SevenHills Investment Management Limited (the “Company”) is established under the laws of Malta with registered address at Suite 5, level 4, Portomaso Business Tower, Portomaso, St Julian’s, STJ 4011, Malta (“We”/”Us”/”Our”).
We are committed to respecting your privacy. If you wish to contact Us about Our privacy practices, please feel free to do so by post at the above registered address or by email at firstname.lastname@example.org. You may also wish to contact us by telephone on +356 21373709.
Please read this Privacy Notice carefully to understand our practices with respect to your Personal Data.
References to “Data Controller”, “Data Subject”, “Personal Data”, “Process”, “Processed”, “Processing”, “Data Protection Officer” and “Data Processor” in this policy have the meanings set out in, and will be interpreted in accordance with the applicable laws. “Applicable Laws” shall mean the relevant data protection and privacy laws, including but not limited to, the Data Protection Regulation (EU) 2016/679, and the Data Protection Act, Chapter 440 of the Laws of Malta and subsidiary legislation thereto, as may be amended from time to time.
We may update this Privacy Notice in Our sole discretion including as result of a change in Applicable Law or processing activities. Any such changes will be communicated to you prior to the commencement of the relevant processing activity.
2. What amounts to Personal Data?
The term “Personal Data” refers to all personally identifiable information about you, such as your name, surname and address, and includes all personal information which may be processed and that can be identified with you personally.
3. How do we collect Personal Data?
We are Data Controllers of your Personal Data and shall process your Personal Data for any purpose in connection with any mandate that you may have entered into with us to provide investment service that we are licensed to provide.
Generally, third parties, Our clients and business partners, may have provided your Personal Data to Us. However, in some instances, We may collect Personal Data about you from third party sources, such as online searches or from public registers. There may also be instances where you would have provided your Personal Data directly to Us.
We typically collect Personal Data and process it for the following purposes:
Irrespective of the manner that We have collected your Personal Data, We will only process such data for any purpose in connection with your mandate with us or, when requested by yourselves, in respect of your Investment in the funds we manage and/or purposes which are inherently related thereto, including the fulfilment of any legal or regulatory obligation imposed on Us.
4. Legal Bases of Processing Personal Data
The legal bases of processing your Personal Data are the following:
5. Recipients of Your Personal Data
We may share your Personal Data with third party recipients who are:
Unless specifically instructed and consented by you, we do not share your Personal Data with any entity located outside of the EU or EEA.
6. Automated Decision-Making and Profiling
Your Personal Data will not be used for any decision solely taken on the basis of automated decision-making processes, including profiling, without human intervention.
In the steps leading up to your investment in the Fund and during our relationship with you, we may collect information from you in order to, amongst others, comply with our obligations and/or for any other purpose connected the services provided to you. We may process such personal data on the basis of and/or pursuant to the performance of the mandate we have and/or the performance of our obligations at law. As stated, no automated-decision will result from Our use of such systems.
7. Data Retention
We retain your personal data exclusively for the period which is lawfully permissible to retain your personal data. Thereafter, your personal data shall be immediately and irrevocably destroyed.
If we have a contractual relationship with you, we typically retain your personal data for up to five (5) years from the end of Our contractual relationship on the basis of Our legitimate interests to protect ourselves from civil cases which you might institute against Us in relation to Our contractual relationship.
Invoices, credit notes and similar transactional documents or information will be kept by Us for up to nine (9) years from completion of the relevant transaction on the basis of legal obligations imposed on Us to retain such information.
We may have a legitimate interest to hold your data for longer periods such as when your data is required for exercising or defending legal claims.
Any personal data which We may hold on the basis of your consent shall be retained exclusively until when you withdraw your consent. As noted above, retention of data on the basis of your consent is only envisaged in case you apply for a job and wish that We hold your data for the purposes of being contacted by Us in respect of future job opening.
We will retain your Personal Data, when requested to assist with the compilation of any subscription forms, or other forms in relation to an investment in the funds we manage, until your investment is redeemed. Thereafter, your Personal Data shall be destroyed, unless we have a statutory obligation imposed on Us, a business need to retain the Personal Data, and/or require the Personal Data to exercise or defend legal claims.
8. Your Rights
For as long as We retain your Personal Data, you have certain rights in relation to your Personal Data including:
Please note that your rights in relation to your Personal Data are not absolute and we may not be able to entertain such a request if we are prevented from doing so in term of an applicable law.
You may exercise the rights indicated in this section by contacting Us at the details indicated above.
9. Keeping your data secure
We shall implement and maintain appropriate and sufficient technical and organisational security measures, taking into account the nature, scope, context and purposes of the processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to protect your personal data against any unauthorised accidental or unlawful destruction or loss, damage, alteration, disclosure or access to personal data transmitted, stored or otherwise processed and shall be solely responsible to implement such measures.
We shall ensure that our staff who process your data are aware of such technical and organisational security measures and we shall ensure that such staff are bound by a duty to keep your personal data confidential.
The technical and organisational security measures in this clause shall mean the particular security measures intended to protect your personal data in accordance with any privacy and data protection laws.
If you have any complaints regarding Our processing of your Personal Data, please note that you may contact Us on any of the details indicated above. You also have a right to lodge a complaint with the Office of the Information and data Protection Commissioner in Malta (www.idpc.gov.mt).
11. Where Your Provide Us with Personal Data Related to Third Party Data Subjects
If you are a company, intermediary or other corporate entity (including a bank or broker), and you provide Us with Personal Data of third party Data Subjects such as your employees, affiliates, service providers, underlying clients/customers, directors or any other individuals connected to your business, you shall be solely responsible to ensure that:
You will indemnify Us and shall render Us completely harmless on first written demand against all costs, damages or liability of whatsoever nature resulting from any claims or litigation (instituted or threatened) against Us as a result of your provision of said Personal Data to Us