FCS Asset Management (FCS AM, referred to also as 'our' or 'we' in this Policy) is a Company established under the Laws of Malta, with Company Number C 54256 and having its registered address at 16/1, Sandra Flats, Windsor Terrace, Sliema.
FCS Asset Management's current Data Protection Officer is Dr. Daniel Caruana. He may be contacted by email at firstname.lastname@example.org or telephone number (+356)2713 0168.
In this Policy, 'Personal Data' shall mean any information which is part of the identification of a person, including their Name, Address, Identity Card or Passport Numbers amongst others.
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The Contact Us form includes fields to insert the name, surname and email address of those who wish to contact FCS AM. All the information provided in these fields will be included in an email to our Directors.
By sending the email, you understand that the data contained within shall be sent to FCS AM's Directors, and shall be used depending on the nature of the personal data. For the policy regarding personal data provided in the Contact Us form with the intent of providing information required for initial subscription purposes, kindly refer to the section marked "Clients" for more information.
All information shall only be kept for as long as is required by the legal obligations of the Company in terms of law or contract.
For onboarding purposes, personal data shall need to be provided from the prospective Client to the Company. This personal data shall be used solely for contact purposes or for the purposes of confirming the source of the initial receipt of moneys, and for the purpose of the depositing of dividends or redemptions. Information on Source of Funds shall be required for compliance with Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) requirements.
Personal data necessary for the depositing of the investment, including bank account numbers shall also be requested during the onboarding process. This data shall be used for the confirmation of identity of the Client and all potential UBOs (ultimate beneficial owners) as required by the law, in particular the Anti-Money Laundering Directives to ensure the legal provenance of funds.
Further personal data, including Tax Identification Number/GIIN and Country of Residence, shall be required in order to comply with tax reporting requirements under the Common Reporting Standards (CRS) and the Foreign Account Tax Compliance Act (FATCA). Data requested in these self-certification forms shall be kept internally, unless the Client's tax residency status makes the information contained within reportable to the Client's local tax authority in the case of CRS, or the United States Inland Revenue Service (IRS) in the case of FATCA.
Such personal data provided is gathered by the Company, and stored securely in our offices in Malta. This information may be shared on a cross-border basis with our Service Providers, for the purposes of the performance of the contract with the Client. All personal data is to be kept internally and not to be shared with third parties except when outlined above. The processing of this data shall only occur when either such is required for the performance of the contract with the Client, or to comply with its obligations under the law, including but not limited to complying with law enforcement or AML regulator requests. Personal data may also be used for the protection of the public interest or the Client's vital interests, or those of any other person, or for the legitimate interests of the data controller. The latter must be backed up by proper justification for its use. In all other cases, the Client's consent will be sought for each and every specific purpose not outlined above.
Data Subject Rights
You are entitled to request all personal data which is kept on you by the Company, and that this data shall be delivered to you without delay upon your request, in a clear, useable and easily portable format. You may also request that such data be transferred in a useable format to a third party.
You possess the right to request correction and/or erasure of personal data, and such correction or deletion shall be carried out without undue delay unless such information is required to keep by law. You may also object to the use of any personal data
You have the right to withdraw any given consent at any point in time, subject to the lawful requirements of the Company. In the case where withdrawn consent does not permit the Company or any of its Funds to keep maintain their relationship with you as Client, full redemption may be required.
To exercise any of the rights outlined in this section, kindly send mail to the address provided above, or contact the Data Protection Officer at the email address or telephone number provided above.
You also have the right to request to no longer be included in any future communications from the Company. To exercise this right, kindly reply to any email from the Company and request the cessation, or send such request to the Data Protection Officer, details above.
Right to Contact Authority
You may at any time also contact the Office of the Information and Data Protection Commissioner to raise any complaint regarding any data collection or processing carried out by the Company which you believe breaches your rights.
IDPC Address: Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549
Telephone +356 2328 7100