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Privacy Notice

  • Canaima Capital Management Limited ("Canaima") is committed to protecting your privacy.

    In accordance with the General Data Protection Regulation (679/2016/EU) (the "GDPR") and applicable Guernsey data protection legislation (in particular, the Data Protection (Bailiwick of Guernsey) Law, 2017) (collectively, "Data Protection Legislation"), this Notice sets out the basis on which any personal data (meaning any information about you which is personally identifiable) that you provide to Canaima will be processed by us.

    This policy includes the following information:

    • How we collect information
    • What type of information is collected
    • Why we collect your data
    • How long we will keep your data
    • Your rights
    • Disclosures to Data Processors and / or Third Parties
    • Failure to provide personal data
    • Changes to this policy

    1. How we collect information

    We collect personal information from you:

    1. from information which you, your authorised representative, Canaima Global Opportunities Fund PCC Limited (either acting on its own behalf or through its service providers) (the "Fund") gives to us within our capacity as Investment Manager to the Fund.
      This includes, but is not limited to:
      • information set out in any subscription agreement with the Fund;
      • such other forms and documents as we may request that are completed in relation to the administration/management of any investment in the Fund; and
      • forms and documents we may request as appointed Investment Manager;
    2. when you communicate with us in writing, electronically, face to face or by telephone to receive information and communications from Canaima in the normal course of business.

    2. What type of information is collected

    The personal information we collect may include, amongst other information; name, telephone, email address, IP address, mailing address, employment details including job title and function and where applicable, tax number and ID number.

    3. Why we collect your Personal data

    Canaima holds and processes your personal data on the following lawful grounds:

    1. to comply with our contractual duties under the terms of the Investment Management Agreement between Canaima and the Fund, and all supplemental agreements thereto:
    2. to comply with the legal and regulatory obligations of Canaima, the Fund and the Administrator, including, without limitation, in collecting, processing and storing “customer due diligence”, source of funds information and verification data under applicable anti-money laundering and terrorist financing laws and regulations;
    3. where we have obtained your consent; or
    4. to pursue the legitimate interests of Canaima, the Fund or the Administrator, including:
      1. In relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, and tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with the Administrator's anti-money laundering procedures;
      2. Carrying out statistical analysis and market research;
      3. Recording, maintaining, storing and using recordings of telephone calls that you make to and receive from Canaima, the Fund and the Administrator, and their delegates or duly appointed agents and any of their respective related, associated or affiliated companies: (i) for the processing and verification of instructions, (ii) for investigation and fraud prevention purposes, (iii) for crime detection, prevention, investigation and prosecution, (iv) to enable Canaima, the Fund, the Administrator and/or their affiliates to enforce their legal rights or defend legal proceedings, themselves or through third parties to whom they delegate such responsibilities or rights, (v) in order to comply with any legal obligation imposed on Canaima, (vi) to pursue Canaima's legitimate interests in relation to such matters, or (vii) where the processing is in the public interest;
      4. To monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of Canaima or the Administrator to improve their service delivery;
      5. To disclose information to other third parties such as service providers of Canaima, auditors, regulatory authorities and technology providers; and
      6. To retain anti-money laundering and other records of individuals to assist with the subsequent screening of them by the Administrator, including in relation to other funds or clients of the Administrator in pursuance of the Administrator's and its clients' legitimate interests.
    Please note that where personal data is processed for purposes of legitimate interests, you have a right to object to such processing. Canaima will no longer process the personal data solely for this purpose unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

    4. How long we will keep your data

    We will hold your personal information on our systems for as long as is necessary for the relevant activity.

    Personal information held that is required for regulatory purposes will be held for the life of the relationship and a further period of 7 years after the termination of the relationship.

    Whereby consent has been relied on to process your data, you have the right to withdraw consent at any time after which your data will be erased. To withdraw your consent, please contact info@canaimacapital.com

    5. Your rights

    Please note that you have the following rights under the Data Protection Legislation in relation to your personal information. In each case, the exercise of these rights is subject to the provisions of the Data Protection Legislation.

    You have the right to:

    1. Access all personal information supplied to Canaima to rectify any inaccuracies on the information held.
    2. Have any incomplete personal data completed.
    3. Request the erasure of your personal data.
    4. Lodge a complaint with the supervisory authority (Office of the Data Protection Authority, Guernsey - https://odpa.gg/).
    5. You have a right to request that your personal information is erased (in certain specific circumstances), subject to the restrictions and periods detailed in clause 4.
    6. You have a right to restrict processing (in certain specific circumstances).
    7. You have a right to data portability (in certain specific circumstances).
    8. You also have the right to object to processing where personal data is being processed for marketing purposes.

    6. Disclosures to Data Processors and / or Third Parties

    Canaima may disclose your personal information as follows:

    1. To its service providers, including the Administrator and their affiliates, and other affiliated or third party service providers engaged by the Fund or the Administrator in order to process personal data for the above mentioned purposes. These data processors will handle your information in accordance with applicable Data Protection Legislation; and
    2. To competent authorities (including tax authorities), courts and bodies as required by law or requested or to affiliates for internal investigations and reporting.

    The disclosure of personal information to the third parties set out above may involve the transfer of data to the USA and other jurisdictions outside the European Economic Area (EEA) in accordance with the requirements of the Data Protection Legislation. Such countries may not have the same data protection laws as your jurisdiction. Canaima has authorised the Administrator as its agent to put in place Standard Contractual Clauses with relevant parties to whom personal data will be transferred. Please contact the Administrator for copies of any Standard Contractual Clauses that may have been entered into on behalf of Canaima.

    Canaima and the Administrator and their appointed data processors engage in screening for the purposes of complying with anti-money laundering and countering terrorist financing legislation and with UN, EU and other applicable sanctions regimes. Personal information about you may be used to complete such screening checks.

    7. Failure to provide personal data

    The provision by you of personal data, as outlined in the section above titled "Why we collect your personal data" is required for us to accept your subscription application and manage and administer your holdings, and so that we can comply with the legal, regulatory and tax requirements referenced above. Where you fail to provide such personal data we will not be able to accept your application or to the extent that we do accept your application and the required personal data is not provided within the specified timeframe we may be required to discontinue our business relationship with you.

    8. Changes to this policy

    Please let us know if any of your personal data changes as soon as possible. It is the responsibility of individuals and authorised representatives providing their personal data to ensure that this information remains accurate.

    Amendments and updates to this Notice may be made from time-to-time. Any revisions will be posted on this page and where appropriate, notified to you by email, so you will always be aware of what information we collect and how we use that information. Please review this page regularly so that you are aware of any changes.

    If you have any questions regarding our Privacy Policy, please write to:

    Canaima Capital Management Limited

    Po Box 156, (Ground Floor) Dorey Court
    Admiral Park, St Peter Port GY1 4EU
    Guernsey
    +44 1481 702408

    Or email your query to info@canaimacapital.com

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