Privacy Policy

Data Controller

Signature Capital Limited (‘the Company’, ‘We’, ‘Us’ or ‘Our’) is a Data Controller within the meaning of the General Data Protection Regulations (697/2016/EU) (‘GDPR’) and applicable Irish data protection legislation (currently the Irish Data Protection Acts 1988 to 2003 as may be amended). As a Data Controller the Company is obliged to provide you with information on how we collect, use, store and share your personal data. This document has been made available for that purpose.

Information we Collect

We collect information: (i) you give us; (ii) information generated during the provision of our services and; (iii) information provided to us by third parties.

Sometimes we may use your information even though you are not our customer. For example, you may be a beneficiary, guarantor, director or representative of a customer of ours or be a potential customer applying for one of our products or services.

Types of information we may collect or hold about you include:

identity details, including your contact information;
information about you provided by others e.g. company secretary for Directors/Shareholders/Beneficial Owners;
information which you have consented to us using; and
other personal information such as information provided when exercising your rights set out below.

Purposes of Processing and the Legal Basis for processing

We use, and share, your data where:

you have agreed or positively consented to the using of your data in a specific way (e.g. to receive information on new investment opportunities). If you have provided your consent you may withdraw your consent at any time by making contact with us;
use is necessary to provide a service or fulfil a contract that you have entered into (e.g. to provide you with investor services) or because you have asked for something to be done so you can enter into a contract with us;
use is necessary because we have to comply with a legal obligation (e.g. complying with our Anti-Money Laundering obligations, reporting to regulatory authorities and law enforcement, etc.);
use is necessary to protect your “vital interests” in exceptional circumstances;
use for our legitimate interests such as managing our business and fraud or crime prevention. This may include things like training and quality assurance, strategic planning, statistical analysis of our service provision. You may object to your personal information being used for these purposes.

Recipients of Your Personal Data – Third Parties

In the course of providing our services to you, complying with legal obligations or pursuing our legitimate interests, we may share your personal data with the following categories of recipients:

third parties with whom: (i) we need to share your information to facilitate transactions you have

requested, (ii) you ask us to share your information or (ii) we are legally obligated to provide information to;

your authorised representatives such as Tax Advisors, Solicitors, etc.;
service providers who provide us with support services to enable delivery of our services;
statutory and regulatory bodies and law enforcement authorities;
pension fund administrators, pension trustees, etc.;
Signature group companies, business or joint venture partners.

Transfers of Data Outside of the EU

Sometimes we transfer personal data outside of the EU such as when it is in connection with our US investments and also in the context of using data storage providers who may have servers outside of the EU. In those cases we will seek to ensure adequate security measures are in place to protect the data and that a lawful basis for the transfer exists.

How long we will hold your Data

How long we hold your data for is subject to a number of pieces of legislation and regulations – as a general rule, we will keep your data for up to a maximum of 8 years after the end our relationship with you or the last service provided. We will however endeavor not to keep any of your personal data longer than is necessary to fulfil the relevant purpose and/or comply with a specific legal retention period.

Your Rights with Respect to Our Use of Your Data

From 25 May 2018, you have several enhanced rights in relation to how we use your information, including the right, without undue delay, to:

find out if we use, access or receive your information;
have inaccurate/incomplete information corrected and updated;
object to particular use of your personal data for our legitimate business interests or direct marketing purposes;
to withdraw consent at any time where processing is based on consent.
in certain circumstances, to have your information deleted or our use of your data restricted;
in certain circumstances, a right not to be subject to solely automated decisions and where we make such automated decisions, a right to have a person review the decision;
exercise the right to data portability (i.e. obtain a transferable copy of your information we hold to transfer to another provider);

If you wish to exercise any of your data rights, you can contact Us by writing to:

Signature Capital Limited, 76 Merrion Square, Dublin 2.

Or emailing info@signaturecapital.com

We will endeavor to deal with your request within 1 calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests) we may extend this period by a further two calendar months and shall explain the reason why. If you make your request electronically, we will try to provide you with the relevant information electronically.

If you are not happy with any aspect of how your data is used, you also have the right to complain to the Data Protection Commission in Ireland. You can contact the Office of the Data Protection Commissioner at:

Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231

Fax: +353 57 868 4757

E-mail: info@dataprotection.ie

Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois.

Information We Need

If you do not provide certain information we may not be able to:

provide the requested services to you;
to continue to provide existing services.

We will tell you when we ask for information which is not a contractual requirement or is not needed to comply with our legal obligations.

Automated Decision-Making

We may analyse your information using automated means to:

help us understand your needs, investment risk profile and develop our relationship with you;
to assist in compliance with our legal obligations in connection with prevention of money laundering, fraud and terrorist financing.