Privacy Policy

Empiric Managed Capital Advisors Limited (“Empiric”’) and your data

Empiric takes privacy seriously. Our fund management services are provided to collective investment schemes and accordingly we do not seek to process personal data but we are very aware that in dealing with prospective investors and others in the course of managing funds we may come across personal data that those individuals would not want us to share with others. Under the General Data Protection Regulations (GDPR), Empiric will be a data controller in that we hold personal data for AML and communication purposes but do not seek to process it for any other purpose.

Where did we get your data from?

We will obtain personal data directly from investors, from personal representatives of our investors, clients or service providers or in some cases from a fund administrator who has been delegated the responsibility of undertaking AML checks on fund investors.

What information do we need and why?

The administrator of our clients need to collect proof of identity and proofs of address of investors or their representatives in order to fulfil our regulatory responsibility to identify those investors and we need to undertake checks on this information to satisfy our regulator that we are meeting AML responsibilities. We often will need to obtain e-mail addresses and phone numbers of personal representatives of investors and prospective investors so as to keep them informed as to the performance of the funds we manage and our views.

How will we use your data?

The personal data we collect for identification purposes will remain on file and may be provided to our compliance consultants and/or our regulator to evidence the fact that we are meeting our regulatory obligations.

The personal data we collect for communication purposes will be used to contact you where you have requested to receive newsletters and other updates.

Who do Empiric share your data with?

We may share your personal data with other parts of the Empiric group, we may also share your personal data with the fund administrator, our compliance consultants and/or regulators as outlined above.

The personal data that we collect will at all times remain within the EEA.

What are your rights?

As we only hold personal data as a data controller you have no rights over that data.

How long do we keep the information for?

Our regulator requires us to keep personal data for six years after the end of any client relationship we have.

How to complain

If you’re not happy with how we process your data, you will have the right to complain to the Information Commissioner and we can provide details about how to do that.

Contacting Empiric

You may contact us at: [email protected]

or

Empiric Capital
7 Howick Place
London SW1P 1BB UK

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