Privacy Statement
This Privacy Statement sets out the use of Personal Data collected through our website’s enquiry forms.
Who we are
For the purposes of this Privacy Statement, the data controller is Merlin Fidelis Asset Management Limited with its address at 1701, 17/F, St. George's Building, 2 Ice House Street, Central, Hong Kong.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority or to the data protection regulator in the country where you live or work for data protection issues. We would however appreciate the chance to deal with your concerns before you approach the relevant regulatory bodies, so please contact us in the first instance.
What types of information do we use?
We may not use “Your Personal Data” (which means any information about you from which you can be identified, including but not limited to name, address, telephone numbers, facsimile numbers and e-mail address) for direct marketing purposes unless we have received your consent for such use. You consent when you contact us (including, submit a request through our website), directing us to provide information about our products and services. You may request us to remove you from direct marketing at any time by emailing or writing to us.
How we will use your personal information?
If you consent, Your Personal Data may be used in direct marketing of one or more of the following products / services: (i) collective investment schemes managed, advised, distributed or promoted by us, (ii) asset management, investment advisory, wealth management or any other investment related services, (iii) other investment opportunities, and (iv) any other financial or investment products or services. Such direct marketing may be by telephone, facsimile, e-mail, or post. We will not sell, distribute or lease Your Personal Data to third parties.
Storing your information
As a financial services provider, we need to comply with the EU GPDR, the UK GDPR and Hong Kong’s Personal Data (Privacy) Ordinance (PAPO). These regulations mandate the retention of certain records, including personal data, for specified periods. The duration of retention depends on the purpose for which the data was collected and applicable legal or regulatory requirements.
When determining retention periods, we consider the nature, sensitivity, and volume of personal data, its intended use, and the potential risks of unauthorized access or disclosure. We regularly review our data retention practices and securely dispose of records that are no longer needed or upon request, where appropriate.
Your Personal Data may be transferred and stored outside the UK or EEA, including in jurisdictions that may not offer the same level of data protection. In such cases, we ensure appropriate safeguards are in place and that transfers comply with relevant legal requirements.
For more information about how your data is protected during international transfers, please contact us.
Your rights
If we reasonably need you to clarify your request or confirm your identity, we may pause the statutory time limits (“stop the clock”) until we receive the information needed.
You are provided with a number of different rights under the data protection laws in relation to your personal information. These allow you:
- To access Your Personal Data;
- To request we correct Your Personal Data;
- To request that we erase Your Personal Data;
- To object to the processing of Your Personal Data;
- To request a restriction in the processing of Your Personal Data;
- To request a transfer of Your Personal Data;
- To complain to the data protection regulator in the country where you live or work
- To withdraw your consent.
If you wish to exercise any of these rights and/or ask for information concerning our policies and practices and the kinds of Your Personal Data held by us are to be addressed in writing to:
Data Protection Officer: info@merlinfidelis.com
Please note that you will not have to pay a fee to access Your Personal Data or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.
Security
We have put in place appropriate security measures to protect Your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required to do so.