Privacy Notice
Identity and contact details of the Data Controller
Platinum Capital Management Limited ("PCM") (company number 03829996), whose registered office is at East Building, Holland Court, The Close, Norwich, NR1 4DY is the Data Controller and recognises the importance of protecting the privacy of all information it collects from individuals while conducting its business. We have created the following policy guidelines to let you know how we collect and use your personal information. Please read this Privacy Notice carefully. By visiting our website or using any of our services, you indicate your agreement to our use of your personal information as set out in the Privacy Notice.
Information collected by PCM
PCM will collect information from individuals when you register on our website, apply to subscribe to our funds or use our services or contact us in person, by telephone, by email or by post.
We may collect information about you from fraud prevention agencies and other organisations when we undertake checks such as identification verification checks.
Information may also be collected about you when you visit our websites (for example via cookies), such as your IP address and other browser-generated information. More information about this can be found in our Cookie Policy.
We record all calls for training and quality purposes and to enable us to deal effectively with queries or complaints and to comply with our regulatory obligations. We may collect the following information from you so you can register for our website or subscribe for our funds or services:
- ·name, address, email address, telephone number;
- Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number;
- Passport details, driving license and utility bills;
- Records held by financial crime prevention agencies, on the Electoral Register and providers of utility services;
- Details of your employment status, income and source of wealth.
Use of information
PCM use information held on you in the following ways:
- To process a request to register for our website;
- To identify you and verify your identity, source of funds and wealth for the purpose of anti-money laundering obligations and for the purpose of crime and fraud prevention;
- To comply with our obligation arising from any contracts entered between you and us or our products and to provide you with information, products and services you request from us;
- To deal with any queries, complaints or problems reported by you;
Legal basis for processing
In accordance with data protection law, we are obliged to inform you that we are using your information as described in this privacy notice statement on the following legal bases:
- you have given your consent to us using your information as described in this notice;
- ·the use is necessary to perform a contract between us or to take steps which you requested us to take before entering into a contract;
- the use is necessary to comply with a legal obligation to which we are subject;
- ·the use is necessary for the purposes of understanding visitors to our website which is in our legitimate interests.
Personal Data Security
We maintain adequate technical and organisational security measures to protect personal information from loss, misuse, and unauthorised access, disclosure, alteration, or destruction.
Sharing of your Information
We may disclose your information to:
- ·Business in the same group as PCM;
- Our brokers, dealers, IT providers, service providers in order to provide and maintain the provision of services;
- Our appointed auditors, accountants, lawyers and other professional advisers to the extent that they require it in order to advise us;
- Fraud prevention agencies and other organisations to allow us to undertake the checks;
- Providers and service providers of the funds that we manage;
- Financial services regulators where they are entitled to require disclosure;
- Meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
- Investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
- Relevant tax, payments and customs authority;
We will not lend or sell your information to third parties.
Transferring Information Overseas We may share your personal information with our service providers and this may involve transferring it to countries outside the European Economic Area (EEA) whose data protection laws may not be as extensive as those which apply to us. Where we do so, we will ensure that we do this in accordance with the Acts and take appropriate measures to ensure that the level of protection which applies to your personal information processed in these countries is similar to that which applies within the EEA. Such measures may include only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.
We may transfer your personal information between businesses that are legally part of the PCM affiliated companies for the purposes of providing our services to you as follows:
- from our businesses based in the United Kingdom to our businesses based in Los Angeles or Switzerland on the basis that the European Commission has given a formal decision that such countries provide an adequate level of data protection similar to that which applies in the United Kingdom and EEA; and
- from our businesses based in Los Angeles or Switzerland to our businesses based in the United Kingdom on the basis that the United Kingdom is an authorised jurisdiction for the purposes of the relevant Acts.
Your Rights
You have the right to:
- ·withdraw your consent where you have given your consent to us to use your personal information for certain purposes. You have the right to withdraw this consent at any time by contacting us using the contact details set out in the "Contact Us" section. This will not affect the lawfulness of any use of your information that we make before you withdraw your consent.
- ·access your personal information to understand whether we hold information about you and, if so, for us to give you certain details about that information and/or the information itself. This is commonly known as a subject access request. If you would like to make a subject access request, please do so in writing and send this to us at the details as set out in the "Contact Us" section below;
- restrict the processing of your personal information if one of the following applies to you:
- you contest the accuracy of the information that we hold about you, while we verify its accuracy;
- we have used your information unlawfully, but you request us to restrict its use instead of erasing it;
- we no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
- you have objected to us using your information, while we check whether our legitimate grounds override your right to object
- ·require the correction of any inaccurate or incomplete information;
- ·object to the processing of your personal information on the basis of our legitimate interests;
- ·require us to erase your personal information without undue delay if one of the following applies, unless it is necessary to use your personal information to comply with a legal obligation or to establish, exercise or defend a legal claim:
- the information is no longer necessary for the purposes for which we collected it;
- we need your consent to use the information and you withdraw your consent;
- you object to us using your information: for the purposes of understanding the visitors to the website and there are no overriding legitimate grounds for the processing;
- you unsubscribe from our marketing communications;
- we have used your information unlawfully;
- the information must be erased for compliance with a legal obligation to which we are subject.
- port your personal information under certain circumstances;
Retention of Personal Information
In accordance with our legal data protection and privacy obligations, we will only retain your information for as long as necessary by law. We will then either securely delete it or anonymise it so that it cannot be linked back to you.
Contact us
If you have any questions about this privacy statement or the practices of this website you can contact us at 
info@platinumfunds.com.
You have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO). However, we would appreciate the chance to put this right for you first. Please contact us using the details set out above. We will do our very best to answer any question and resolve any complaint to your satisfaction. If, for whatever reason, you feel we do not meet the high standards we expect of ourselves, you have a right to complain to the ICO.
