Privacy Statement

Introduction

Protecting your personal information is important to us.  We have, therefore, created this statement in accordance with the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679 the “GDPR”). GDPR strengthens and unifies data protection across the European Union. It also applies to all organisations that hold or process the personal information of EU-based individuals.

The legislation is intended to ensure that all personal information held by organisations (including, for example, a work email address) which might allow you, as an individual, to be identified, is accurate and secure and there is no mis-use of personal information by that organisation.  

This document sets out how the ML Capital group (“ML Capital”) collects, uses and safeguards the personal information that you, as an individual, provide to us. 

This statement covers all communication with ML Capital, including users of ML Capital’s websites.

In this privacy statement:

 “you” or “your” refers to you as an individual and not to any legal entity (such as your employer) which you may be representing by viewing our websites or communicating with us

“our”, “ours”, “we” or “us” refers to ML Capital.

Please note, if you provide personal information relating to other individuals (for example contact details in a work context), you must either advise those individuals of the details of this statement or provide them with a link to this statement. 

By providing your information to ML Capital you consent to the collection and use of your personal information in the manner set out below. 

The privacy statement covers only ML Capital, it does not cover the privacy policies of other entities which may be accessible through, or linked to, any ML Capital website or communication.

We will not notify you separately of any changes or updates to this privacy statement, but instead will post them to this page. Any change or update will be effective immediately upon posting.

Should you have any questions on this statement, please email them to: investorrelations@mlcapital.com

 

Collection of personal data

When you visit an ML Capital website or contact an ML Capital entity, and when providing any services to you, ML Capital may collect personally identifiable information about you from information provided by you.  

This can include the following information relating to you: name, address (residential or corporate), geographical location, email address, contact details, corporate contact information, correspondence records. 

We may also obtain personal information on you from other public sources.

If you are an investor in a fund managed by a member of the ML Capital group, you will be asked for certain personal information to process the subscription and information required for regulatory purposes. These requirements and your rights in relation to the processing of this information will be separately explained in the fund prospectus and application form. 

 

Purposes of Processing and Legal basis for processing

Generally, ML Capital will use the personal information provided by you to:

  • Create an account allowing access to detailed information about the funds we manage
  • Facilitate the administration of a website account
  • Email updates relating to the funds which we manage (for example fund performance or factsheets)
  • Respond to queries or provide services to you
  • Maintain or update contact data about you or a third party (for example your employer) within ML Capital’s systems
  • Enable us to act on any agreement with you, your employer or any other relevant third party
  • Provide to any third parties that may host, maintain or manage services for ML Capital, solely to the extent necessary to fulfil their hosting, maintenance or service management functions.

We will never share your personal information with others for marketing purposes, unless you have given us your explicit permission to do so.  Where you have done so, we will only share your information with:

  • Those service providers that help us manage our marketing activities; or
  • With the co-sponsors of our events, for the purposes of facilitating those events.

Accordingly, you understand that we may use your personal information for the purposes as described above, provided that we are acting in a fair, transparent and accountable manner and that we have taken appropriate steps to prevent the activity having any unwarranted impact on you and also noting your right to object to such use, as discussed below. 

Should we wish to use your personal information for other purposes (including, if applicable, any purpose that requires your additional consent), we will contact you.

 

Recipients of Data and Transfer of Data

ML Capital may disclose personal information to:

  • Entities within the ML Capital group, service providers of the funds it manages (including Distributors and Investment Managers), its service providers and their respective affiliates engaged by ML Capital to process data for the above-mentioned purposes;
  • To regulatory authorities, courts and bodies as required by law or to service providers for internal investigations and reporting.

The disclosure of personal information to the third parties set out above may involve the transfer of data other jurisdictions outside the European Economic Area (“EEA”) which may include the United States. Any transmission of personal information by ML Capital or its service providers outside the EEA shall be in accordance with the conditions of the GDPR. These countries may not have the same data protection laws that apply in the EEA, but ML Capital will authorise its group entities or other service providers to transfer personal information to other countries only where standard contractual clauses or other safeguards permitted under the GDPR have been put in place with parties to whom personal information will be transferred.

ML Capital and its service providers apply appropriate information security measures designed to protect personal information in its or its service providers’ possession from unauthorised access by third parties or from any form of computer corruption.

 

Third party sites

Our communications may contain links to third party websites. As we do not control the information on these websites, you should review their privacy policies and cookies to learn about how that website may collect and use your personal information.

When accessing any third party sites that may be linked you will leave this website. These third party sites are not controlled or endorsed by ML Capital. ML Capital is not responsible for the contents, operation or security of such sites.

 

Retention period

ML Capital will retain personal information only for as long as required for the purposes set out above. Once the personal information is no longer required, we will take appropriate steps to dispose of any records containing your personal information, to the extent this is operationally feasible and proportionate. 

 

Data subject rights

Where ML Capital holds personal information, the owner of that information has the following rights, in certain circumstances, in relation to their personal information:

  • Right to access any personal data held
  • Right to have any inaccurate personal data rectified
  • Right to restrict the use of personal data
  • Right to request that personal data is erased
  • Right to object to the processing of personal data
  • Right to obtain a copy of any personal data held in electronic form (data portability)

ML Capital will notify you of any personal data breach affecting you that is likely to result in a high risk to your rights and freedoms.

You also have the right to lodge a complaint with the Office of the Data Protection Commissioner, or your local supervisory authority, if you consider that the processing of your personal information by us infringes the Data Protection Legislation.

If your personal information has changed or requires correcting, please let us know by emailing investorrelations@mlcapital.com so that we can update our records.

 

Opting out of receiving communications

ML Capital and its service providers from time to time send communications, such as fund performance information, manager factsheet, general ML Capital updates and event information. All such communications from us include an “unsubscribe” link which can be clicked should you no longer wish to receive these types of communication from us.  

Alternatively, you can send an email to investorrelations@mlcapital.com requesting to be removed from some of or all our mailing lists.

 

Personal data requests

Any questions about our use of your personal information should be directed to ML Capital at investorrelations@mlcapital.com

 

 

 

Cookie Policy

Introduction

A cookie is a small text file placed on your device that stores information about a user’s use of a website. Tracking technologies, such as cookies and local shared objects (sometimes called “Flash cookies”) may be used by this website. We use cookies for allowing the website to work and enhancing usability, as well as for providing information to us. The different types of cookie we use are outlined below:

“Session based”:This is a temporary cookie and, once you close out of the website, any information is no longer needed and is deleted. It is essential for parts of the website to operate and is used to allow the website to carry background information as you navigate between pages, allowing the website to provide you an efficient service. 

“Persistent”:This remains in the cookie file of your browser even after you log out of the website or close the browser. It enables a website to remember you the next time you visit the website and can remember your site settings preferences. You will be asked for your explicit consent before agreeing to the use of this function.

Given the nature of some cookies however, you may not be able to use all features of the website, or access secure areas, if these are disabled. 

For more information on cookies and why they are used, please visit: www.allaboutcookies.org.

 

How we use cookies

ML Capital websites use cookies in the following ways:     

  • Enabling us to provide you requested services, including, where those services are held in secure areas of our websites, by identifying and authenticating you
  • Remembering your user ID so that you do not have to input it every time you visit our websites
  • Measuring your use of our websites so that we can improve them, enhancing overall user experience
  • Measuring the effectiveness of our performance updates, factsheets, information campaigns and event invitations (we may also use cookies from third-parties to help us to do this)
  • Understanding when or if emails sent from or documents held on our websites have been opened and acted upon

Some of our cookies may collect and store your personal information. Protecting your personal data is important to us and we will ensure that all personal information collected by us is handled in accordance with our privacy statement.

 

Managing Cookies

You have the ability to change your internet browser settings to accept or reject cookies. To find out how to do this please either refer to the “Help” menu of your specific browser or visit www.allaboutcookies.org - Manage Cookies

If you do not wish to accept cookies from this website, please either disable them or leave this website. If cookies are disabled, however, it may mean that either you experience reduced functionality or may be prevented from using some, or all, of this site. 

 

Third party sites

Our communications may contain links to third party websites. As we do not control the information on these websites, you should review their privacy policies and cookies to learn about how that website may collect and use your personal information.

When accessing any third party sites that may be linked you will leave this website. These third party sites are not controlled or endorsed by ML Capital. ML Capital is not responsible for the contents, operation or security of such sites.