Old Compton Holdings
corporate profile

DATA PRIVACY NOTICE

  1. This data privacy Notice (“Notice”) is issued and provided by each of the following entities (together “Old Compton Holdings”, “we”, “us” or “our”):

Old Compton Holdings Ltd

  1. The Notice is addressed to external individuals, professionals, and legal entities (collectively referred to as “you” or “your”) with whom we may interact, or may have interacted, in the course of our business, including any person with whom we or one of our investment companies (“Company”) has entered into a contractual relationship.

III. By means of this Notice, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process in accordance with the EU General Data Protection Regulation and/or other non-EU laws and regulations, as applicable (“Data Protection Legislation”). The Data Protection Legislation governs the meaning of the terms used in this Notice.

  1. When handling your data, we may act as data controller and/or data processor, as the case may be, in accordance with the Data Protection Legislation, depending on the circumstances in which personal information is collected, held or used. The data collection and processing may be in hard copy or through electronic instruments. The servers where your personal data are stored are located  in Mauritius.
  2. We may collect, store and process personal data received as part of the business relationship at any stage of the same relationship. Where your data are provided for investment purpose, we as data controller may directly (or through a third-party service provider) process your personal information. If you are an entity, we may process the personal information of your beneficial owner(s), employees, directors, officers and you shall make sure that these persons are properly informed of this Notice.
  3. Personal data may include: (i) personal identification information (e.g. name, date of birth, nationality, addresses, telephone number, ID details, signature samples, social security number); (ii) identification data provided by public authorities (e.g. tax and passport numbers); (iii) personal distinguishing marks (e.g. video or voice recordings); (iv) information surrounding life areas (e.g. professional activity, hobbies, family members); (v) financial information (e.g. investment profiles including preferences, creditworthiness data, origin of wealth and assets); (vi) communications (e.g. e-mail correspondence). You are responsible for ensuring that any personal data that you send to us are complete, updated, correct and sent securely. From time to time we may ask you to confirm the accuracy of personal data.

VII. The purposes of the processing include:

– the establishment of the business relationship (e.g. onboarding and disinvestments, compliance procedure, liaison with public authorities and service providers);

– the exercise of the rights and the fulfilment of both contract obligations (including implementation of pre-contractual measures) and legal obligations (e.g. reporting to tax authorities);

– maintaining and updating your data;

– marketing and promotional activities;

– notification regarding changes to our service offers or business;

– monitoring and improving the quality of our services;

– quality assurance and training purposes.

VIII. Personal data may be disclosed to: (i) any of our affiliated entities including their respective directors, officers, employees, agents, and service providers; (ii) any public or accredited authorities; any third parties processor and in general any relevant parties to the extent necessary for the establishment, exercise or defence of legal rights or contractual obligations; (iii) any relevant parties for the purpose of prevention and detection of crimes; (iv) any relevant parties in the event that we sell or transfer all or any relevant portion of our business or assets.

  1. In accordance with and to the extent permitted by the Data Protection Legislation, every data subject shall have the following rights:

– Request access to any personal data we hold about you, along with information regarding its nature, processing, and disclosure;

– Request rectification of your personal data if it is inaccurate or incomplete;

– Request erasure of your personal data (“right to be forgotten”), where applicable;

– Restrict further collection of personal data beyond what has already been gathered;

– Obtain and reuse your personal data, and transfer it to another controller (“data portability”);

– Restrict processing of your personal data under certain conditions;

– Withdraw your consent at any time, where processing is based on consent;

– Be informed without undue delay in the event of a personal data breach that may affect your rights and freedoms;

– Lodge a complaint with a supervisory authority regarding the processing of your personal data.

Notwithstanding the foregoing, we may exercise rights in connection with compelling legitimate grounds which override the data subject’s interest or where the data subject’s rights are not feasible, e.g. if data must be retained for the defense of legal claims or for compliance with applicable laws.

For any request, please contact us at TERMS OF USE OF THE WEBSITE

 

INTRODUCTION

  1. The terms of use hereunder (“Terms of Use”) are addressed to any person (collectively referred to as “you” or “your”) that may access, or may have accessed, to any data or information (each and/or collectively, as applicable, hereinafter referred to as “Information”) presented on this website (“Website”).

The Information is released by Old Compton Holdings Ltd, in respect of itself and/or any of its affiliated investment companies, as applicable (“Originator”).

  1. The Terms of Use contain important statements that govern access to and use of the Information, as well as any external information to which the Information may refer. By continuing to use the Website, you confirm that:

(i) you have fully read, understood, and accepted the Terms of Use;

(ii) you are permitted to access the Website and view the Information in accordance with all applicable laws and regulations applicable to you, including those of your home country;

(iii) you acknowledge that the Originator accepts only eligible investors in accordance with relevant offering terms and conditions; and

(iv) you represent and warrant that, if you intend to subscribe for shares in the Originator, there is no violation of any regulatory requirements that may restrict your eligibility to invest in the Originator.

OWNERSHIP OF THE INFORMATION

  1. The Website describes or features certain investment structures, services, or other data related to the business of the Originator. Any Information is the property of the Originator. Accordingly, no part of it may be reproduced or transmitted without the prior written consent of the Originator.
  2. The Originator reserves the right to unilaterally amend or cancel the Information including the Terms of Use at any time and without notice.

ACCURACY AND UPDATE OF INFORMATION

Any Information:

(a) is provided as of the date it is posted and may be changed at any time without notice;

(b) may no longer be accurate or complete when accessed by you, as the Originator does not undertake any obligation to update such information;

(c) may be based on data and information obtained from third-party sources; and

(d) has not been, and will not be, reviewed or approved by any governmental authority in any jurisdiction.

INVESTMENT RISK AND FORWARD-LOOKING STATEMENTS

Any Information may include projections or other forward-looking statements regarding future events or financial performance. These statements are only predictions, opinions, or estimates made on a general basis, and actual results may differ significantly. Any Information relating to future prospects may not be realized; and any Information relating to past performance may not be indicative of future results.

NO ADVICE

Any Information is provided for informational purposes only, with no obligation or liability on the part of the Originator. Any person who relies on such information does so entirely at their own risk. No information shall constitute investment, tax, legal, or any other form of advice. Before making any investment decision, you are strongly encouraged to seek independent legal, tax, and financial advice.

NO OFFER OR SOLICITATION

  1. Nothing on this website should be construed as an offer or solicitation of an offer to: (a) purchase, transfer, subscribe to or sell units in the Originator, other financial products mentioned on the Website and/or any investment; or (b) to engage in any other transaction. Furthermore, the information and services offered and described on this Website are not intended for distribution to any person or entity in any jurisdiction where such distribution would be contrary to applicable local laws or regulations or would subject the Originator to any registration requirements in such jurisdiction.

 

  1. By continuing in the Website, you confirm that (i) you have approached the Originator on an unsolicited basis and (ii) that any further access to this Website or separate approach to the Originator is at your initiative; (iii) the Originator’s staff may be invited to contact you to explain relevant products, services and requirements.

III. You should be aware you may not enjoy certain investor protections provided under the laws of your country of nationality, domicile or residence. It is your responsibility to inform yourself of the applicable laws and regulations and to ensure that your access and use of Information do not contravene any restrictions and to observe all applicable laws and regulations of any relevant jurisdiction.

RESTRICTION ON ACCESS

  1. Access to this Website is not permitted to any person in any jurisdiction (by way of domicile, residence, nationality, or otherwise) where the disclosure of or access to the Information would result in a violation of any applicable law or regulation. Persons or entities, in respect of whom such prohibitions apply, must not access or use this website.
  2. The Originator does not aim at accepting any contact or relation with any person – either corporate or individual – that is citizen, domiciled and/or resident of the United States of America or is organized, incorporated and/or registered under the laws of the United States of America (“USA Person”). The Website is reserved exclusively for persons that are not USA Persons and should not be accessed by any USA Person.

NO LIABILITY

Any obligations or liabilities by the Originator are subject to agreement as set out thereunder. In no event shall the Originator be liable to any person for any losses or damages of whatever kind or nature arising out of any access to and use of the Information. By continuing in the Website, you agree to hold harmless the Originator from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of the Information.

CONTACTS

If you have any queries, please contact the Originator at the contact details below:

info@oldcomptonholdings.com

GOVERNING LAW AND JURISDICTION

Any dispute arising from the use of the Website is subject to the laws of the jurisdiction where the Originator is registered and domiciled. The courts of the sale jurisdiction shall have exclusive jurisdiction to hear any claims in connection with the same dispute.

MISCELLANEA

  1. If any provision hereunder, or any part thereof, is held to be illegal, invalid, void, or unenforceable under applicable law, that provision or part shall be deemed not to form part of the Terms of Use. The legality, validity, and enforceability of the remaining provisions shall not be affected.
  2. Words used in the Terms of Use, where the context permits, shall be deemed to include the plural or singular as appropriate.

III. No information, whether oral or written, obtained by you through or from any Information or from any contact or exchange with the Originator’s staff, agents or consultants shall affect the validity or enforceability of this Terms of Use.

 

  1. By signing an agreement with us or approaching us or the Company for the establishment of the business relationship, you represent and warrant that: (i) you have provided all necessary Notices and obtained any required consents (including consents by any relevant data subject) for the lawful cross-border transfer of personal data to us, our affiliated companies, service providers and contractual partners for the whole duration and purpose of the business relationship; (ii) you will assist us with responding to data subject requests and with compliance obligations relating to security, breach notifications, data protection impact assessments, and consultations with supervisory authorities; (iii) you will notify us without delay on becoming aware of any personal data breach that may impact the business of the Company.
  2. We reserve the right to amend this policy at any time. The examples provided herein are illustrative and not exhaustive. You may have additional rights under applicable Data Protection Legislation. This notice is not intended to constitute legal advice and should not be relied upon as such. We recommend consulting a qualified professional to understand your rights under the relevant Data Protection Legislation.