Who is responsible for your personal data?
Aurum is responsible for your personal data. Aurum comprises the Aurum group which includes Aurum Fund Management Ltd. located at Aurum House, 35 Richmond Road, Hamilton HM 08, Bermuda, Aurum Research Limited located at 37 Ixworth Place, London SW3 3QH, Aurum Funds Limited located at 37 Ixworth Place, London SW3 3QH, Aurum Funds Management (Pty) Limited located at Unit 20 & 21, Second Floor, 1 Melrose Boulevard, Melrose Arch, South Africa and the various funds managed or advised by Aurum.
Which personal data do we collect?
The personal data we collect may include:
- Personal details, such as name, age, date of birth, gender, citizenship, occupation and marital status;
- Contact details, such as current and previous address, telephone, email, in some cases both private and work related contact details;
- Identification documents or copies thereof, such as your passport, national identity card or driver’s license (which generally include a head and shoulders photograph), as required and permitted by applicable laws and regulations addressing due diligence and related matters;
- A government-issued personal identifier, such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number or Medicare Number etc. (as permitted by law);
- Personal details relating to your immediate family members and details relating to any senior political figures (e.g. senior military or government official) to whom you are connected; and
- Financial information, including source of wealth/funds, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources.
How do we collect your personal data?
The personal data we collect regarding you comes primarily from information that you submit to us or that is otherwise captured during the course of your relationship with us.
What about personal data obtained from other sources?
We may also obtain your personal data from referees, services or databases as part of our due diligence process and employment checks. Your personal data may also be provided to us, in connection with any business transaction or arrangement by your or our agents or advisers.
Where you are an individual associated with a company or institution with which Aurum does business, your personal data will also be provided to us via that company or institution.
Are you required to provide personal data?
As a general principle, where you provide us with your personal data you do so entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide personal data and there is no obligation to provide any personal data on the public areas of this website. However, there are circumstances in which Aurum cannot proceed without certain of your personal data, for example because this personal data is required to process your instructions or orders, provide you with access to information or materials or to carry out any legal or regulatory obligations. In these cases, it will unfortunately not be possible for us to provide you with what you request without the relevant personal data and we will notify you accordingly.
For which purposes and legal basis will we use your personal data?
We may not process personal data if we do not have a valid legal ground to do so. Accordingly, Aurum and/or other persons acting on our behalf, will only process and use your personal data:
- In order to comply with legal and regulatory obligations and requests, (including any legal or regulatory guidance, codes or opinions), applicable to us anywhere in the world;
- If necessary for our legitimate interests or those of any third party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms;
- Where necessary for taking steps to enter into or execute a contract with you for the services or products you request, or for carrying out our obligations under such a contract;
- To exercise and defend our legal rights anywhere in the world including in relation to any litigation, disputes or contentious matter we are involved in and/or to assist with investigations, complaints, regulatory requests, litigation, arbitration or mediation;
- To analyse and improve our services and communications to you;
- To protect the security of, and manage access to, our premises, IT and communication systems, online platforms, websites and other systems, and to prevent and detect security threats, fraud or other criminal or malicious activities;
- For insurance purposes;
- For monitoring and assessing compliance with our policies and standards;
- To identify persons authorised to give instructions on behalf of our investors, clients, customers, suppliers and/or service providers; and
- For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.
Where you have expressly given us your consent, we may process your personal data for the following purposes:
- Communicating with you through the channels you have approved to keep you up to date on the latest developments, announcements, and other information about Aurum (including briefings, newsletters and other information) as well as Aurum events and projects;
- Customer surveys, marketing campaigns, market analysis or other promotional activities or events; or
- Collecting information about your preferences to create a user profile to personalise and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).
With whom will we share your personal data?
Aurum does not sell, rent or trade your personal data, and does not disclose your personal data except as described in this Privacy Statement.
Our processing and use of your personal data, for the purposes specified in this Privacy Statement, includes disclosure of your personal data:
- Among the Aurum group and to associated entities;
- To third parties such as transfer agents, banks or exchange or clearing houses to whom we disclose personal data in the course of providing products and services to you;
- To other persons processing your personal data on our behalf or otherwise providing us with professional (such as legal, accounting or auditing) or other services including our associated firms and vendors which conduct operational, technology and customer service functions in various jurisdictions; and
- To any third party to whom you authorise us to disclose your personal data.
What about personal data about other people that you provide to us?
If you provide personal data to us about someone else (such as one of your co-workers or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Statement. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Statement, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices (including disclosure to overseas recipients), the individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided (such as our inability to provide services).
How do we keep personal data about you secure?
Aurum maintains appropriate physical, technical and procedural safeguards designed to protect any information that you provide to us from accidental or unauthorised loss, misuse, damage, modification, access or disclosure.
Do we transfer personal data abroad?
Aurum is a globally active provider of alternative investment solutions. We may transfer your personal data abroad if required for the Permitted Purposes as described above. This may include countries which do not provide the same level of protection as the laws of your home country. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679 or other relevant laws. This includes entering into the EU Standard Contractual Clauses which are available here. You may contact us anytime using the contact details below if you would like further information on such safeguards.
How to update personal data about you?
If any of the personal data that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate personal data about you, please let us know by sending an email to email@example.com. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
For how long do we retain your personal data?
Your personal data will be deleted when it is no longer reasonably required for the permitted purposes or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing such data.
What are your rights?
Subject to certain circumstances, legal and contractual conditions and the legitimate interests of Aurum, you have the right to request a copy of the personal data about you, which we hold, to have any inaccurate personal data corrected, to have your personal data deleted, to withdraw your consent to processing and to object to or restrict our use of your personal data. You may also make a complaint to us or to the relevant data protection authority if you have a concern about our handling of your personal data.
If you wish to do any of the above please send an email to firstname.lastname@example.org. We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data, and for any additional copies of the personal data you request from us.
We will consider any requests or complaints that we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.
Designated Privacy Officer
Members of the Aurum group domiciled in Bermuda have nominated Adam Hopkin as the Designated Privacy Officer for the purposes of Personal Information Protection Act 2016 (the “PIPA”), such nomination is not a Data Protection Officer for the purposes of European Union’s General Data Protection Regulation (the “GDPR”), there has been no appointment of a Data Protection Officer in the Aurum group.
Updates to this Privacy Statement
This Privacy Statement was last updated in May 2020. We reserve the right to update and change this Privacy Statement from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the changed Privacy Statement on our website or publish it otherwise. The changes will take effect as soon as they are posted on this website.
How to get in touch with Aurum
We welcome your views about our Privacy Statement. If you would like to contact us with any queries or comments, please send an email to email@example.com or send a letter to Aurum House, 35 Richmond Road, Hamilton HM 08, Bermuda or to 37 Ixworth Place, London SW3 3QH in each case for the attention of the Compliance Officer.