For onboarding purposes, personal data shall need to be provided from the prospective Client to the Company. This personal data shall be used solely for contact purposes or for the purposes of confirming the source of the initial receipt of moneys, and for the purpose of the depositing of dividends or redemptions. Information on Source of Funds shall be required for compliance with Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) requirements.
Personal data necessary for the depositing of the investment, including bank account numbers shall also be requested during the onboarding process. This data shall be used for the confirmation of identity of the Client and all potential UBOs (ultimate beneficial owners) as required by the law, in particular the Anti-Money Laundering Directives to ensure the legal provenance of funds.
Further personal data, including Tax Identification Number/GIIN and Country of Residence, shall be required in order to comply with tax reporting requirements under the Common Reporting Standards (CRS) and the Foreign Account Tax Compliance Act (FATCA). Data requested in these self-certification forms shall be kept internally, unless the Client’s tax residency status makes the information contained within reportable to the Client’s local tax authority in the case of CRS, or the United States Inland Revenue Service (IRS) in the case of FATCA.
Such personal data provided is gathered by the Company, and stored securely in our offices in Malta. This information may be shared on a cross-border basis with our Service Providers, for the purposes of the performance of the contract with the Client. All personal data is to be kept internally and not to be shared with third parties except when outlined above. The processing of this data shall only occur when either such is required for the performance of the contract with the Client, or to comply with its obligations under the law, including but not limited to complying with law enforcement or AML regulator requests. Personal data may also be used for the protection of the public interest or the Client’s vital interests, or those of any other person, or for the legitimate interests of the data controller. The latter must be backed up by proper justification for its use. In all other cases, the Client’s consent will be sought for each and every specific purpose not outlined above.
