At AlphaWealth we take your privacy seriously and will take all such reasonable measures to protect it. This privacy policy (this “Privacy Policy“) is provided by Alpha Asset (Pty) Ltd (the “Investment Manager“), AlphaWealth (Pty) Ltd (the “Investment Advisor“). The aforementioned entities and any of their affiliates, will collectively be referred to as the “Alpha Group“.  All Alpha Group Funds will collectively be referred to as the “Funds”. The Alpha Group and the Funds collectively be referred to as “we” or “us”. This Privacy Policy sets forth the policies of the Alpha Group and the Funds for the collection, use, storage, sharing, disclosure (collectively, “processing“) and protection of personal data relating to current, prospective and former clients of us. This Privacy Policy is being provided in accordance with the requirements of data privacy laws, including the EU General Data Protection Regulation 2016/679 (“GDPR“), the U.S. Gramm-Leach-Bliley Act of 1999, as amended, and any other laws relating to privacy or the processing of personal data and any statutory instrument, order, rule or regulation implemented thereunder, each as applicable to us (collectively, “Data Protection Law“). References to “you” or “investor” in this Privacy Policy means any investor who is an individual, or any individual connected with an investor who is a legal person (each such individual being referred to as, a “data subject“), as applicable.

We commit to treating your personal information strictly confidential and will take appropriate technical and organizational measures to ensure that your personal information is kept secure and protected against unauthorized or unlawful processing, accidental loss, destruction and damage, alteration, disclosure or access.

Personal data types we may collect and use

We maintain a CRM system that holds information that prospective, current and past clients, and investors provide us. The categories of personal data we may collect include names, residential addresses or other contact details, signature, nationality, place of birth, tax identification number, date of birth, place of birth, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds details, as well as other sensitive information.  We also collect, and store information provided when subscribing to our newsletters, when inquiring for information or subscription details, and as well as any relevant communication between us and investors (e.g. emails, meeting notes, etc.).

Using your personal data: the legal basis and purposes

We are entitled to process your personal data for the purposes of administering the relationship between you and us (including communications and reporting), direct marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities with competent jurisdiction over our business). Your personal data will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so. We also may receive your personal information from third parties or other sources, such as our affiliates, the administrator of the Funds or publicly accessible sources, such as the internet.  Where personal data is required to satisfy a statutory obligation (such as compliance with applicable anti-money laundering or sanctions requirements, as well as court orders) or a contractual requirement, failure to provide such information may result in your subscription in the Funds being rejected or forcibly redeemed. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How Alpha may share your personal data

We are entitled to disclose personal information about you to our affiliates or third parties, including the administrator, the prime broker and custodians of any of the Funds, for our everyday business purposes, such as to facilitate transactions, maintain your account(s) or respond to court orders and legal investigations. It may also be necessary, under anti-money laundering and similar laws, to disclose information about the Funds’ investors in order to accept subscriptions from them or to facilitate the establishment of trading relationships for the Funds with executing brokers or other trading counterparties. We are entitled to also release information about you if you direct us to do so.  We are entitled to share your personal information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us as described below (see “Who to contact about this Privacy Policy“). We are entitled to also disclose personal information about your transactions and experiences with us to our affiliates for their everyday business purposes. If you are a new client or investor, we may begin sharing your information 30 days from the date we have sent this Privacy Policy to you. When you are no longer an Alpha Group client or investor, we may continue to share your personal information as described in this Privacy Policy. We are entitled to disclose personal information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by the Funds. Should your personal information change, please inform us and provide us with updates to your personal information as soon as reasonably possible to enable us to update your personal information (see “Who to contact about this Privacy Policy”).

Monitoring of communications

We are entitled to record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.  Retention periods and security measures: We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Law. Personal data will be retained for the duration of your tenor as a client, your investment with us and for a minimum period of five to seven years after a redemption of an investment from the Fund or liquidation of the Funds. We are entitled to retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us. To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with Data Protection Law. These measures include computer safeguards and secured files in buildings. We will notify you of any material personal data breaches affecting you in accordance with the requirements of Data Protection Law.

International transfers

Because of the international nature of the Alpha Group business, personal data may be transferred to countries outside the EEA (“Third Countries“), such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the Data Protection Law in the EEA. In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of the Data Protection Law, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries.

Your rights under Data Protection Law

You have certain rights under GDPR in relation to our processing of your personal data and these are, generally: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of direct marketing activities); (vi) where relevant, the right to request the portability; (vii) where your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. You should note that your right to be forgotten that applies in certain circumstances under GDPR is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above. You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. You should note that US state laws may give you additional rights to limit sharing.

Complaint process to a supervisory authority

A complaint in respect of the Investment Advisor may be made to the Information Commissioner’s Office in the United Kingdom.

Alpha contact with regards to the Privacy Policy

Please contact our Compliance Officer on +27 11 707 1340 or by writing to the following address,
Alphawealth (Pty) Ltd, Alpha House,
Ballywoods Office Park,
33 Ballyclare Drive,
Bryanston.

Updates to our Privacy Policy

We reserve the right to make changes to this Privacy Policy and any changes to this Privacy Policy will be posted accordingly. All changes will apply going forward and not on a retrospective basis.

For any questions about this Privacy Policy or requests with regards to the personal data we hold.  For more specific information or requests in relation to the processing of personal data by the administrator, the prime broker and custodians or any other service provider of the Funds, you may also contact the relevant service provider directly at the address specified in the directory section of the offering memorandum of the fund or by visiting their website.