Privacy Notice
This Privacy Notice applies to Pi Investment Management Limited and Perspective Capital Management Limited (together, “Perspective Investments”) and to funds managed by Perspective Investments (the “Funds”). In this Privacy Notice, we refer to Perspective Investments as the “Investment Managers” and, together with the Funds, collectively as “we”, “us”, and “our”.
This Privacy Notice describes how we treat individual personal information that is provided to us or that we collect, including:
• What personal information is acquired, and how it is used;
• Our legal basis for processing personal information;
• Protection of the security of personal information;
• Disclosure of personal information to third parties;
• Transfer of personal information internationally;
• Retention of personal information;
• Rights in respect of the personal information we have;
• Website & Cookies;
• Privacy Notice Review; and,
• How to contact us.
The Funds and Investment Managers are each data controllers in respect of personal information. A data controller is responsible for deciding how to hold and use personal information. We may process your personal information ourselves or through others acting as data processors on our behalf (such as the administrator of the Funds (the “Fund Administrator”)). The Fund Administrator will generally process personal information provided to it in connection with an investment in the Funds. The Funds and Investment Managers are responsible for ensuring that they use personal information in compliance with data protection regulations, including the Data Protection Law of the Cayman Islands and the EU General Data Protection Regulations (“GDPR”).
This Privacy Notice applies to you if: (i) you are an investor or prospective investor in the Funds or an adviser to an investor or prospective investor in the Funds; (ii) your personal information has been provided to the Funds in connection with an investment or prospective investment directly or by another person (such as where you are a director, partner, trustee, employee, agent or direct or indirect owner of an investor or prospective investor); or, (iii) we otherwise use your personal information. This Privacy Notice sets out the basis on which personal information about you will be processed by us. Please take the time to read and understand this Privacy Notice.
We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. These supplemental notices should be read together with this Privacy Notice.
What personal information is acquired, and how it is used
Personal information includes any information that directly or indirectly identifies an individual. We acquire personal information relating to you and your use or potential use of our products and services from a variety of sources, which are detailed below.
We are likely to process the following categories of personal information about you:
• (a) Information provided by you directly to us, including (i) personal identification data or characteristics, such as your name and address (including proofs of name and address), contact details, date of birth, gender, domicile, nationality, country of residence, and information related to your family and other close associate relationships, (ii) identification documents, such as copies of your passport or driver’s license, photograph, and signature specimen, (iii) occupational information, such as your job title and employment history, and (iv) financial information, such as your income, assets, other financial information, bank details, investment history, tax residency and tax identification information.
• Information collected or generated by us, including information obtained through emails, call recordings, and website usage data (and other related data).
• Information that we obtain from other sources, including information obtained for the purpose of know-your-customer procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-person checks, and sanctions checks, among other things), information from public websites and other public sources, and information received from your advisers, representatives, service providers or intermediaries.
There are more limited bases for processing sensitive or special category personal information. Sensitive or special category personal information is information which contains or reveals racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health information, or sex life and sexual orientation information. We do not intend to collect sensitive or special category personal information about you actively. Whilst we will use reasonable efforts to limit our holding of such information, please be aware that we may hold such information incidentally. For example, where:
• you volunteer sensitive or special category personal information to us or one of our processors, such as if you send us an email containing sensitive or special category information; or,
• documents gathered for legal / regulatory purposes contain sensitive or special category information, such as a due diligence search from public sources which includes sensitive or special category information.
Your personal information may be stored and processed by us for the following purposes:
• Assessing and processing materials in connection with your investment in the Funds and related dealings, including performing know-your-customer procedures, conducting capital activity related to your investment, calculating net asset value and ownership, and overseeing these and similar processes.
• General relationship and business administration, including communicating with investors and their advisers, representatives, intermediaries, service providers and other counterparties about an investment in the Funds, communicating with such persons regarding the potential for other investments with us, conducting other relationship management matters, engaging with the Funds’ accountancy, legal and audit services, and conducting risk monitoring, information technology systems administration and other product improvement matters.
• Compliance with legal and regulatory obligations and industry standards, including know-your-customer procedures, the automatic exchange of tax information and legal judgments.
• Business activities of the Investment Manager and its affiliates relating to the Funds, such as investor relations, discussions with our service providers and counterparties, and general business strategy, development, decision-making and marketing efforts.
We will use your personal information only for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Unless and until you make a decision to invest or otherwise engage in a business transaction with us or invest in one of our investment products, you are not required to provide us with any personal information, except where this is for the purposes of investor qualification.
Our legal basis for processing personal information
We will process your personal information only where we have a legal basis for doing so. We may rely on the following legal bases for collecting and further processing your personal information:
(a) If you are an investor or prospective investor, you may enter into an investment contract with the Funds and some processing will be necessary for the performance of that contract or will be done at your request prior to entering into that contract.
(b) Processing will be necessary to discharge a relevant legal or regulatory obligation.
(c) The processing will, in all cases, be necessary for the legitimate business interests of the Funds, the Investment Manager, the Funds’ administrator or another person, such as:
(i) carrying out the business activities of the Funds, the Investment Manager, the Funds’ administrator or other persons, including, for example, to provide advisory services to its investors, providing sub-advisory services to an adviser pursuant to a management agreement, to asses and open accounts for its investors and prospective investors, to process transactions for such accounts, to communicate with and market products and services to its investors and prospective investors, to communicate with service providers and counterparties, and for informing our decision-making (such as in connection with business strategy and development).
(ii) complying with legal and regulatory obligations and industry practice, and preventing fraud;
(iii) establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and
(iv) ensuring the security of information systems.
(d) In respect of any processing of sensitive personal information falling within special categories, such as any personal information relating to the political opinions of a politically exposed person, the processing will be necessary for reasons of substantial public interest.
If you provide us with personal information in respect of any third party, then we rely on you to have the authority to provide any third party’s personal information to us and agree to share this Privacy Notice with such third parties and inform them of the details of the personal information you provide to us.
Protection of the security of personal information
We have implemented and currently maintain an effective information security program that includes administrative, technical, and physical safeguards and other security measures necessary to:
(a) ensure the security, confidentiality, and integrity of personal information;
(b) protect against any anticipated threats or hazards to the security, confidentiality, and integrity of personal information;
(c) protect against unauthorized access to, destruction, modification, disclosure or use of personal information; and
(d) detect and respond to security incidents involving your personal information.
We permit persons working for us to access and use personal information only to serve our legitimate business and our client & investor service needs, in accordance with this Privacy Notice.
Disclosure of personal information to third parties
We may share your personal information with a third party where this is required by law, where it is necessary to perform our contract with you, or where we have another legitimate interest in doing so.
We may need to share your personal information with:
• other entities within our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise or for assistance in relation to marketing and business development;
• professional advisers including lawyers, bankers, auditors and insurers to the extent such information is relevant to their performance of their services;
• regulators; and,
• any of our service providers where such information is relevant to their performance of such services.
We may also need to share your personal information with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
We may also process your personal information, if necessary, in the defence of a legal claim. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
We will not, without consent, sell or rent to any third party any personal information collected.
Transfers of personal information internationally
We operate in multiple jurisdictions, both within and outside the Cayman Islands and the European Economic Area (EEA). Personal information is stored on cloud servers managed by our system providers and personal information will be transferred to and stored by persons outside the Cayman Islands and the European Economic Area (the “EEA”), and in particular will be transferred to and stored by affiliates or service providers of the Funds or the Funds’ Administrator outside the Cayman Islands and the EEA.
While countries outside the Cayman islands and the EEA do not always have strong data protection regulations, where such transfers of personal information are made, they will be made in accordance with applicable law, and subject to appropriate safeguards. For example, the country to which the personal information is transferred may be approved by the European Commission, the recipient may have agreed to model contractual clauses approved by the European Commission that oblige them to protect the personal information, or the recipient may be located in the United States and be a certified member of the EU-US Privacy Shield scheme.
Retention of personal information
Personal information will be retained for the purposes detailed in this Privacy Notice and where we have a legal basis for doing so.
We will keep your personal information only for as long as necessary for the purposes for which it was acquired. This will normally include any period during which we are dealing or expect to deal with you and what we consider to be a suitable period thereafter for our internal record-keeping purposes. We will regularly review records to ensure that your personal information is retained no longer than is necessary, unless there is a legal reason for extended retention. In some circumstances your personal information data may be anonymised so that it can no longer be associated with you, in which case it is no longer personal information data. Generally, we will keep information relevant to our dealings with you for five years following the last date of activity (or up to seven years if requested by a regulatory authority).
Once we no longer require your personal information for the purposes for which it was held, we will securely destroy your personal information in accordance with applicable laws and regulations.
Rights in respect of the personal information we have
You have rights as an individual which you can exercise in relation to information we hold about you under certain circumstances. These rights are to:
• request access to your personal information data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
• request rectification of your personal information;
• request the erasure of your personal information;
• request the restriction of processing of your personal information;
• object to the processing of your personal information; and,
• request the transfer of your personal information data to another party.
You will not usually have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Compliance@PerspectiveInvestments.com . Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we are required to retain your personal information for a legal or regulatory purpose.
If you would like to exercise any these rights, please contact us at Compliance@PerspectiveInvestments.com
We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this Privacy Notice. You can contact them at Compliance@PerspectiveInvestments.com
You also have the right to make a complaint at any time to a supervisory authority for data protection issues. In the Cayman islands, the relevant Data Protection Supervisory Authority is the Office of the Ombudsman and you can contact them via their website www.ombudsman.ky/data-protection. In the UK, the relevant Data Protection Supervisory Authority is the Information Commissioners Office (“ICO”) and you can contact them via their website: www.ico.org.uk.
Website & Cookies
The Perspective Investments Website uses cookies to distinguish you from other users of our Website and to collect information about your online preferences. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. By continuing to browse the Website, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers stored on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive, allowing the website to load and function faster when revisited.
Perspective Investments uses the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enabled you to agree with our Terms & Conditions of use of our Website.
• Analytical/performance cookies. These cookies collect information about how you use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. These cookies are sometimes placed by third-party providers of web traffic analysis services, such as Google Analytics.
• Functionality cookies. These cookies remember choices you make and are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
We use Google Analytics to monitor our Website traffic patterns and usage to help us develop the design and layout of the Website. This software does not enable us to capture any personal information. For information on how Google processes and collects your information in regard to this product and how you can opt-out, please see www.policies.google.com/technologies/partner-sites
Most internet browsers are automatically set up to accept cookies. However, you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please refer to the help and support area on your internet browser for instructions on how to block or delete cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
For more information on managing cookies, please go to www.allaboutcookies.org or visit www.youronlinechoices.com which has further information about behavioural advertising and online privacy.
Please note that our Website may contain links to other websites of interest. However, if you use these links to leave our Website, you should note that we do not have any control over other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such websites, and such websites are not governed by this Privacy Statement. You should exercise caution and look at the Privacy Statement applicable to any website you visit.
Privacy Notice Review
We may make changes to this Privacy Notice from time to time and will post such updates on our website.
How to contact us
You can contact us directly if you have any questions about this Privacy Notice or in order to exercise your personal information data subject rights by contacting your relationship manager or addressing your email questions and requests to Enquiries@PerspectiveInvestments.com.