Data privacy is of high importance for Kylin Prime Asset Management Ltd and we want to be open and transparent with our processing of your personal data and are committed to protecting your privacy. Kylin Prime Asset Management Ltd employs appropriate security measures and controls to minimise and mitigate any; unauthorised access, disclosure, destruction or alteration of your personal data.

We therefore have a policy setting out how your personal data will be processed and protected. This policy sets out our process in relation to the; collection, use and storage of digital content and that all data is held in accordance with the General Data Protection Regulation (EU 2016/679) (“GDPR”) and any applicable legal and regulatory requirements.

This policy applies to former, existing and potential clients as well as to any visitors of the company’s website.

Kylin Prime Asset Management Ltd is mainly responsible for the provision of investment and risk management services to Alternative Investment Firms (“AIFs”) under its management. We may also perform additional functions in the course of the management of AIFs including administration, marketing and services specifically related to the assets of an AIF such as valuation and reporting.

Kylin Prime Asset Management Ltd shall collect information necessary to fulfil its legal and regulatory obligations for the provision of our services.

Kylin Prime Asset Management Ltd will gather information and documentation to personally identify, contact or locate you, and may gather information from third parties and other sources which will help us to offer our services effectively.

Kylin Prime Asset Management Ltd collects and uses personal data on the basis that it is in its legitimate interests to do so, for example to keep records of transactions and to enhance the service provided to its customers.

Kylin Prime Asset Management Ltd will not collect any unnecessary personal data from you and will process your information in accordance with legal and regulatory requirements.

We may collect information about you in the following ways:

• From our website. We collect information you provide by filling in one of our online enquiry forms to request further services and a box you may tick consenting to the use of your details for marketing purposes. The information you give us may include your name, phone and e-mail address. You may withdraw this consent at any time by emailing us at dataprotectionkpam@kylinprime.com or writing to us using the information at the end of this notice.

• From our service. We may collect personal information about you from applications or forms you may complete, agreements you enter into with us or in the course of your establishing or maintaining a client relationship with us regarding an investment product or vehicle.

  • Personal information requested during the registration process such as your name, date and place of birth, citizenship, nationality, status, identification numbers and contact details including postal, residential and email address; Financial information such as your income, source of funds, investment objectives, debit card details, ongoing statements and other related information. This is to allow us to complete your transaction and also to provide confirmation of the transaction to you.

  • Further to this, we may be required to evaluate the appropriateness and suitability of the financial instruments/services we provide to you, and as such will collect information on your source of income, financial obligations, investment knowledge and experience, as well as your investment and risk attitude as they related to such financial instruments.

• Form recruitment applications. If you apply for a job with us you will provide us with personal information in connection with your application.

Each time you visit our site we will automatically collect the following information:

• Technical information. including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, browser plug-in types and versions, operating system and platform;

• Information about your visit. including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), traffic data and other communication data, the resources that you access and information derived from the cookies we place on your mobile device and computer.

• General information as provided. including; name, e-mail, phone number, postal address, age to demonstrate that you are eligible to engage with Kylin Prime Asset Management Ltd and any data where applying for a job with Kylin Prime Asset Management Ltd.

We may combine information and data from other websites we operate which offer similar or other services provided by Kylin Prime Asset Management Ltd or its subsidiaries or other third-party service providers. This data maybe shared between Kylin Prime Asset Management Ltd, its subsidiaries and third-party service providers, to include; business partners, sub-contractors, payment services, advertising networks, analytics providers, search information providers and credit reference agencies who are also obliged to adhere to GDPR.

We may be required under governing Anti Money Laundering legislation to perform background checks through legitimate third-party providers.

If you have applied for a job with us – We may receive personal information about you relevant to the job you have applied for, from background check providers, previous employers or employment agencies.

Your personal data is used for specific, explicit and legitimate purposes and only as required to provide quality service to you and to comply with applicable legislations. We may use the personal information we hold about you for the following purposes:

• To analyse data to enhance the services offered to you, as well as to provide tailored services or products, act as your CySEC authorised principal or otherwise conduct business with you.

• To send you marketing material you have requested to receive via our websites or information on other products and services offered by Kylin Prime Asset Management Ltd or other associated companies.

• To process your application for a job with us.

• To comply with our legal and regulatory obligations including verifying your identity and constructing economic and investment profiles.

• To establish, defend or exercise our legal rights or in connection with legal proceedings.

• To improve our; services, websites and mobile applications or create new ones.

We rely on the following legal grounds to process your information:

• Compliance with law or regulation – we may collect and use your personal information in order to comply with law and regulation.

• Contract performance – we may collect and use your personal information in order to enter into a contract with you or perform a contract with you.

• Legitimate business interests – we may collect and use your personal information in order to further our legitimate business interests such as improving our; services, websites and mobile applications or creating new ones.

• Consent – we will only use your personal information per legal and regulatory requirements, please see ‘What are your rights’ below.

• Any member of our group, being our ultimate holding company and any of its subsidiaries.

• Selected third parties, to include:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;

  • Regulatory authorities (such as the Cyprus Securities and Exchange Commission) and Ministry of Finance, should they require such disclosure on legal grounds.

  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.

The information that we collect from you is stored within the European Economic Area (“EEA”) but may also be transferred to and processed in a country outside of the EEA. Any such transfer of your personal data will be carried out in compliance with applicable laws.

We will only hold your information for as long as necessary. How long we hold your personal information for will vary and is dependent on:

• The purpose for which we have your personal information – we need to keep your personal information for as long as necessary to fulfil the purpose and with regard to any contractual obligations.

• Legal or regulatory obligations – we are obliged by law to maintain records for five years after the termination of a client relationship, or up to 7 years, upon request by the local competent authority.

• We have appropriate security measures in place to keep your personal information secure whilst we hold it.

If you ask us to remove you from our marketing list, we may keep your personal details on an “opted-out” list in order to ensure that we do not market to you again.

You have certain rights in respect of the information we hold relating to you:

• Right to access: You have the right to request information about the personal data we hold on you, the purposes the data is being processed and obtain a copy of it at any time. Upon request, information must be provided to you without delay and at the latest within one month of receipt. We are able to extend this by a further two months if the request is complex and numerous but will inform you accordingly.

• Right to portability: You have the right to obtain and reuse your personal data for your own purposes across different services. Whenever Kylin Prime Asset Management Ltd process your personal data by automated means based on your consent or based on an agreement you have the right to get a copy of your data transferred to you or to a nominated party. This only includes the personal data you have submitted to us.

• Right to rectification: You have the right to request rectification of your personal data if it is incorrect or incomplete.

• Right to be forgotten: You have the right to require us to delete your personal information in specific circumstances including: where it is no longer necessary in relation to the purpose for which it was collected/processed, when you withdraw consent, when you object to its processing and there is no overriding legitimate interest for continuing the processing, in order to comply with a legal obligation or if the data was unlawfully processed. There are some specific circumstances where the right to erasure does not apply.

• Right to restrict processing: In some circumstances, where you may not be entitled to require us to erase your personal information, you may be entitled to limit the purposes for which we can use your information.

• Right to withdraw your consent to processing: You have the right to withdraw the consent you have given us to allow us to process your personal information or to receive any materials from us.

• Right to object to direct marketing: You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes.

In order to exercise these rights, to request a Subject Access Request or if you have any concerns about our use of your personal information, please contact us at dataprotectionkpam@kylinprime.com or at the details in, ‘How to contact us.’ below.

You can also contact the Office of the Commissioner for Personal Data Protection in, which is the supervisory authority in the Republic of Cyprus for the implementation and enforcement of data protection law. Website: http://www.dataprotection.gov.cy, Address: 1 Iasonos str., 1082 Nicosia, P.O.Box 23378, 1682 Nicosia. Tel: +357 22818456, Fax: +357 22304565, Email: commissioner@dataprotection.gov.cy

Our website contains links to other websites. This privacy notice only applies to our website. When you use a link to another website you should read the privacy policy of that site.