The following disclosure explains what personal information we collect, what we do with that information and the steps we have put in place to protect the personal information you have entrusted to us. For the purposes of European data protection laws, we are the data controller of your personal information.
Information We Collect
From time to time, we gain access to your personal information through:
- Our interaction with you on the telephone, in person or through e-mail
- Subscription applications or other forms you complete
- Transactions in your accounts or on your behalf
- Our website or the websites of our affiliated companies
- Informational tools we may make available to you
- Transactions in your accounts or on your behalf
- Third parties with whom we deal, such as consumer-reporting agencies, to verify information (including name, nationality, residential address, aliases, any criminal record findings and credit-rating) we receive from you and your credit worthiness
The provision of personal information by you may be necessary in order for us to provide you with the requested services (including tasks such as, servicing accounts, processing transactions, maintaining investor accounts and communicating with investors), for the performance of any contractual relationship with you and for the other purposes as set out in this Notice where in our legitimate interests. We may also process your personal information where we are under a legal or regulatory obligation to do so. If you do not provide us with the required personal information, we may not be able to provide you with the relevant services.
Information We Disclose
Subject to legal, regulatory or other governmental requirements, it is our policy not to disclose any of your personal information to third parties without your consent, unless those parties are providing services or support to us or the funds we manage and have agreed to keep your personal information confidential. Examples of these parties include, but are not limited to, the Administrator, auditors and legal counsel and/or affiliates thereof. Even if you cease to transact business with us, we will continue to apply the same protections to your personal information as we did when you were an active client.
Protecting Your Information
Markel CATCo Investment Management Ltd. protects your personal information from access by third parties by maintaining physical, electronic and procedural safeguards. Investor data will be held for a period of seven years following the investor’s full and final redemption.
Transfer of Personal Data outside of the EEA
If you are located in the European Economic Area (“EEA”) we will disclose your personal information to recipients located in countries outside of the EEA, including in Bermuda and the U.S., which may not have data privacy laws equivalent to those in the EEA as we deem advisable (i) if called upon to establish the availability under any applicable law of an exemption from registration of the Shares; (ii) if the such personal information is relevant to any issue in any action, suit or proceeding to which we are a party or by which it is or may be bound or upon request of a governmental or self-regulatory body with jurisdiction over us; (iii) in connection with applicable anti-money laundering laws; (iv) if needed by an affiliate as part of an audit; or (v) if needed by our service providers, such as, administrator, auditors and legal counsel and/or affiliates thereof. In such a case, we will take all necessary steps to ensure the safety of the personal information in accordance with applicable data protection laws. By signing the Subscription Agreement, you hereby consent to the transfer of your personal information to us and the other recipients described in this Notice that may be located in countries outside of the EEA. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Rights of Investors
If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to you, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with their local data protection authority in the EEA.
Changes
This Privacy Notice is dated 17 May 2018. We may update this Privacy Policy at any time if required in order to reflect changes in our data processing practices, in personal data protection laws or otherwise. For substantial changes to this Privacy Policy, we will use reasonable endeavors to provide notice thereof.
Contact
Questions related to this Privacy Policy or requests to excecise the Rights of Investors as outlined within this Privacy Policy can be directed to investor@markelcatco.com.