Privacy Notice

General Data Protection Regulations:

The General Data Protection Regulations (GDPR) is the new regulation being brought into the EU to introduce greater control over the use of personal data. The underlying principles of GDPR are similar to existing Data Protection legislation. However, the GDPR contains more specific requirements for the use and protection of personal data than existing legislation.

Under the GDPR, personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural personal is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

We are required to notify you with the following information regarding the processing of personal information relating to you.

Who we are:

ATG Fund Services Ltd and its subsidiaries and group companies (“ATG”) are a “data controller” of the personal information we hold for the purpose of the GDPR and may process your personal data.

ATG is an independent group of companies specialising in Administration and Management solutions for Investment Funds, Corporate Structures and Private Wealth clients.

We are in operation since 1998 from our head offices in Nicosia, Cyprus offering solution-driven services to international clients who set up or manager their structures through Cyprus.

Definitions:

Data Subject is a living individual to whom personal data relates.

Personal Data means any operation or set of operations which is performed on personal data or on sets of personal data.

Consent of the Data Subject means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes.

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Purpose of processing your data:

ATG will process your data for the following purposes:

In the performance of the contract we have entered with you;
It is in our legitimate interest to process your personal data;
When we collect and use certain special categories of personal data with your express consent; and
Where we need to comply with a legal obligation.

Information that we collect:

Personal data is defined in the GDPR as any information relating to an identified or identifiable natural person. The following non-exhaustive list includes the types of personal data that we may collect about you and, in some circumstances, your spouse, civil partner, partner or dependents:

full name, address and contact details;
date of birth;
gender;
marital (or relationship) status;
National Insurance Number / Tax Identification Number;
passport number;
details of bank account;
Your source of wealth.

Categories of personal data:

Information and documentation relating to your identity, location, family, employment background and financial details;
Recorded telephone calls;
We may obtain some of this information from your advisors or agents if we hold your permission to do so; and
Information may also be obtained from sources available in the public domain.

Telephone call recording:

ATG and its affiliates may have a legal obligation to record telephone calls in certain circumstances and use a secure telephone call logging software to record, store and archive those telephone calls. Therefore, please note that calls may be recorded for training, quality, and regulatory purposes.

Consequences of non-provision of your personal data:

ATG would not be able to continue with its contractual agreement with you.

Recipients of your personal data:

From time to time and if you instruct us to do so, we may share your data with:

Other ATG group companies and offices across the world;
Professional advisors such as lawyers, accountants, financial advisors;
Other financial institutions such as banks, insurance and investment companies;
Tax authorities and regulators for reporting purposes; and
Third party risk intelligence agencies for the purpose of KYC screening and due diligence.

We may disclose your personal information in some cases to governmental agencies or entities, regulatory authorities or other persons in line with any applicable law, regulations, court order or official request. For example, your data may be shared with these entities where ATG would be expected to cooperate in the event of a criminal investigation.

Will your data be transferred inside/outside of the EU?

Only in the circumstances described above.

How will it be protected whilst in transit and where can I obtain further details? Data will be encrypted and/or password protected.

Further details can be obtained from compliance@atgfunds.com

How long will the data be retained? In accordance with jurisdictional legislation.

Your rights:

To be informed about how we use your personal data;
To access your data;
To have your data rectified promptly if it is inaccurate or incomplete;
To have your data erased in specific circumstances;
To restrict processing;
To object to processing of your data;
To portability of your data so that you can obtain and reuse your data; and
To prevent automated decision making and profiling.

Withdrawing consent:

If you wish to withdraw your Consent to process data, you can do so in writing, but such a withdrawal may affect the way in which we deal with you and/or any related entities.

Please note that we are contractually obliged to retain certain information in accordance with legislation.

Complaints:

If you wish to make a complaint, please contact ATG’s DPO (compliance@atgfunds.com) or, if you prefer to complain to a higher authority, please contact your local data protection commissioner.

What about Cookies?

The ATG website utilizes cookies as a means of providing personalization features to our visitors. You can choose whether to accept cookies by changing the settings of your browser. Typically, by accessing the browser’s help feature you can obtain information on how to prevent your browser from accepting all cookies or to notify you when a cookie is being sent. If you choose not to accept these cookies, your experience at our website and other websites may be diminished and some features may not work as intended. To find out more about our Cookies Policy click here.

Hyperlinks from ATG to websites outside ATG:

There may be cases on our website when ATG provides hyperlinks to other locations or websites on the Internet. These hyperlinks lead to websites published or operated by third parties who are not affiliated with or in any way related to ATG. They have been included in our website to enhance your user experience and are presented for information purposes only. We endeavour to select reputable websites and sources of information for your convenience.

However, by providing hyperlinks to an external website or webpage, ATG shall not be deemed to endorse, recommend, approve, guarantee or introduce any third parties or the services/ products they provide on their websites, or to have any form of co-operation with such third parties and websites unless otherwise stated by ATG.

We are not in any way responsible for the content of any externally linked website or webpage. You use or follow these links at your own risk and ATG is not responsible for any damages or losses incurred or suffered by you arising out of or in connection with your use of the link. ATG is not a party to any contractual arrangements entered into between you and the provider of the external website unless otherwise expressly specified or agreed to by ATG.

Any links to websites that contain downloadable software are provided for your convenience only. Again we are not responsible for any difficulties you may encounter in downloading the software or for any consequences from your doing so. Please remember that the use of any software downloaded from the Internet may be governed by a licence agreement and your failure to observe the terms of such licence agreement may result in an infringement of intellectual property rights of the relevant software provider which we are not in any way responsible.

Please be mindful that when you click on a link and leave our website you will be subject to the terms of use and privacy policies of the other website that you are going to visit.