Polymer Capital collects and use certain Personal Data. Polymer Capital is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
In the course of our correspondence and other dealings with you, we will receive information relating to you and/or, where you act as an agent or a representative of a legal person or other entity (rather than a natural person), information relating to other officers, directors, partners, members or employees of that legal person or other entity (such information, “personal information”). If the personal information you provide to us does not relate to you, you agree to provide the disclosures set out below to the individuals whose personal information you have provided.
Personal information is subject to certain legal safeguards specified in the European Union's General Data Protection Regulation (2016/679) (“GDPR”) and any secondary and domestic legislation implementing the GDPR, and in the Data Protection Law, 2017 (“DPL”) of the Cayman Islands (together, the “Data Protection Legislation”). The Personal Data which you have provided to us will at times also be governed by the terms of the Personal Data (Privacy) Ordinance, as amended and supplemented from time to time (the “PDPO”). Polymer Capital is a ‘controller’ of your personal information for the purposes of the PDPO or GDPR. The PDPO and Data Protection Legislation prescribe the ways in which we may collect, retain and handle personal information.
What personal information will we process?
The types of personal information relating to you may include, for example:
How do we use your personal information?
We may process your personal information in order to market our investment products, to process queries, undertake normal investment business activities in order to offer our services and manage assets on behalf of clients, and to exercise our rights at law or under contract. We will also use your personal information, where required, in order to comply with our legal and regulatory obligations. This may include, without limitation, establishing investor eligibility, preventing fraud, carrying out money laundering checks or conflict checks, and reporting to national and international regulatory and tax authorities.
We may also process your personal information to manage and administer our business, to analyze and improve relationships with our clients and service providers, and for business development activities.
We may share your personal information with third parties (including legal advisors and law enforcement agencies) in order to respond to investigations, court orders, legal process, or to investigate, prevent or take action regarding illegal activities, suspected fraud, or as otherwise required by law.
Polymer Capital may also use your information in order to provide you with information of investments or products you may be interested in. If you object to being contacted in respect of prospective products, please contact [email protected].
Lawful bases for processing your personal information
The lawful bases for processing your personal information are as follows:
Performance of contract: to ensure our ability to perform our obligations under investment contracts and other documents that form the basis for our contractual relationship with you (or, in certain circumstances, another person), and certain required pre-contractual steps. If we cannot process personal information as required, it may not be possible for us to perform our obligations under the relevant contract, and we may be required to terminate the contract.
Legal obligations: we are required to comply with applicable legal and regulatory requirements,including, for example, any regulatory or tax reporting requirements; to carry out money laundering/terrorist financing checks, conflict checks, for purposes of fraud prevention, to comply with any applicable auditing or financial reporting requirements; and to comply with information disclosure requests from regulatory, tax or other governmental or public authorities.
In addition to the above lawful bases for processing your personal information, your personal information may also be processed on the basis of our legitimate interests:
When processing your personal information, we will comply with the relevant requirements under the PDPO, DPL or GDPR as applicable to us.
With whom do we share your personal information?
We may share certain of your personal information with the following categories of third parties for the following reasons:
They may in turn use the services of their affiliates or service providers to process your personal information where necessary or appropriate. Where we share your personal information with a third party, we generally take steps to ensure the recipients of that personal information will process it appropriately.
International Transfers of your personal information
Your personal information is held by Polymer Capital in its offices in Hong Kong, Japan, Singapore and other locations, and may be shared with advisers, service providers, and disclosed to regulatory, tax or other governmental or public authorities outside these locations or the EEA, as described above.
Where we share your personal information with persons outside our office locations or the EEA we will, to the extent practicable, take appropriate steps to ensure your personal information is subject to safeguards in compliance with the requirements of Data Protection Legislation. We will seek to achieve this, for example, by entering into appropriate data transfer agreements with third party recipients of your personal information which may set out the standard contractual clauses approved by the PDPO or European Commission (as applicable) governing the transfer of Personal Data outside the EEA, where possible. Please contact us if you would like a copy of the aforementioned standard contractual clauses.
Personal Data collected for recruiting or employment purposes, regardless of where collected, may be transferred to our Hong Kong headquarters and may be transferred outside of the EEA (or your home country, if not the EEA) to our affiliates or third parties that process application information for the purposes described above. When this occurs, Polymer Capital requires such companies to treat your information confidentially.
How long is your personal information retained?
We will not retain your personal information for longer than is necessary in relation to the purposes for which your personal information is processed and in accordance with regulatory requirements. Generally, we will retain your personal information concerning your investments for 7 years after the end of any relevant contractual relationship. Personal information may be retained for longer if it is required by law, or by a tax or regulatory authority, a law enforcement agency or other governmental or public body, or considered necessary in order to allow us to act in accordance with a specific set of circumstances, for example, in light of an actual or a potential legal action or a regulatory investigation.
Where do we collect your personal information?
Polymer Capital may collect Personal Data through a range of means. These may include direct interactions (where a person provides Personal Data to us through correspondence or other direct methods of communication, including communications relating to investments), third-party or publicly available sources (where a Fund receives personal data through a publicly available source such as a website or publicly available registry).
Safeguarding your information
We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where particularly sensitive Personal Data (e.g., resumes/CVs submitted for recruiting purposes) is gathered, processes or stored is limited to authorized employees.
Polymer Capital employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need it to perform their roles. Unauthorized use or disclosure of confidential client information by a Polymer Capital employee is prohibited and may result in disciplinary measures.
EEA Data Subjects: Your rights in relation to the personal information we process about you
In all of the above cases in which we collect, use or store your Personal Data and you are in the EEA, or if controlled by a Cayman Islands entity, you have various rights under Data Protection Legislation in relation to the personal information relating to you. These include:
You can seek to exercise any of these rights by contacting us at [email protected].
Questions or complaints
If you have any questions or complaints regarding the processing of your personal information, please contact us directly at [email protected].
Complaints regarding our processing of your personal information may also be made directly to the relevant data protection regulator in your local jurisdiction in the EU or to the Office of the Ombudsman in the Cayman Islands.
 Where those obligations derive from the laws of the European Union or the member states of the European Economic Area or the Cayman Islands.