Privacy Policy

Your privacy is very important to us. This notice (“Privacy Notice”) is provided by Aptior Capital LLP (“Aptior”, “we”, “us”), and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, ‘processing’) and protection of personal data.

Aptior is a company registered in England and Wales with company number OC418001. Aptior is authorised and regulated by the Financial Conduct Authority (“FCA”) with Firm Reference Number 784435.

Who to Contact About This Privacy Notice

This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”).

For the purposes of the General Data Protection Regulation (‘GDPR’), Aptior will be the ‘controller’ of the personal data you provide. Please read the following information carefully to understand Aptior’s practices in relation to the treatment of your personal data. Should you have any questions about this Privacy Notice or requests with regards the personal data we hold, please email us at [email protected] or write to Aptior Capital LLP, 78-79 Pall Mall, London SW1Y 5ES.

The Types of Personal Data We May Hold

The categories of personal data we may collect include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches.

How We Collect Personal Data

We may collect personal data about you through:

  • information provided directly to us by you, or another person on your behalf;
  • information that we obtain in relation to any transactions between you and us; and
  • recording and monitoring of telephone conversations with you.

We also may receive your personal information from third parties or other sources, such as our affiliates, service providers, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

How We May Use Personal Information

We may process your personal data for the purposes of administering the relationship between you and us, marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities, or law enforcement agencies).

We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal information. Such grounds include, for example, circumstances where:

  • processing is necessary to perform our obligations under the relevant fund documents;
  • we are required to comply with a legal or regulatory obligation applicable to us; or
  • we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal information, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose.

What Are The Consequences Of Failing To Provide Personal Information

As a regulated financial services firm, we are subject to 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, tax and regulatory reporting, or the rules on recording and monitoring of communications.

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.

A refusal to provide us with personal information may, 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 enforcement agencies.

How We May Share Personal Data

We may (to the extent relevant to the purpose for which we collect your information), share your personal data 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;
  • our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators;
  • service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools;
  • credit 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.

Retention Periods and Security Measures

We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to the applicable Data Protection Laws. Personal data will be retained for the duration of any investment in the applicable fund and for a minimum of five years after a redemption or withdrawal, as applicable, of such investment, or liquidation of the applicable fund. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

To protect your personal information from unauthorised access and use, we apply organisational and technical security measures in accordance with applicable Data Protection Laws. These measures include computer safeguards and secured files and buildings.

We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws.

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

Additional Information under the EU General Data Protection Regulation

You may have certain rights under EU General Data Protection Regulation (“GDPR”) in relation to our processing of your personal data and any processing carried out on your behalf. These rights include:

  • the right to request access to your personal data;
  • the right to request rectification of your personal data;
  • the right to request erasure of your personal data (the “right to be forgotten”);
  • the right to restrict our processing or use of your personal data;
  • the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities);
  • where relevant, the right to request the portability of the data;
  • if your consent to processing has been obtained, the right to withdraw your consent at any time;
  • the right to lodge a complaint with a supervisory authority. Please note that the right to be forgotten that applies in certain circumstances under GDPR is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above.

A complaint in respect of the Investment Manager may be made to the Information Commissioner’s Office in the United Kingdom. Further information is available from the ICO’s website.

Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection to personal data as under the GDPR (“Third Countries”). In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of GDPR, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries. We may also be required to transfer your personal information to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.

Will I be notified of changes to this policy?

Aptior may, from time to time, review and update this policy. Aptior will maintain the latest version of this policy on its website, and where the changes are deemed material, it will make you are aware of these.