Privacy Policy

Introduction

The Firmament Group (“Firmament”) considers your privacy and the protection of personal data to be of utmost importance and has implemented this Privacy Notice and Policy (the “Policy”), which explains how we collect and use personal data. We collect and process the personal data in compliance with the provisions of the European Union’s General Data Protection Regulation (“GDPR”).

The Policy summarizes our policies regarding the collection, use and transfer of your personal data, the security measures we employ to protect such data and your rights and choices with regard to access or use of such data. We are committed to protecting the privacy of any information we hold about you.

Your Personal Data

We collect personal data about you from various sources, including our discussions with you, from documents that you may deliver to us, and while providing services to you or on your behalf.  Personal data is any information relating to you or that we can otherwise link to you. The personal data collected about you will help us provide you with a better service and facilitate our business relationship. The personal data we collect might include your name, postal address, e-mail address, phone and fax number, company name, company structure, job title and business affiliations. Depending on your previous relationship with Firamment, the information maintained may include employment history, education information and a record of our contact history with you and comments, views or references from third parties. For investors, personal data may include information to allow Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) requirements to be fulfilled, bank account details, social security number and income, assets and investment experience, investment activity and history, source of funds, and tax information.

The personal data collected about you is processed on the lawful basis of legitimate business interest and is stored in a secure and confidential database which is accessible only by Firmament’s employees or Firmaments’s advisors or representatives.

Use of Personal Data

From time to time, we will use your personal data to contact you in the ordinary course of our business activities, which may include direct marketing related to information and services that may be of interest to you, for raising investments into Firmament’s funds, in connection with future fundraising activities, and when inviting you to events which may be of interest to you.

We do not sell any personal data to third parties. Your personal data will be shared only with Firmament’s entities in order to best manage our relationship with you; tax authorities to comply with applicable laws and regulations; services providers to deliver and facilitate services needed to support our business relationship with you; and our lawyers, accountants, and other professional advisors to provide you with investment-related services, to provide us with legal advice in relation to your actual or potential investments, and to comply with applicable legal and regulatory requirements.

Your Rights

We keep your personal data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or where longer, such period as is required by law or regulation which apply to us.  We generally do not rely on obtaining your consent to process your personal data but rather rely on other lawful bases for processing.  In the event that consent is obtained, you have the right to withdraw such consent at any time. You may withdraw consent by contacting us at cao@thefirmamentgroup.com. You may ask us either to remove you from our marketing lists or to remove your personal data entirely from our database.  If requested by you and to the extent we can do so without affecting an ongoing business relationship or breaching compliance, legal or regulatory requirements, we will delete your personal data.

We take your concerns very seriously. We encourage you to bring it to our attention if you have any concerns regarding the processing of your personal data.

This Policy was drafted with simplicity and clarity in mind. We are happy to provide further information or explanation. Please contact us at cao@thefirmamentgroup.com

If you wish to make a complaint, you can contact the body regulating data protection in your country, where you live or work, or the location where the data protection issue arose.

Data Security and Integrity

We use every reasonable effort to ensure that data is accurate, complete, current and reliable for its intended use. We use appropriate technical and organizational measures and safeguards to help protect your personal data from unauthorized access, alteration, or loss. Our internal policies and procedures are designed to help ensure we safeguard the privacy and accuracy of all data we collect or process. To the extent that we disclose personal data to any third parties, we will request that they properly protect the security and confidentiality of such information and otherwise process such data in accordance with applicable law and regulation.

Contact Us

Please contact us if you have any questions about this Policy or the personal data we hold about you, if you would like us to delete your personal data, or if you prefer to unsubscribe from our marketing mailing list, by emailing cao@thefirmamentgroup.com

Changes to the Policy

We keep this Policy under regular review.  We reserve the right to modify or amend this Policy at any time and for any reason, as permitted by applicable law and regulation. If there are material changes to this Policy, we will post the amended Policy on our website or publish it otherwise.

This Policy was last updated on 25 May 2018.