Privacy Policy

Your privacy is important to us. It's our policy to respect your privacy regarding any data we may collect from you across this website, and throughout your engagement with us.

About Your Personal Information

Prism Capital Management Limited (“PCM”) is committed to processing personal information (“PI”), including sensitive personal information (“SPI”) in line with applicable privacy and data protection laws (please note that not all privacy laws define SPI such as Hong Kong, Canada and Singapore). Our offices are located in countries with laws governing the processing of PI. “PCM”, “we”, “us” or “our” means PCM, and each of the direct or indirect subsidiaries or affiliates of PCM (the “PCM Group”). PCM’s entity you contract with are the controllers of your PI. However, if you are unsure as to the nature of the relationship, PCM will be the controller. References to “you” or “your” refers to individuals whose PI is processed by PCM Group, including clients with direct or indirect relationships; employees, contingent workers, officers, agents (together “Representatives”); and beneficial owners of an organization or entity in connection with:

This Privacy Notice sets out the purposes for which we collect, process, use, transfer and disclose (collectively “processing”) PI and how it is protected. It also sets outs individuals’ rights in relation to the processing of their PI. There may be additional terms, conditions and commitments that also govern how we collect, process, use, transfer and disclose your PI, which should be read in conjunction with this Privacy Notice.

Personal Information We Collect About You

PI we collect about you is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. PI does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. SPI is a sub-category of PI that includes PI relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data or tax and financial information. The nature of the information that we collect will depend on the our relationship with you. We categorize PI we process as follows (the PI listed for each category are non-exhaustive examples:

How We Collect Personal Information About You

We collect PI in relation to you in a numberof ways, including:

We may also create or derive PI such as creating records of your interactions with us, subject to applicable law. Unless we otherwise indicate that the provision of specific PI is optional, any PI we request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the PI requested, we may not be able to provide those products and services.

Purpose and Legal Basis for Processing Your PI

The below table sets out the purposes and basis for which we process PI.

Processing Purpose

To consider opening an account, or entering into a relationship at your request,including performing anti-money laundering, anti-terrorism, sanction screening, fraud and other due diligence checks

Category of PI

Identification data
Contact data
Financial data
Services data
SPI

Basis of Processing

Performance of a contract
Legal or regulatory obligation Legitimate interests: ensuring we do not accept the proceeds of criminal  activities or assist in fraudulent or any unlawful activities, such as  terrorism

To deliver the services you have requested, including liaising with third parties and to provide access to our technology solutions services

Identification data
Contact data
Financial data
Profile data
Services data
Technical data
Marketing and Communications data
Professional Information data

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring that you are provided with the best client services and visitor services we can offer, and securing a prompt payment of any fees, costs and debts in respect of our services

To manage payments, fees and charges and to collect and recover money owed to us

Identification data
Contact data
Financial data
Professional Information data
Services data

Performance of a contract
Legitimate interests: ensuring we can manage payments,fees and charges and to collect and recover money owed to u

To manage our relationship with you which will include notifying you about changes to our terms of business or this privacy notice

Identification data
Contact data
Profile data
Marketing and Communications data
Professional Information data

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring we can notify you about changes to our terms of business or this notice

Legal or regulatory obligation
Public interest

Identification data
Contact data
Financial data
Services data
Professional Information data

Legal or regulatory obligation
Public interest

To detect or prevent fraud and/or other criminal activity and to protect our employees and assets

Identification data
PCM Building and Assets Security data
Contact data
Electronic Monitoring data
Financial data
Professional Information data
Profile data
Services data
Technical data
SPI

Legal or regulatory obligation
Public interest
Legitimate interests: protecting PCM and client assets; detecting, and protecting against breaches of our policies and applicable laws; protecting PCM employees

To manage and protect our business, including improving data security,troubleshooting data and systems, system maintenance and testing,data hosting, managing our offices and other facilities

Identification data
Contact data
Profile data
Technical data
Marketing and Communications data
Professional Information data
SPI

Legal or regulatory obligation
Legitimate interests: ensuring the efficient and secure running of our business, including through office and facilities administration, maintaining information technology services, network and data security and fraud prevention

To invite you to take part in market insight or other events, or client seminars or similar events, and to manage your participation in them

Identification data
Contact data
Profile data
Technical data
Marketing and Communications data
Professional Information data

Legitimate interests: ensuring our client records are up-to-date; promoting our client services receiving feedback; improving our services; identifying ways to expand our business

To send you marketing (including by paper and electronic channels) communications and service updates

Identification data
Contact data
Profile data
Technical data
Marketing and Communications data
Professional Information data

Legitimate interests: reviewing how clients use, and what they think of, our services; identifying ways to improve and expand our business

Inrelation to vendor services:
Purpose and/or activity

To engage you or the organization or entity you work for as a new supplier, including performing anti-money laundering, anti-terrorism, sanctions, fraud and other background checks

Type of data

Identification data
Contact data
Financial data
Services data
Professional Information data
SPI

Legal basis forprocessing

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring we do not accept the proceeds of criminal activities or assist in fraudulent or any unlawful activities, such as terrorism
Public interest

To manage payments,fees and charges and to collect and recover money owed to us

Identification data
Contact data
Financial data
Professional Information data
Services data

Performance of a contract
Legitimate interests: ensuring we can manage payments,fees and charges and to collect and recover money owed to us

Where we provide you access to our systems we need to manage and protect our business,including improving data security, troubleshooting data and systems,system maintenance and testing, and data hosting

Identification data
Contact data
Profile data
Technical data

Legal or regulatory obligation
Legitimate interests: ensuring the efficient and secure running of our business, including maintaining information technology services, network and data security

To Whom We Disclose Your PI

In connection with one or more of the purposes outlined in the section‘ Purpose and Legal Basis for Processing Your PI’ above, we may disclose PI in any jurisdiction to:

Transfers of Pl

To provide global services and in the course of running our business, we may transfer PI to a location outside of the country where you reside or where services are provided to you or the organization or entity you work for, including PCM processing centers in Taiwan, Australia, United States, Hong Kong and Singapore. Although the country to which PI may be transferred may not have the same level of privacy and data protection laws, we apply the same level of security and organizational controls to the processing of PI wherever it is processed.

We require by contract that our third party service providers processing PI on our behalf to comply with PCM’s criteria for PI processing. If we transfer PI out of the EEA, we ensure a similar level of protection for your PI by  ensuring the country to which the PI is transferred is considered by the EU Commission to provide an adequate level of protection, putting in place contractual clauses the EU Commission consider to provide the same level of protection. For third party service providers in the US, we may rely on the EU-US Privacy Shield certification.

Marketing And Opt-Out

We will not process your PI for marketing purposes if you have informed us you do not wish to receive marketing materials. You can request that we stop processing your PI for marketing purposes at any time by clicking on marketing opt-out links in any electronic marketing materials we send you, by making a request to your usual PCM contact or by using the contact details set out in the “Contact Us” section of this notice.

Sale of Pl

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

Pl Retention

We will process your PI for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defense of legal claims.

PI Security

We use a range of physical, electronic and  managerial measures to ensure a level of security appropriate to the risk of PI processing. These measures include:

The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries the risk of access and interception. You should not send us any PI by open/unsecure channels over the internet. We endeavour to protect personal information but cannot guarantee the security of data transmitted to us or by us.

Your Rights

The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries the risk of access and interception. You should not send us any PI by open/unsecure channels over the internet. We endeavour to protect personal information but cannot guarantee the security of data transmitted to us or by us.

You may exercise your rights at any time by using the details set out in the “Contact Us” section in this notice. To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights. We may need to request specific information from you to help us confirm your identity and ensure your right to access to the PI requested, or to exercise any of your other rights. This is to ensure that PI is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the PI processed in relation to you, including, for example, the nature and location of your relationship with us. We aim to respond to all legitimate requests within one calendar month. If we think it may take us longer than one calendar month, (such as where your request is particularly complex or you have made a number of requests), we will notify you and keep you updated. You will not be disadvantaged in any way by  exercising your rights in relation to the processing of your PI.

Contact Us

PCM’s director’s office oversees compliance with privacy and data protection at PCM. If you wish to exercise any of your rights, or have questions concerning this notice, please contact:

The Directors
Privacy and Data Protection
Prism Capital Management Limited
3-212 Governors Square, 23 Lime Tree Bay Avenue,
Seven Mile Beach,
Grand Cayman, KY1-1203, Cayman Islands
Email: privacy@prism.financial

Complaints

If you have any concerns or complaints about the way your PI is processed, please contact the directors at Privacy@prism.financialYou also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your PI has arisen.

Linked Websites

This notice is not applicable to third party websites that we do not own or control, or to any third-party website where PCM may be displayed.

Changes to this Privacy Notice

We may modify or amend this notice from time to time and you are advised to visit our website regularly to check for any amendments. Any material changes will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

Cookie Notice

What are cookies?

Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties which receive data obtained from that website. When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.

Why do we use cookies?

Cookies help us to provide customized services and information. We use cookies on our Website to tell us, in general terms, how and when pages on our Website are visited, what our users’ technology preferences are – such as what type of video player they use – and whether our Website is functioning properly. Depending on their purpose, some cookies will only operate for the length of a single browsing session, whilst others have a longer life span to  ensure that they fulfil their longer-term purposes (as explained in more detail below). Please note that, however long the cookies’ active life may be, you can delete cookies (and therefore stop any further data collection by them) as further described below.

If you are using one of our password-protected sites, then the Website may use cookies or other technology to help us authenticate you, store and recognize your configuration and user attributes, facilitate your navigation of the website and customize its content so that the information made available is likely to be of more interest to you.

In broad terms, we use cookies on our Website for the following purposes:

Please note that third parties may use cookies. The kind of cookies and the consequent data processing carried out by such third parties are regulated by their privacy policies. Please see below for more information about third party cookies. Your cookie preferences Cookies are necessary in order for you to be able to make full use of PCM’s Website. In addition, cookies help us provide you with personalized features on our Website. If you chose to disable cookies, some of PCM’s Website’s functionality might be impaired.

Local Flash Storage

On certain pages of our Website, we include content designed for display using Adobe Flash Player, such as animations, videos and tools. Local flash storage(often referred to as “Flash cookies”) can be used to help improve your experience as a user. Flash storage is retained on your device in much the same way as standard cookies but is managed directly by your Flash software. If you wish to disable or delete information stored locally in Flash, please see the documentation for your Flash software, located at www.adobe.com.

Please note that, if you disable Flash cookies, some site functionality may not work.

Third party cookies

When you visit our Website, you may receive cookies that are set by third parties. These may include cookies set by Google, LinkedIn, and/or Rocket fuel. These cookies are used for the purposes described in the “Why Do We Use Cookies?” section of this policy.

We do not control the setting of these third-party cookies, so we suggest you might wish to check the third party websites for more information about their use of cookies and how to manage them: Google's privacy policy.

Amending cookie preferences If you wish to remove cookies set by our Website from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our sites will impair the functionality of the sites.

The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browses, or you may consult the vendor documentation for your specific software. Further information about cookies If you would like to find out more about cookies in general and how to manage them, please visit www.allaboutcookies.org

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