Your privacy is important to us. This Privacy Policy is provided by Atlantide Asset Management Ltd (“Atlantide”, “we”, “us”) and it explains your privacy rights and how we gather, use and share information about you.  We are committed to safeguarding information provided to us by any third parties (“you”) or which we otherwise obtain about you, from which any individual can be identified (“Personal Information”). By visiting and contacting us through our website you acknowledge that we may collect, use and transfer your Personal Information as set out in this policy. This Privacy Policy sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of Personal Information that we hold on individuals, in relation to services we provide.

This Privacy Policy is being provided in accordance with the requirements of data privacy laws, including UK GDPR, as amended, and any other law relating to privacy or the processing of Personal Information and any statutory instrument, order, rule or regulation implemented thereunder, each as applicable to Atlantide (collectively, “Data Protection Law”).

1. The Categories of Personal Information That We May Collect And Use

When you engage with Atlantide (e.g.: by making an enquiry through the website, contacting us by telephone or by email), you may provide Personal Information about yourself including your name and contact details e.g.: email or telephone number. Where you make use of our website, we may collect Personal Information such as your IP address. If you consider entering into any agreement with Atlantide you may provide additional Personal Information such as residential address, identification documents, bank details, information about assets or net worth, credit history, source of funds details or other sensitive information, such as certain special categories of data contained in the relevant materials or documents.

2. How We Collect Personal Information

We may collect Personal Information directly from you or from third parties to whom you have provided this information. We may also obtain information from publicly accessible databases or registers, or other publicly accessible sources, such as the Internet or from recording of electronic communications with you, as detailed below.

3. The Lawful Basis On Which We Process This Information

We may process your Personal Information for the purposes of administering the relationship between you and us, that is, in fulfilling our contractual duties as an alternative investment fund manager with respect to communications and reporting, 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 with competent jurisdiction over our business). Your Personal Information will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so.

Where Personal Information is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in the termination of our contractual relationship with you. Where there is suspicion of unlawful activity, failure to provide Personal Information may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

4. Who We Share This Information With and Why

We may disclose information about you to our affiliates or third parties, for our everyday business purposes, such as to facilitate transactions or to respond to court orders and legal investigations. It may also be necessary, under anti-money laundering and similar laws, to disclose information. We will also release information about you if you direct us to do so. We do not share your information with non-affiliates for them to market to you.

5. Electronic Communications

We record electronic communications with you for the purposes of ensuring compliance with our regulatory obligations.

6. Retention Periods And Security Measures

We will not retain Personal Information for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Law. Personal Information will be retained for the duration of any contractual relationship, direct or indirect, where applicable, and for a minimum period of three years after the termination of such relationship. We may retain Personal Information for a longer period for the purpose of marketing our services or compliance with applicable law. From time to time, we will review the purpose for which Personal Information 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 Data Protection Law. These measures include computer safeguards and secured files and buildings. We will notify you of any material Personal Information breaches affecting you in accordance with the requirements of Data Protection Law.

7. International Transfers

Because of the international nature of a fund management business, Personal Information may be transferred to countries outside the UK (“Third Countries”), such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the Data Protection Law in the UK. In such cases, we will process Personal Information (or procure that it be processed) in the Third Countries in accordance with the requirements of the Data Protection Law, which may include having appropriate contractual undertakings in legal agreements with service providers who process Personal Information on our behalf in such Third Countries.

8. Your Rights Under Data Protection Law

Under Data Protection Law, you have the right to request access to information about you that we hold. To make a request for your Personal Information or if you have any questions about this Privacy Policy, contact Niki Malik at compliance@atlantideam.co.uk. If you remain dissatisfied, you have the right to make a complaint to The Information Commissioners Office in the UK (https://ico.org.uk/concerns).

9. Our Website

When you visit Atlantide’s website, we may use traffic log cookies to identify which pages on our website are being used. This helps us analyse data about web page traffic and improve our website by tailoring it to the needs of users. We only use this information for statistical analysis purposes. A cookie is a small file which asks permission to be placed on your computer. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular website. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Overall, cookies help us provide a better website by enabling us to monitor which pages users find useful and which they don’t. A cookie does not give us access to a user’s computer or any information about them, other than the data they choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, this may prevent you from taking full advantage of the Website. For further details on cookies and how to manage them, we recommend that you visit the All About Cookies website.