Last updated: 25 May 2018
Coupland Cardiff Asset Management ("CCAM") respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice only applies to personal information that we collect through our website at https://couplandcardiff.com ("Website").
The data controller of your personal information is in most circumstances Coupland Cardiff Asset Management LLP, a limited liability partnership registered at 31-32 St James Street, 5th Floor, London SW1A 1HD with company number OC310342.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
What does CCAM do?
CCAM is a specialist fund management group, headquartered in the United Kingdom and with a presence in Singapore. Our services involve managing capacity constrained, performance focused funds in the Asian and Japanese markets.
For more information about us, please see the "About CCAM" section of our Website at https://www.couplandcardiff.com/about-ccam.
What personal information does CCAM collect and why?
The personal information that we may collect about you broadly falls into the following categories:
- Information that you provide voluntarily Our "Contact" page allows you to provide information to us including your name and email address. You may also choose to include personal information in the message you submit to us.
- Information that we collect automatically When you visit our Website, we will collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including whether you have visited before, the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading "Cookies and similar tracking technology" below.
Who does CCAM share my personal information with?
We may disclose your personal information to the following categories of recipients: (i) Coupland Cardiff Management (Singapore) pte Limited, the Investment Adviser to the CC Asian Evolution Fund, where your enquiry relates to this subfund. More information about these disclosures can be found at "International data transfers" below; (ii) to third party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice; (iii) to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (for example: (a) as a matter of applicable law or regulation; or (b) to exercise, establish or defend our legal rights); (iv) to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business; or (v) other persons where we have a legitimate interest in doing so and we are otherwise permitted to do so by law.
Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests (such as our interest in providing our website) and those legitimate interests are not overridden by your rights; or where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Cookies and similar tracking technology
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Specifically, our Website servers are located in the EU and the US. We may transfer your personal data to our entity in Singapore, Coupland Cardiff Management (Singapore) pte Limited. Whenever we transfer your personal data out of the European Economic Area we ensure there are appropriate safeguards to require that it will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers to Coupland Cardiff Management (Singapore) pte Limited. Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
If EU privacy rules apply, you have the following rights in relation to your personal information: (i) to access, correct, update or request deletion of it; (ii) to object to processing of your personal information; (iii) to ask us to restrict processing of it; (iv) to request portability of it; and (v) to opt-out of marketing communications. You can exercise these rights by contacting us using the contact details provided below.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
If you have any concerns or complaints about the way we use your information, please contact us using the contact details at the bottom of this Privacy Notice and we will do our best to resolve the issue.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the "last updated" date displayed at the top of this Privacy Notice.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact us using the following details: