Privacy Policy

Introduction

This Data Protection Notice provides information about data that is collected, recorded, organized, structured, stored, altered, retrieved, used, or transmitted by Orchard Global Asset Management LLP, Orchard Global Asset Management (S) PTE LTD, OGAM Ltd, and OGAM LP,  (collectively “OGAM” or the “Firms”), and OGAM’s commitment to appropriately using and protecting the data collected.

This Data Protection Notice applies to both clients and employees of OGAM. When you use our services, you acknowledge that you have read and understand the contents of this Data Protection Notice.

Policy Administration

This Data Protection Notice was approved by Senior Management on 15 May 2018. We reserve the right to update this Data Protection Notice at any time.

Why Does This Policy Exist?

This Data Protection Notice ensures OGAM:

  • Complies with Data Protection laws and follows good practices
  • Protects the rights of its clients, employees, and partners
  • Is open about how OGAM stores and processes personal data

What Personal Information Do We Collect?

OGAM does not collect more information than is needed. The following are examples of the type of Personal Information that we may collect:

  • Government Identification
  • Name
  • E-mail Address
  • Job Title
  • Birth Date
  • Tax ID
  • Bank Account Information
  • Background Check Data
  • Telephone Recordings
  • Medical Data
  • CCTV Video Footage

How Do We Collect Information?

Information That You Give Us: OGAM may collect and process information from you. When OGAM collects data from you directly, we will provide the following information:

  • OGAM’s contact information;
  • OGAM’s purpose for processing the data;
  • Where the processing will take place;
  • The length of time the data will be stored; and
  • A statement detailing your rights.

Information from Websites: Some information may automatically be collected as you browse our website(s), such as type of browser, operating system, domain cookies or IP addresses. This information is stored in necessary session cookies, and is deleted whenever a session ends or the browser is closed.

Information from Other Sources: OGAM may also collect your personal information from other sources, such as public databases, joint marketing partners, or through background checks. For example, we may collect information from business partners in order to verify your identity and/or prevent fraud. If any personal data is collected in this way, we will provide you with the following information:

  • The third-party’s contact information;
  • The contact information of the third-party’s Data Protection Office (if applicable);
  • OGAM’s purpose for processing the data;
  • Where the processing will take place;
  • The length of time the data will be stored; and
  • A statement detailing your rights.

Do We Need Consent to Collect Your Data?

In certain instances, consent is required to collect and process data from you. Your Consent can be withdrawn at any time by providing adequate notice to OGAM.

How Do We Use Personal Information?

Personal information is used for specific business purposes and use is limited, where necessary. Additionally, employee access to personal information is granted on an as-needed basis. We may use your personal information for the following purposes:

  • To send you marketing communications in accordance with your communication preferences;
  • For our business purposes, such as accounting, payroll, tax filings, and medical benefits
  • To conduct background and hiring checks;
  • Collection activities, audits, crime/fraud monitoring and prevention;
  • To provide security in order to ensure employee safety;
  • To comply with and enforce applicable legal requirements, agreements, and policies; and
  • To perform other activities consistent with this Data Protection Notice.

When the data is collected, this above information will be provided in greater detail and as it specifically pertains to your data.

Who Do We Share Personal Information With?

Privacy is an integral part of our organization. We never sell any of your personal information to third parties. Additionally, we will not share your personal information with third parties without your specific consent or unless OGAM is required to by law and/or government authorities or under any other legitimate purpose such as performance of a contract.

Third parties that we share personal information with are required to provide adequate protection and are prohibited from using your personal information for purposes other than those that were specified upon receipt of your data. Examples of third parties that we may share your personal information with include, but are not limited to:

  • Our authorized service providers and suppliers who provide services, such as server and cloud hosting and storage, data analysis, email delivery, fund administration, payroll, medical insurance, and other similar services;
  • Our affiliate entities and subsidiaries for the purposes described in this Data Protection Notice;
  • A third party in the event of any contemplated or actual re-organization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stocks; and
  • Government authorities in order to comply with appropriate laws and/or requests.

What Security Measures Do We Have?

OGAM has technical and administrative safeguards in place to help protect data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please contact us for a copy of OGAM’s policies for more information on OGAM’s information security practices and procedures.

Is My Personal Information Transferred Outside of European Union or European Economic Area?  

Personal Data may be transferred outside the European Economic Area (the “EEA”) in connection with administering an investor or employee, in accordance with an Individual’s instructions, where an Individual has explicitly consented, and / or as otherwise required or permitted by law. 

Many of the countries will be within the EEA, or will be ones which the European Commission has approved, and will have data protection laws which are the same as or broadly equivalent. 

However, some transfers from the EEA may be to countries which do not have equivalent protections, and in that case OGAM shall use reasonable efforts to implement contractual protections for the Personal Data.  While this will not always be possible where the OGAM Entities are required to transfer the Information in order to comply with and perform the contract with an investor or where it has a legal obligation to do so, any transfers will be done in accordance with applicable data protection laws, including through the implementation of appropriate or suitable safeguards in accordance with such applicable data protection laws.  

How Long Do We Retain Personal Information?

We will retain your personal information for the period necessary to fulfill our services and the purposes outlined in this Data Protection Notice unless a longer retention period is required or permitted by law.

Do We Perform Automated Decision-Making and Profiling?

We do not use computer algorithms to make automatic decisions that are based on your personal information.

What Rights Do I Have?

We will always fulfill any rights that concern the protection of your personal information, including, but not limited to the:

  • Right to withdraw your consent to the processing of your personal information;
  • Right to object to the processing of your personal information for any purpose;
  • Right to access your personal information free of charge for a single copy;
  • Right to rectification of your personal information; and
  • Right to erasure of your personal information.
  • Right to lodge a complaint with Information Commissioner’s Office, OGAM’s data protection supervisory authority in Europe

You have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller without hindrance from us.

How Can You Manage Your Personal Information?

If you would like to request, delete, or update the personal information that you provided us, or exercise any of your data protection rights you may contact us using the information below. For your protection, we will need to verify your identity prior to complying with your request. OGAM does not charge for this service.

OGAM will make a good faith effort to provide access to requested data without undue delay, at the latest within one month. OGAM reserves the right to limit or deny access to personal information where providing such information would be unreasonably burdensome or expensive or as otherwise permissible under relevant laws. If OGAM determines that access cannot be provided in any particular instance, OGAM will provide the individual requesting access with an explanation of why it has made that determination and a contact point for any further inquiries. For more information about this service, please contact us.

Where Can This Data Protection Notice Be Accessed?

This Data Protection Notice is accessible through:

  • Our website:  and
  • Our contracts, agreements, and other necessary documents.

Contact Us

If you have questions, concerns, or suggestions related to our Data Protection Notice or our privacy practices liaise with your normal coverage personnel at OGAM, or please navigate to our  'Contact' page and get in touch with your local office.

Contact the Information Commissioner’s Office

If you believe OGAM’s processing activities are infringing on your rights or violate data protection laws, you have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a Supervisory Authority, in particular, in the Member State of your residence, place of work or place of the alleged infringement.

OGAM’s Supervisory Authority, the Information Commissioner’s Office (ICO), and can be contacted through their helpline (0303 123 1113 or from outside the UK on +44 01625 545 700) or through their website (https://ico.org.uk/concerns).