This Data Privacy Notice was last updated on 1 October 2019.
Relationship | Purpose(s) |
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Investors or Potential Investors |
•
maintain a directory of contacts
•
send updates, information and notices or otherwise
corresponding with you in connection with your investment(s)
in Affirma Capital
• provide you with, and inform you about, investment products
and services; manage our risk and operations
• organise meeting with investors and potential investors
• assess and process requests you make
• perform conflict checks, including investor due diligence
• perform contracts, including administering or managing of
Affirma Capital, processing the subscription and investment
into funds managed by Affirma Capital
• facilitate the continuation or termination of the contractual
relationship between investors and Affirma Capital
• facilitate business asset transactions involving Affirma Capital
or related entities
• facilitate the transfer of funds, and administering and
facilitating any other transaction, between investors and
Affirma Capital
• maintain statutory registers
• enter information in the register of partnership interests;
send each investor statements relating to such investor’s
investment(s)
• facilitate the payment of dividends and/or other distributions
• protect the security and integrity of our IT systems
• billing and invoicing purposes
• facilitate advice from our professional advisors, including
accountants, lawyers and other consultants
• send to third party service providers or professional advisors
to process information on Affirma Capital's behalf
• general business purposes, including statistical analysis and
market research
• inform parties of changes to Affirma Capital’s policies, terms
and conditions and other administrative information
• investigate any complaints, or pursue or defend any claims,
proceedings or disputes
• prevent and detect fraud
• comply with audit requirements; ensure internal compliance
with our policies and procedures
• protect Affirma Capital against fraud, breach of confidence or
theft of proprietary materials
• anti-money laundering and counter-terrorist financing checks,
including verifying the identity and addresses of our investors
(and, where applicable, their beneficial owners)
• sanctions screening and complying with applicable sanctions
and embargo legislation
• comply with requests from regulatory, governmental, tax and
law enforcement authorities; surveillance and investigation
activities
• comply with legal, tax, accounting or regulatory obligations to
which we or the third party are subject
• monitor communications to/from us (where permitted by law)
|
Investment and Transaction Counterparties | • maintain profiles of counterparties in Affirma Capital's system
database
• send periodic updates about Affirma Capital's business,
events, presentations and opportunities
• market our investment products
• organise meetings with transaction counterparties
• perform conflict checks, undertaking due diligence and
performing background checks
• verify and process personal particulars to maintain accurate
records
• inform parties of changes to Affirma Capital’s policies, terms
and conditions and other administrative information
• evaluate potential transactions and maintain records of
investments
• perform contractual obligations with such counterparties
• administer transactions which are entered into
• trades and transaction reporting
• business development and promotion
• facilitate advice from our professional advisors, including
accountants, lawyers and other consultants
• send to third party service providers or professional advisors
to process information on Affirma Capital's behalf
• general business purposes, including statistical analysis and
market research
• send to applicable or other governmental agencies for
compliance purposes
• billing and invoicing purposes
• safeguard legal rights and interests
• anti-money laundering and counter-terrorism financing checks
in compliance with our internal risk management framework
• monitor communications to/from us (where permitted by law)
|
Employees or Job Applicants | • verify and process personal particulars, evaluate the
qualification and suitability for employment with Affirma
Capital and assess the job applicant's financial status
• communicate and inform the employee or job applicant of
changes to Affirma Capital’s policies, terms and conditions and
other information
• send updates to the employee or job applicant
• conduct market research for statistical analysis and profiling
for the improvement of services
• monitor communications to/from us (where permitted by law)
|
External Service Providers or Vendors | • verify and process personal particulars and assess suitability as
an external service provider or vendor for Affirma Capital as
well as assess its financial status
• inform the external service provider or vendor of changes to
Affirma Capital’s policies, terms and conditions and other
information
• maintain profiles of our investment counterparties in Affirma
Capital's system database
• conduct anti-money laundering and counter-terrorism due
diligence and run checks in compliance with our internal risk
management framework
• administer and maintain records of goods, services or advice
that we have received
• commission further services or procure further goods
• monitor communications to/from us (where permitted by law)
|
Visitor of our website or offices; or attendees of events organised by Affirma Capital | • maintain a directory of contacts
• contact information for security reasons or emergency
purposes
• health information for first aid accident book
• collect information for names and dietary preferences for the
purposes of catering
• collect, use, disclose and transfer photos and videos featuring
such attendee for publicity purposes by Affirma Capital
• respond to queries from visitors and event attendees
• maintain profiles of our visitors and event attendees in
Affirma Capital's system database
• monitor communications to/from us (where permitted by law)
|
Jurisdiction | Transfer of Personal Data Internationally |
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India | Affirma Capital may transfer your SPDI to any person or entity whether in India or located in any other country that ensures a similar level of data protection as provided in the RSP Rules when the same is necessary for the performance of a lawful contract with you or where you have consented to such transfer. The SPDI transferred would include such information provided to Affirma Capital either directly by you (the information provider) or by any legal entity with whom you (the information provider) are associated in any capacity. You acknowledge that some countries to which we may transfer your SPDI may not have data protection laws which are as stringent as the data protection laws of India. You acknowledge and agree that it is adequate that when we transfer your Personal Data to any other entity overseas, we will put in place contractual obligations on the transferee which will oblige the transferee to adhere to the same levels of data protection as those adopted by us. |
EU | Affirma Capital may transfer your Personal Data into and outside the European Economic Area and when we do, you can expect a similar degree of protection in respect of your Personal Data as set out in this Data Privacy Notice. |
Jurisdiction | Transfer of Personal Data Internationally |
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India | In addition to the rights granted to you in this Data Privacy Notice, if you would like to obtain access to review your Personal Data, please contact the Grievance Officer at the contact details set out below. We have appointed a Grievance Officer to address any concerns or grievances that you may have regarding any use of your Personal Data. If you have any such grievances, please write to our Grievance Officer at: Benaifer.Rabady@affirmacapital.com. |
EU | The designated contact entity in relation to Affirma Capital matters in the European Union and the European Economic Area is data.protection@affirmacapital.com. |
South Korea | Affirma Capital has appointed an individual as the Personal Information Protection Manager to oversee responsibility for matters relating to the handling of personal information as well as the handling of complaints from providers of personal information. For matters relating to Affirma Capital in Korea, Korean residents or activities taking place within the territory of Korea, please contact: Karen.Lee@affirmacapital.com. |
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