Cavamont Investment Advisors Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and use our services. This privacy notice will tell you about your privacy rights and how the Cayman Islands Data Protection Act (As Revised) protects you.
This privacy policy gives you information about how Cavamont Investment Advisors Limited collects and uses your personal data through your use of this website, including any data you may provide when we provide services to you.
Cavamont Investment Advisors Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact the us using the information set out in the contact details section (paragraph 10).
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We use different methods to collect data from and about you including through:
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Use | Type of data | Legal basis |
| To register you as a new client |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries (c) Performing our anti-money laundering checks |
(a) Identity (b) Contact (c) Marketing and Communications (d) Special Category Data |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you |
You will receive marketing communications from us if you have requested information from us or received services from us and you have not opted out of receiving the marketing.
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
You can ask to stop sending you marketing communications at any time.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
We may share your personal data where necessary with third parties, including third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may be required to share your personal data with government or regulatory authorities such as the Cayman Islands Monetary Authority, the Cayman Islands Financial Reporting Authority and the Cayman Islands Tax Information Authority.
We do not transfer your personal data outside of the Cayman Islands.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and the Cayman Islands Ombudsman of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
You have certain rights under the DPA under certain circumstances, including:
If you wish to exercise any of the rights set out above, please contact us.
Depending on where you are a resident you may not have to pay a fee to access your personal data (or to exercise any of the other rights). We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
You have the right to make a complaint at any time to the Cayman Islands Ombudsman, the Cayman Islands regulator for data protection issues (Cayman Islands Ombudsman | Cayman Islands Ombudsman). We would, however, appreciate the chance to deal with your concerns before you approach the Cayman Islands Ombudsman so please contact us in the first instance.
We keep our privacy policy under regular review. This version was last updated on March 31, 2025.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
