New Zermatt Properties (the “Company”)
The Company is committed to respecting your privacy in relation to the personal data we collected from you in the course of operating our business and our website and to complying with the Personal Data (Privacy) Ordinance (Cap 486) and other applicable data protection law (the Data Protection Legislations).
The purpose of this document is to provide you with information on the collection, use and disclosure of your personal data by the Company and your rights with respect to those personal data. In this document, “we”, “us” and “our” refer to the Company and its affiliates and delegates.
This document may be amended from time to time and the company will send you the latest updates to you via email correspondence that you have provided to us. The changes will take effect as soon as the revised version is made to you.
Your Personal Data
The Company might process the following personal data about you:
Information provided to the Company by you:
This might include your name and address (including proofs of name and address), contact details, date of birth, gender, nationality, photograph, signature, copies of identity documents, occupational history, job title, income, assets, other financial information, bank details, investment history, tax residency and tax identification information. Such information might be provided in an application form or in other documents (as part of an application process or at other times), face-to-face, by telephone, by email or otherwise.
Information that the Company collects or generates:
This might include information relating to your (or an applicant’s) investment in the funds managed by Company, emails (and related data), call recordings and website usage data.
Information that the Company obtains from other sources:
This might include information obtained for the purpose of the Company’s know-your-client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-person checks, sanctions checks, among other things), information from government or public bodies, public websites and other public sources and information received from your advisers or from intermediaries.
Use of your Personal Data
The Company may collect, store and use your personal data for lawful purposes disclosed below:
to reflect your ownership of shares or units in funds managed by the Company (i.e. where this is necessary for the performance of the contract to purchase shares or units in the funds managed by the Company including without limitation the processing of redemption, conversion, transfer and additional subscription requests and the payment of distributions);
to discharge our anti-money laundering obligation to verify the identity of our customers (and, if applicable, their beneficial owners) or for prevention of fraud or for regulatory or tax reporting purposes or in response to legal requests from regulatory authorities (i.e. where this is necessary for compliance with a legal obligation to which we are subject); and/or
for direct marketing purposes (that is, us providing you with information on products and services) or for quality control, business and statistical analysis or for tracking fees and costs or for customer service, training and related purposes (i.e. where this is necessary for the purposes of the legitimate interests of us or third party and such legitimate interests are not overridden by your interests, fundamental rights or freedoms and provided that we are acting in a fair, transparent and accountable manner and have taken appropriate steps to prevent such activity having any unwarranted impact on you and also noting your right to object to such uses, as discussed below).
to send you any relevant information/policy updates that may be of interest to you using the email and/or postal address which you have provided;
The Company shall take reasonable measures to ensure that your personal data is only accessible by those with a need for access to fulfil the purposes set out above. Where the Company is entering into an engagement with third party pursuant to which data may be processed by that third party, we will seek to enter into an agreement with that third party setting out the respective obligations of each party and will seek to be reasonably satisfied that the third party has measures in place to protect data against unauthorized or accidental use, access, disclosure, damage, loss or destruction.
In the event that any such third party is outside the European Union and where the data being transferred would include personal data which would be protected under applicable Data Protection Legislations in the European Union, we will ensure we meet the relevant requirements of that Data Protection Legislation prior to carrying out any such transfer. This may include only transferring the data where we were satisfied that:
the non-European Union country has data protection laws similar to the laws in the European Union;
the recipient has agreed through contract to protect the information in the same data protection standards as the European Union;
we have obtained consent from relevant data subjects to the transfer; or
if transferred to the United States of America, the transfer will be to organizations that are part of the Privacy Shield.
Retention of Personal Data
How long we hold your personal data for will vary. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal data). After the retention period, we shall take appropriate steps to dispose of any records containing your personal data, to the extent this is operationally feasible and proportionate.
Your Data Protection Rights
Under the Data Protection Legislation, you have a right to request access to, and to request correction of, your personal data in our possession.
If you are located in the European Union, you also have the following rights our use of your personal data:
the right to data portability;
the right to restrict the use of your data;
the right to withdraw any consent given to the processing of your data (where applicable);
the right to receive information regarding any entities we disclose your data to;
the right to request that we erase your personal data in certain circumstances; and
the right to lodge a complaint with the Data Protection Commission
Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it. Also, where you choose not to provide any personal data or where any of the rights set out above are exercised to limit the processing of personal data by the Company, we may be unable to provide relevant services, or may have to restrict the services that can be provided, to you
The Company may charge a reasonable fee for processing a data access request.
New Zermatt Properties Contact Information
The Company is not required to designate a data protection officer. However, should you have any queries or wish to discuss your data protection rights with us, please contact info