Privacy

Privacy Policy

This Privacy Policy explains how Majedie Asset Management Limited and (where applicable) Majedie Asset Management (International) Investment Fund Company PLC each collects, uses and discloses the personal data you may provide, and your rights in relation to the personal data we hold.

In this Privacy Policy, “Majedie”, “us”, “we” and “our” refers to Majedie Asset Management Limited and/or (where applicable) Majedie Asset Management (International) Investment Fund Company PLC).

We may amend the Privacy Policy from time to time, including to reflect changes in law and in the way we process your personal data. This Privacy Policy will apply from 8 April 2021. It supersedes any previous version which you may have been provided with or have had access to.

Data Protection

Majedie Asset Management Limited will process your personal data as a data controller and is subject to the Data Protection Act 2018 (“DPA”).

Majedie Asset Management (International) Investment Fund Company PLC will process your personal data as a data controller and is subject to the EU Data Protection Directive 95/46/EC and the EU Privacy and Electronic Communications Directive 2002/58/EC, any amendments and replacement legislation including the EU General Data Protection Regulation (EU) 2016/679 (“GDPR”), European Commission decisions, binding EU and national guidance and all national implementing legislation (“Data Protection Legislation”).

Your Rights

To have access to, and copies of, your personal data;
To require rectification of your personal data, if it is incorrect;
To require us to erase your personal data;
To require Majedie not to send you marketing communications;
To require Majedie to restrict processing of your personal data;
To object to Majedie processing your personal data; and
To transfer your personal data to another data controller.

Please note that these rights are not absolute and we may be entitled to refuse requests where exceptions apply. More information on these rights and exceptions can be found at www.ico.org.uk or https://www.dataprotection.ie/.

What Information do we collect?

We may collect personal information in the following ways:

Under the DPA and Data Protection Legislation, you have the following rights:

From information you provide to us via our employees, telephone, email or other forms of electronic communication (e.g. Contact Us forms);
When you complete an application form into a Majedie fund;
From third parties, including your agents, advisers and service providers; and
From publicly available sources.

What categories of data do we collect?

This Privacy Policy applies to all individuals for whom we may hold personal data, including clients, investors in Majedie funds and employees. Depending on your relationship with Majedie, we may (where relevant) collect the following categories of personal data about you:

Name, address, email address, telephone number;
Date of birth, tax identification number, passport number or equivalent details;
Information about your employment, education, family and personal circumstances and interests;
Financial information, including, where relevant, bank account details; and
Information or background checks for anti-money laundering/client due diligence purposes and for employee vetting.

What is the purpose & basis of collection?

Majedie processes personal data to enable us to provide investment management services, to operate the Majedie funds, to promote our investment management services and the Majedie funds, to manage our business, including reporting to and communicating with regulatory, fiscal, law enforcement and other governmental bodies and maintain our own accounts and records, and to manage and support our employees. The processing of personal data will be necessary for our compliance with a legal obligation, for our legitimate interests, or for the performance of a contract to which you are a party.

How is the data used and who do we share it with?

Depending on your relationship with Majedie, we may use your personal data:

To provide our investment management services;
To operate and promote the Majedie funds;
To determine whether you may invest or continue to invest in the Majedie funds;
To perform our reporting obligations to and communicate with clients (e.g. via MajIQ);
To comply with our anti-money laundering and client due diligence obligations; and/or
To manage and support our employees.
Failure to provide us with personal data will prevent us from using your personal data as described above.