​Categories of Personal Data

We process the following categories of personal data:

1. Contact information, such as first and last names, addresses, telephone numbers, email addresses, and countries of residence.

2. Personal characteristics, including gender, date of birth, place of birth, citizenship, and nationality.

3. Government-issued identifiers, such as passport numbers, identification cards, tax identification numbers, tax certificates, social insurance numbers, and FATCA/CRS information.

4. Financial information, including bank account details, transaction data, investment experience, objectives, income, source of wealth, and source of funds.

5. Personal information and powers of authorized representatives (if applicable).

6. Education, employment, and occupation information, such as CVs, professional memberships, job titles, responsibilities, academic and professional qualifications, and public positions held (for PEPs).

7. Certificates of clear criminal records, criminal convictions and offences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic and biometric data.
We process collected data subject to your documented consent and when processing is necessary for the establishment, exercise, or defense of legal claims relevant to us.
If your personal data changes during our business relationship, please promptly update the applicable details by contacting us. We may also periodically request confirmation of the accuracy of personal data and take reasonable steps to correct any inaccuracies.
Failure to provide requested personal data may impede our ability to fulfil our obligations under our business relationship and related agreements.

Purposes of Processing

We will process your personal data for the following purposes:

1. Meeting our obligations under our business relationship and related agreements, including fund management and licensing engagements.

2. Operating, managing, and controlling our business.

3. General business planning and organization.

4. Maintaining and developing our business relationships with you.

5. Carrying out surveys and direct marketing, including via our website.

6. Management, planning, and organization at work.

7. Compliance with legal and regulatory requirements, including but not limited to the Alternative Investment Fund Managers Law of 2013 (L.56(I)/2013 as amended), the Money Laundering and Terrorist Financing Law of 2007 (L.188(I)/2007 as amended), Common Reporting Standard (CRS), Foreign Account Tax Compliance Act (FATCA), EU, UN, and US sanctions, and relevant Directives and Circulars issued by any competent authority or professional body (where applicable) of which we are a member and/or are licensed under (e.g. the Cyprus Securities and Exchange Commission).

Collection of Personal Data

We collect personal data from you through the following methods and channels:

1. Application Forms – through the completion of application forms to invest in our managed AIFs, open an account with us, or apply for employment.

2. Online Portals – through the submission of data through secure online portals used for managing investor accounts, processing transactions, or accessing AIF-related information.

3. Email Correspondence – through email communications containing inquiries, instructions, or documents containing personal information.

4. Phone Calls - during phone conversations.

5. Meetings and Interviews – during face-to-face meetings, presentations, interviews or other events.

6. Surveys – through surveys that are distributed by us for collecting feedback from clients, investors and dirctors.

7. Questionnaires – through the completion of questionnaires issued by us or by the Cyprus Securities and Exchange Commission for the purposes of assessing competency and good repute.

8. Transaction Records – during the facilitation of financial transactions and investments.

9. Third-Party Sources – through the use of third-party sources, such as credit agencies or screening platforms, for due diligence, background checks, or credit assessments.

10. Publicly Available Information – through accessing public records or news articles.

11. AIF Service Providers – through accessing data collected from service providers (fund administrators, custodians etc.) who have access to data subjects' information as part of their contractual agreements.

Lawful Basis of Processing

We process your personal data based on the following lawful grounds:

1. Processing necessary for anti-money laundering and terrorist financing prevention practices (i.e., KYC requirements, AML checks).

2. Processing necessary for compliance with our reporting obligations (e.g. reporting to our regulator, CRS & FATCA reporting, statistical reporting etc.)

3. Processing necessary for the performance of agreements you have entered into with us.

4. Processing based on your consent (where applicable), unless you choose to withdraw consent at any time.

5. Processing necessary for our legitimate interests, including business and commercial interests, fraud prevention, and legal claims.

Disclosure of Personal Data

We may disclose your personal data to the following categories of recipients:

1. Other member companies, affiliated entities, or group companies.

2. Clients, contractors, business partners, and affiliates.

3. AIF auditors, fund administrators, custodians, depositaries, lawyers, tax advisors, consultants, accountants, investment advisors, credit reference and fraud prevention agencies and other professional advisors.

4. IT and data reporting service providers and other companies who assist us with the effective operation of our business by providing technological expertise, file storage and record management, logistic services and solutions and other subcontractors.

5. Persons acting on behalf of beneficial owners, shareholders, and stakeholders of our clients, investors, contractors, and business affiliates, being legal entities, including but not limited to payment recipients, beneficiaries, account nominees, correspondent and agent banks.

6. Banks, financial institutions, payment service providers, and insurance companies.

7. Public and regulatory authorities, such as the Cyprus Securities and Exchange Commission, the Unit for Combating Money Laundering (MOKAS), and criminal prosecution authorities.

When transferring personal data to countries outside the European Economic Area (EEA), we ensure adequate safeguards are in place, such as standard data protection clauses adopted by the European Commission or explicit consent.

Security

We implement appropriate technical and organizational measures to ensure data security, including data encryption, to prevent unauthorized processing, accidental loss, destruction, or damage of personal data.

Retention of Personal Data
 
We will process and store your personal data for as long as you have a commercial or business relationship with us and for up to five (5) years thereafter, unless otherwise required by competent authorities or applicable law. In certain cases, we may retain data for longer periods due to legal processes.

Use of Cookies

Our website uses cookies for analytics and remarketing features to track website usage and reach previous visitors. We collect and process personal data of website visitors, ensuring it is adequate and necessary for these purposes.

Collection of Personal Data

Visitors to our website have control over the personal data they share with us. We may automatically collect limited personal data through the use of cookies on our website. Please refer to the information below for more details.
We receive personal data, such as names, titles, company, email addresses, and investment interests, from website visitors. This typically happens when an individual subscribes to our periodic articles to stay up-to-date with our latest investment ideas and insights.
Visitors also have the option to send us emails through the website for the purposes of getting to know us or placing a complaint. These messages include the user’s full name, company and title, email address and any other additional information the user chooses to include in free text.
We kindly request that sensitive information (such as race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, sexual life or sexual orientation, and criminal records) not be provided to us when using our website. If you choose to provide sensitive information for any reason, doing so implies your explicit consent for us to collect and use that information.
 
Use of Personal Data
 
When a visitor provides us with personal data, we will use it for the purposes for which it was provided, as stated at the point of collection or as evident from the context of collection. Typically, personal data is collected for the following purposes:

1. Subscribing to our periodic articles.

2. Inquiring for further information.

3. Distributing requested reference materials.

4. Submitting CVs.

5.  Monitoring and enforcing compliance with our website’s terms and conditions.

6. Administrating and managing our website, including confirming and authenticating identify and preventing unauthorized access to restricted areas, premium content, or other services limited to registered users.

7. Aggregating data for website analytics and improvements.

Unless we are explicitly asked not to, we may also use your data to contact you with information about our business, services, events and other topics of interest to you.
If visitors choose to unsubscribe from mailing lists or any subscriptions, we will provide instructions on the appropriate webpage, in our communications, or the individual may contact us via email at support@argusmanager.com

Third-Party Services

We may employ third-party entities to facilitate our website, to perform website-related services, or to assist us in analyzing how our website is used. These third parties may have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Third-party links
 
Our website does not collect or compile personal data for dissemination or sale to outside parties for consumer marketing purposes, not do it hosts mailings on behalf of third parties.
Nevertheless, the website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.

Children

We understand the importance of protecting children's privacy, especially in an online environment. Our website is not intentionally designed for or directed at children, and all users should be above the age of majority in their local country.

Data Retention
 
Personal data collected via our website will be retained by us for as long as necessary.