Introduction

PRIVACY POLICY

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.

1. Important information and who we are

Privacy policy

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.

Controller

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).

2.  The types of personal data we collect about you

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:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account details.
• Transaction Data includes details about payments to and from you and other details of services we provide
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Usage Data includes information about how you interact with and use our services.
• Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Special Category Data includes, but is not limited to, your political opinions and, or affiliations, so that we can identify whether you are, or are connected to, a politically exposed person; your criminal records or alleged criminal activity.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by corresponding with us. This includes personal data you provide when you apply for our services; give us feedback or contact us.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources

4. How we use your personal data

Legal basis

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:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent money laundering and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose

Purposes for which we will use your personal data

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.

 Direct marketing

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.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

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

5. Disclosures of your personal data

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.

6.  International transfers

[We do not transfer your personal data outside of the Cayman Islands.

OR

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the Cayman Islands to countries which have laws that do not provide the same level of data protection as the laws of the Cayman Islands.

Whenever we transfer your personal data out of the Cayman Islands to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place 

• We will only transfer your personal data to countries that have been deemed by the Cayman Islands to provide an adequate level of protection for personal data; or
• We may use specific standard contractual terms approved for use in the Cayman Islands which give the transferred personal data the same protection as it has in the Cayman Islands, namely The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. ]

NTD: Please confirm. If you will transfer data out of the Cayman Islands then we should discuss the ways in which you can do this in compliance with the DPA.

 7. Data security

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.

8. Data retention

How long will you use my personal data for?

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.

9. Your legal rights

You have certain rights under the DPA under certain circumstances, including:

• To request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• To request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• To request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• To object any time to the processing of your personal data for direct marketing purposes (see paragraph 4 for details of how to object to receiving direct marketing communications).
• To withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• To request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data’s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us 

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.

10. Contact details

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:

• Email address: info@cavamont.com
• Postal address: 4-202 Governors Square, 23 Lime Tree Bay, West Bay, Grand Cayman, Cayman Islands, KY1-1105

11. Complaints

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.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on December 31, 2024.

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.