Anchor Investment Management Ltd. Privacy & Cookie Policy


PRIVACY POLICY


This policy (“Privacy Policy”) is provided by Anchor Investment Management Ltd. (“we” or “us”) is committed to maintaining the security, confidentiality and privacy of your Personal Information and sets out our policies with respect to the collection, sharing and use of personal information.

This Privacy Policy documents our commitment to protecting your Personal Information.

How we collect information?

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 electronic communications with you as described below; or
• the use of Internet “cookies” (an information collecting device from a web server), as described further below.

We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.

Why we collect information

We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analyzing our activities, and complying with applicable legal or regulatory requirements.

We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or performance of a contract, or where we or a third party determine that is necessary for our legitimate business interests to collect and use your personal information. The legitimate business interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes (see below).

What are the consequences of failing to provide your personal information?

As a regulated investment manager, we are subject to certain legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime (such as money laundering or terrorist financing), tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below).

We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us, such as an investment in one of our managed products or services.

A refusal to provide us with personal information will, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or or enforcement agencies.

The types of personal data we may collect and use

The types of personal data we may collect will depend on the nature of our relationship with you and the purpose of which information is being collected. Such personal data might include your name and address (including proofs of name and address), contact details, date of birth, gender, nationality, photograph, signature, copies of identity documents, occupational history, job title, income, assets, other financial information, bank details, investment history, tax residency and tax identification information.

How long do we retain your personal information?

We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of seven years after the termination of any such relationship.

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

Do we share your personal information with third parties?

To the extent it is relevant to the purpose for which we collect your information, we may share your personal data with third parties, such as:

• 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 and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, and providers of customer relationship management tools;
• reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;
• any person, as directed by you; 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?

You have certain rights under Data Protection Law and Personal Information Protection Act 2016 in respect of the personal data we hold about you and which you may exercise. These rights generally include:

• to request access to your information;
• to request rectification of inaccurate or incomplete information;
• to request erasure of your information (a “right to be forgotten”);
• to restrict the processing of your information in certain circumstances;
• to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
• where relevant, to request the portability of your information;
• where you have given consent to the processing of your data, to withdraw your consent; and
• to lodge a complaint with the competent supervisory authority.

Recording and monitoring of communications

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

• ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances pertaining to your account;
• ensuring compliance with our various regulatory obligations; or
• detecting and preventing the commission of financial crime.

Copies of any such recordings will be stored for a minimum period of seven years, or such other longer period as we may determine from time to time.

Safeguarding Personal Information

Anchor protects Personal Information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification or disposal. Confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. Anchor will not be responsible for any loss or damage suffered because of security and/or confidentiality when information is transmitted by e-mail or wireless communication. We will take your use of any particular mode of communication as permission for us to communicate with you using the same mode of communication unless otherwise instructed by you.

USE OF COOKIES


We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer.

A cookie is an element of data that a website can send to a browser which may then get stored on a computer. The cookie can be used to identify a repeat user to the site that placed the cookie on the computer. Cookies also can be used to track the user's movements from page to page, or within a single page of a website. Cookies are used to enhance the navigation and functionality of this site, to securely verify identity, and to personalize aspects of a visitor's experience on this site. The visitor does not have control over cookies but may be able to set their browser to notify them when a cookie is being placed on their computer. For example, a visitor to this site will receive a cookie when they access this area. An individual may be able to set their browser software to not accept cookies at all. However, this may well affect the individual's ability to view certain areas and their ability to use certain tools and contents on this site.

We have put arrangements in place to permit visitors to this site to access sites of other organizations. Each organization has their own privacy policy. Individuals are advised to read the privacy policies of all organizations and sites they visit.

Anchor Investment Management Ltd. has no control over other organization's websites and when individuals click through to other sites, they leave the area controlled by us. We may change this policy from time to time. Any changes will be posted on this site and will take effect immediately.

How to contact us
If you have any questions about this Privacy Policy or requests with regards to the personal data we hold about you, you may contact us at shawke@anchor.bm or by writing to Anchor Investment Management Ltd. 7th floor, 42 Reid Street, Hamilton, Bermuda, HM12.

Last updated: March 1 2021

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