our website) or which we feel may interest you, where you have consented to be contacted for such purposes; and,
  2. to notify you about changes to our products and services.

If at any time you wish to be removed from marketing mailing lists or for any limits to be applied with respect to marketing materials received by you, please let us know. You can do this by e-mailing your Swiftsure relationship manager, data protection officer or any of the Swiftsure senior employees. Contact details are available at the bottom of this notice or on our website.

Data collection

Swiftsure may collect data:

  1. when you or an agent of yours contacts Swiftsure in relation to business and services offered;
  2. when you complete documents or forms during the course of business with Swiftsure;
  3. from Service Providers and other third parties that assist us in conducting business;
  4. when you telephone Swiftsure; and
  5. when you use the Swiftsure website or online services.

Data storage

Swiftsure stores your data on physical and electronic media. Data is safeguarded by Swiftsure and its Service Providers by maintaining physical and electronic security controls that are designed to comply with applicable legal standards.

The Data that is collected or held in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who works for us or for one of our Service Providers. In some cases, the laws of the destination country may not provide the same level of data protection as countries within the EEA. However, all Data wherever they are held by Swiftsure will be afforded a high level of protection against any unauthorised or accidental disclosure, access or deletion. By submitting your Data you agree to this transfer, storing or processing.

Unfortunately, the transmission of information via the internet is not completely secure. Although Swiftsure will do its best to protect your Data, we cannot guarantee the security of your Data transmitted electronically. Any such transmission is at your own risk.

Types of data that might be collected

During Swiftsure’s relationship with you, Swiftsure will collect and process Data about you, including:

  1. information which individuals and entities provide when contacting us (including through using this website) (such as their names, postal addresses, telephone numbers, identification documents and e-mail addresses);
  2. corporate information;
  3. details of services provided to you; and,
  4. details of purchases and redemptions of financial instruments.

Data sharing

Swiftsure uses Service Providers to conduct aspects of its business, so information may be disclosed to them and their affiliates Data that you have provided in order to fulfil the purposes for which the Data is held. These Service Providers may disclose such Data to each other and to each other’s affiliates in order to achieve the same purposes.

Swiftsure and its Service Providers may also be required to disclose your Data to governmental agencies, self-regulatory organisations, industry associations and similar bodies in order to fulfil legal and regulatory requirements. In addition, the laws of certain countries and states give people involved in lawsuits and other legal proceedings the right under certain circumstances to obtain information from Swiftsure and its Service Providers, including your Data. Swiftsure and its Service Providers will comply with these laws to the extent required.

Swiftsure will not sell your Data to any third party. Wherever possible, Service Providers are required to enter into confidentiality agreements that prohibit them from selling or improperly using your Data.

Data retention

Swiftsure will retain your personal information for a period of up to seven years following the point where the business relationship has ceased.

It may be necessary to retain your personal information beyond this period depending on additional legal/regulatory obligations. Thereafter, Swiftsure will refrain from collecting any further personal information on you and shall take appropriate steps to dispose of any records containing your personal information to the extent this is operationally feasible and proportionate.

Cookies

Swiftsure does not use cookies on its website.

Your personal data is not currently collected by Swiftsure using cookies.

Lawful basis for processing

Swiftsure assesses all personal data that is collected or stored to ensure that there is a legal basis for each type of data under GDPR. 

Other lawful basis may be used where Swiftsure assesses this is necessary and appropriate.

Data subject rights

You have the following rights, in certain circumstances, in relation to your personal information:

  • Right to access your personal information (in an easily readable form);
  • Right to rectify your personal information;
  • Right to restrict the use of your personal information (in certain specific circumstances);
  • Right to request that your personal information is erased (in certain specific circumstances). Please note that the right for your data to be erased (the "right to be forgotten") that applies in some contexts under the General Data Protection Regulation is not likely to be applicable to most, if not all, of the personal information you provide to Swiftsure, given the specific nature of the purposes for which Swiftsure uses the data, as described above;
  • Right to object to processing of your personal information (in certain specific circumstances);
  • Right to data portability (in certain specific circumstances);
  • Right to withdraw consent (in certain specific circumstances); and
  • Right to receive information regarding any entities we disclose your data to.

Where Swiftsure or its Service Provider(s) requires your personal information to comply with AML or other legal requirements, failure to provide this information means Swiftsure will not be able to accept you as a client or investor.

Swiftsure shall notify you of any personal information breach affecting you that is likely to result in a high risk to your rights and freedoms.

Changes to this notice

Swiftsure will need to update its privacy notice in response to regulatory requirements or changes to its business. The latest notice will always be available on the Swiftsure website (www.swiftsurepartners.com).

How to contact Swiftsure

Under the GDPR, data subjects can make a complaint to the supervisory authority including the Member State in which they reside or work or the place of the alleged infringement.

If you have any questions or concerns about personal data or this privacy policy or you wish to make a complaint about how Swiftsure has processed your personal data, please contact Swiftsure by writing to info@swiftsurepartners.com.


Swiftsure
16th October 2018

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