The scope and purpose of this Privacy Notice

This Privacy Notice explains how Prosperity (“PCM”, “we”, “us”, “our”), collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with us as a client, prospective client,
acting for a client or being generally interested in our services and our publications in accordance with applicable data privacy laws and the General Data Protection Regulation (“GDPR”) which will become applicable as of 25 May 2018.


Should you have any questions about this Privacy Notice you can contact us
at info@prosperitycapital.com or at the address mentioned below.


We may provide supplemental privacy notices on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. Those supplemental notices should be read together with this Privacy Notice.

Prosperity

Prosperity Group consists of two investment managers: Prosperity Capital Management (UK) Limited and Prosperity Capital Management Limited.


You can contact us at Cavendish Square 6, London, W1G 0PD, United Kingdom or on info@prosperitycapital.com

Telephone: 0044 – 20 7299 6950

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would very much appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Personal Data

The term “Personal Data” as used in this Privacy Notice means any information about you from which you can be identified. Examples of personal data includes your name, contact details, bank account details and email addresses and it also includes pieces of information which can be used to identify you, either directly or indirectly, such as a cookie.

Personal Data does not include data from which you can no longer be identified such as anonymised aggregated data.

What information do we collect about you, how do we collect it and what do we use it for?

We collect information in the course of providing our financial services to you. The information which we collect, use and store about you are: your contact details (such as your address, email address and telephone number) and employment details such as your job title and company name and address.
Educational history (for classification), financial information (financial position and history) and documentary data (e.g. driver’s license or other forms of identification).

In addition, we collect the Personal Data you choose to provide to us, e.g. if you contact us by letter, telephone, email or any other means of electronic or personal communication. We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore
process your Personal Data only:

a) if you have consented to us doing so;
b) if we need it to perform the contract we have entered with you;
c) if we need it to comply with a legal obligation; or
d) if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms.

We will use your Personal Data to deliver information to you and/or the institution you work or act for. We may also use your Personal Data to inform you about our services.

We do not collect any special categories of personal data. This includes details about your race or ethnicity, religion, gender, political opinions or anything relating to your health.

Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Consequences of not providing some types of information

Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the services you asked for. In this case we may have to cancel the services but we will inform you about it in this case.

How do we collect information about you?

Typically, we will collect information from you when you contact us directly or provide information in order for us to provide our products and services. We collect information from you and about you in the following ways:

Through direct interactions when you give us your personal information by filling in forms or during correspondence with us. This includes when you:

• Subscribe to our services
• Meet with us in person
• Apply for our products and services
• Complete questionnaires

Through using our website when we collect information using cookies or similar technologies which tell us about your equipment, browsing actions and patterns.

How we will use your personal information

We only obtain, use and keep personal information where we need it for a specific purpose. We are only able to use your personal information if we have a proper legal reason or basis for doing so. This is called a legal basis and the regulations require that we have a legal basis so that your privacy is protected.

Most commonly we will use your information in the following ways:

• We have a contract with you
• We have a legal obligation
• We have asked for, and you have provided, consent to use your information. Please note that you can withdraw your consent at any time – this is part of how the law protects your interests.
• We, or a third party, have a legitimate interest in processing the information and your interests and fundamental right do not override those interest.

Our legitimate interest includes:

• Processing for direct marketing purposes
• To on-board you as a new client
• To meet our regulatory obligations to provide you with regular information about your investment
• To contact you about other services that you might be interested in.

Marketing

The two lawful bases that apply here are legitimate interests or consent. Prosperity deems to have and rely on legitimate interest. We need to comply with the Privacy in Electronic Communications Regulations which has specific requirements for consent for any electronic marketing (marketing calls, texts, emails, faxes, cookies or similar technologies).

We can use your personal information to send you communications if we believe we have a legitimate interest. We are required to make an assessment with regards to the benefits for us weighted against how appropriate it is to contact you in this way and whether it would be unfair to you. We believe that as a commercial enterprise we do have a legitimate interest in contacting you about our products and services and we will only do so if we decide it would be of interest or beneficial for you.

You are free to change your mind at any time by contacting us at info@prosperitycapital.com

Cookies

Cookies are small text files placed on your computer (or other devices where you access the internet) used to collect information on your activities online.
We do not store any personal information in our cookies.

Accuracy of information

It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.

Change of purpose, anonymisation

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis
which allows us to do so.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

With whom will we share your information?

When using your Personal Data for the purposes and on the legal basis described above we will not share this data with any other entities.

We do not transfer your Personal Data from the European Economic Area (EEA) to any third parties outside of the EEA and in a jurisdiction not being subject to an adequacy decision of the European Commission. We do share data within our corporate group.

Your rights in relation to your information

You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

• request access to your Personal Data (commonly known as a “data subject access request”) and
request certain information in relation to its processing;
• request rectification of your Personal Data;
• request the erasure of your Personal Data;
• request the restriction of processing of your Personal
Data;
• object to the processing of your Personal Data.
• To request a transfer of your information; and
• to withdraw your consent

If you want to exercise one of these rights please contact us at info@prosperitycapital.com.

Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may charge a reasonable fee if your request is clearly unfounded. We may also need to
seek further information from you to confirm your identity before we release any personal information.

How long will we retain your information?

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. In accordance with our retention policy data will be erased after 7 years after you
are no longer a client. We will ensure all records are safely destroyed if we no longer need to retain them. We review our retention periods for personal information on a regular basis. We will tell you if we change the retention period.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Upon expiry of the applicable retention period your Personal Data will be destroyed in accordance with applicable laws and regulations.

Security

We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required to do so.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our website.

Further information

If you have any concerns or require any further information, please do not hesitate to contact info@prosperitycapital.com