Building the future of the institutional investment industry.

NAV Shapes

What does 'going digital' really mean for pension funds?

AMX is evolving

NAV Shapes

Privacy notice

On this page there are three privacy notices:

  • Privacy and cookies
  • Investor privacy notice
  • Asset manager privacy notice

Privacy and cookies

This privacy notice describes how The Asset Management Exchange (“AMX”) generally collects and processes personal information collected through www.theAMX.com and other websites controlled by AMX. The Asset Management Exchange and AMX are trading names of The Asset Management Exchange (Ireland) Limited (registered in Ireland, No. 632258; authorised and regulated by the Central Bank of Ireland), The Asset Management Exchange (UK) Limited (registered in England, No. 11555138; authorised and regulated by the Financial Conduct Authority No. 823316) and The Asset Management Exchange (IP Co.) Limited (registered in England, No. 11686713) (the “AMX Entities”). The AMX Entities are wholly owned subsidiaries of Willis Towers Watson.

This privacy notice may be revised from time to time to reflect changes in law or changes in AMX’s business operation. This privacy notice was last updated on 30 July 2021.

1. Scope of this privacy notice

This privacy notice only applies to www.theAMX.com and any other AMX website where a link to this privacy notice is provided.

Websites and specific web pages linked from www.theAMX.com may be subject to separate terms of use (including separate privacy notices). You must not use those websites (or provide Personal Information) if you do not accept such terms of use.

Where links from www.theAMX.com are provided to non-AMX websites, AMX is not responsible for those websites. These third-party websites will be governed by different terms of use (including privacy notices) and you are solely responsible for viewing and using each such websites in accordance with the applicable terms of use. AMX is not responsible for how your Personal Information is handled by such third-party websites.

2. Information we may collect from you

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.
The Personal Information we may collect through our websites includes:

  1. your name, address, occupation and other contact information;
  2. information regarding your dealings with us;
  3. any interest you have in relation to our services or our practice areas (including job openings);
  4. any information you may voluntarily submit to us by completing any form on our websites; and
  5. details of your visits to and usage of our website including the date and time of your visit, the internet address from which you visited and the resources on our website that you viewed.

We collect Personal Information in various ways:

  1. from any form you may complete and submit through our websites, for example information collected from the “Contact Us” page of our website;
  2. from the content of surveys that you may complete on our website;
  3. from ‘cookies’ and other similar tools deployed on our websites (for further information regarding cookies used on our websites, please see Section 7 below); and
  4. when you provide information as a client of an AMX entity in connection with it providing professional services to you. Such information may be collected through www.theAMX.com when clients access AMX client links within this website. Access will be subject to the terms of business AMX has with clients and any additional terms and conditions of use attached to those sites.
  5. from setting up a user profile and facilitating your access to AMXConnect.

3. Legal basis for processing personal information

We must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:

  1. for our legitimate interests, for example to provide services to our clients, to ensure that the services we provide are appropriate for our clients’ requirements, to improve our services, to enable us to comply with regulatory and governance requirements and to manage our business in an efficient way;
  2. for the legitimate interests of our clients and other third parties, for example to ensure that any financial services we provide to clients are suitable, to verify that our services are only made available to certain categories of investor and to provide a high quality of service; and/or
  3. to comply with our legal obligations, regulatory requirements and governance procedures.

When we process Personal Information to meet our legitimate interests or those of a third party, we put in place robust safeguards to ensure that the privacy of individuals is protected and to ensure that those legitimate interests are not overridden by the interests or fundamental rights and freedoms of individuals.

4. What we may do with your personal information

We may use your Personal Information in the following ways and for purposes specified in the relevant parts of the website:

  1. to facilitate your participation in interactive features you may choose to use on our websites;
  2. to correspond with you, notify you of events or changes to our services, or otherwise to respond to your queries and requests for information, which may include marketing to you;
  3. for the purposes of AMX providing professional services to you via AMX applications; such services will be subject to additional terms and conditions of use including privacy;
  4. for data analysis, audits, fraud monitoring and prevention,
  5. to enable us to comply with our legal obligations; and
  6. to monitor website usage to help us enhance, improve or modify our website and to identifying usage trends that help us determine the effectiveness of our promotional campaigns and help us to develop new products and services.

5. Disclosure of your information

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above. We may also disclose your Personal Information to independent third parties as follows:

  1. to third party service providers such as entities providing customer service, email delivery, auditing, hosting our website, our marketing activities and other services;
  2. to third parties involved with events that you register for, to facilitate your participation in those events;
  3. if we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence;
  4. in order to enforce or apply our website terms of use, or to protect the rights, privacy, safety or property of AMX, our clients, affiliates or other parties;
  5. in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
  6. in accordance with the separate terms and conditions of use that may attach to AMX website links.

6. Cross border transfer

In connection with the above purposes we may transfer your Personal Information outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.

Further details of the measures that we have taken in this regard and the territories to which your Personal Information may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Cookies and information collected from your computer

When you visit our website, our server may record your IP address for the purposes of systems administration. In most cases, your IP address is not linked to any of your Personal Information, but in limited circumstances (e.g. if you log into restricted parts of our website), your IP address can be linked to your Personal Information. AMX may also gather other non-personal information from you (from which AMX cannot identify you), such as the type of your internet browser, which AMX uses to provide you with a more effective service.

Additionally, when you visit our websites, AMX may store a ‘cookie’ on the hard drive of your computer.

Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on websites, pages visited, language preferences, and other traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using our websites and to recognize your computer in order to assist your use our websites. We also gather statistical information about use of our websites in order to improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

There are different types of cookies, for example:

  1. Cookies served directly by AMX (‘first party cookies’) and cookies served on our behalf, for example by advertisers and data analytics companies (‘third party cookies’)
  2. Cookies which endure for different periods of time, including those that only last only as long as your browser is open (referred to as ‘session cookies’) These are deleted automatically once you close your browser. Other cookies are ‘persistent cookies’, meaning that they survive after your browser is closed. For example, they recognise your device when you open your browser and browse the internet again

In order to help us improve our websites and the services we provide and to improve your experience of using our websites, our websites use several types of cookies:

Session cookies.

This type of cookie is used only on those parts of our websites that are restricted and can only be accessed by authorized users who typically authenticate themselves through their user IDs and passwords (e.g. our online client/carrier tools). This type of cookie is essential to keep authenticated users logged into our websites and to enable them to visit different parts of our websites. It will be stored on your computer for a short period (typically 48 hours) and the information held in it will be accessed automatically to authenticate you when you visit the website again. Otherwise, this cookie will be deleted when you log out and close the browser.

Google Analytics.

This cookie is provided by Google, and we use them on our websites in order to analyze how visitors use our websites, thereby helping us to improve our websites. Google Analytics collects information in an anonymous form, including the number of visitors to our websites, how visitors have arrived to our websites, and which pages on our websites the visitors have viewed.
You have the right to choose whether or not to accept cookies. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen. Go to the ‘options’ or ‘preferences’ menu on your browser to change your settings.

Hubspot.

These cookies are provided by Hubspot and we use them on our website to enable some functionality, analyse how visitors use our website and display targeted promotions. Read this article to find out more about the Hubspot cookies.

Remove Hubspot cookies
 

 

Advertising cookies.

Advertising cookies are set to display targeted promotions or advertisements based upon your interests on the sites or to manage our advertising. These cookies collect information about your activities on these and other sites to provide you targeted advertising. You can find information about advertising cookies, including how to see what cookies have been set on your device and how to manage and delete them at www.aboutcookies.orgwww.allaboutcookies.org, or www.youronlinechoices.eu.

These are the services we use and how you can control their cookies.

  • Google Ads: Google Ads is an advertising service for businesses to show ads on Google and its advertising network. Opt-out.
  • LinkedIn: LinkedIn is a business social network that allows business to show ads on its platform and advertising network. Opt-out.
  • Twitter: Twitter is a social network that allows business to show ads on its platform and advertising network. Opt-out.
  • Bing Ads: Bing Ads is an advertising service for businesses to show ads on the Bing and Yahoo ad networks. Opt-out.

Please note that if you choose not to accept cookies, this may affect the functioning of our websites.

8. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your Personal Information for as long as is necessary for the provision of any services we provide to you. When we no longer need your Personal Information in connection with any services, we will retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations or governance requirements and to defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

9. Choices and access

AMX is the controller responsible for the Personal Information we collect and process.

If you would like to review, correct, update, suppress, object to or restrict the processing of your Personal Information or request a copy of Personal Information about you, you may contact us using the details found in the “Contact” section below.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to undertake any services or requests that you initiated prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. Where that is the case, we will implement reasonable measures to ensure that this data remains secure and is not accessed or used in any way.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Information Commissioner’s Office, at www.ico.org.uk/concerns.

10. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

11. Contact

If you have any questions or comments regarding this privacy notice, please contact us at: The Asset Management Exchange, 51 Lime St, London EC3M 7DQ, or through our website.

 

Investor privacy notice

Last Updated: July 2019
Investors in Asset Management Exchange Feeder ICAV

 

Changes to Data Protection Laws – Privacy Notice

 

Introduction

As you will be aware, there have recently been some significant developments in European data protection law. Of particular importance is the adoption of the General Data Protection Regulation (“GDPR”). The GDPR will be effective from 25 May 2018.

In order to comply with our obligations under GDPR, this notice sets out details of how and why Asset Management Exchange Feeder ICAV of Riverside One, Sir John Rogerson’s Quay, Dublin 2, D02 X576, Ireland (the “Company”, “we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with investments in Asset Management Exchange Feeder ICAV (the “Fund”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to any individual investor in the Fund and personal information relating to individuals associated with corporate investors in the Fund, such as a corporate investor’s directors, shareholders, employees, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a corporate investor with which an individual is associated. Corporate investors should ensure that this notice is provided to any individual whose personal data the corporate investor has provided to us, such as its directors, shareholders, employees, and other personnel, within one month of the date of this letter.

We also refer you to our CRS Customer Information Notice contained in our subscription application form and the information under the heading “FATCA & CRS Self-Certification” and “Individual (Controlling Person’s) Self-Certification” in the subscription application form which contain certain further information relating to our use of your personal information.

 

About Us

The Company is the controller of the personal data collected via the subscription application form, which means that it determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

 

Personal Data that we Process

We collect personal data relating to you that is provided to us in the subscription application form and in connection with our dealings with you or your company in relation to investments in the Fund, including your name, signature, postal address, email address, fax number, date of birth, and other contact details.

We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including PPS number, passport number, photographic identification and verification such as copies of your passport and address verification. For the purposes of carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.

We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls, and in connection with our administration of you or your company’s investment in the Fund. We may record telephone calls for the purposes of record keeping, security and training.

In addition, we may collect personal data relating to you from third party sources in connection with complying with legislation relating to anti-money laundering, taxation, and other legislation applicable to investment funds.

We require you to complete the mandatory fields identified in our subscription application form for the purpose of entering into a contract with you or your company. Please note that some of the information required by our subscription application forms is necessary in order for us to administer your or your company’s investment in the Fund. The Administrator has the discretion to decline an application for investment in the Fund in the event that the required details are not provided.

 

Purposes of Processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

  • processing your or your company’s application to become an investor in the Fund;
  • establishing your identity, and providing, servicing and administering your or your company’s investment;
  • complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
  • for direct marketing purposes, subject to any preferences you communicate to us;
  • if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
  • to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Instrument of Incorporation;
  • maintaining appropriate business records, including maintaining appropriate registers of shareholders;
  • statistical analysis and market research;
  • internal training and management of personnel;
  • to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
  • internal and external audits and, where necessary, investigations; and
  • establishing, exercising or defending legal claims.

 

Legal basis for Processing

The legal grounds that we rely on to process your personal data are:

  • that this is necessary to comply with our legal obligations;
  • that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
    • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
    • preventing, investigating or detecting theft, fraud or other criminal activity;
    • pursuing our corporate and social responsibility objectives;
  • where you are an individual investor, that this is necessary to take steps at your request prior to entering into our contract with you and for the performance of our contract with you;
  • in certain limited circumstances, your consent.

 

Recipients of Data

We may disclose your personal data to various recipients in connection with the above purposes, including:

  • to the Administrator;
  • to The Asset Management Exchange (Ireland) Limited, the Fund’s AIFM;
  • to the Fund’s distributors;
  • to the Fund’s depositary;
  • to the Revenue Commissioners and other tax authorities as required by applicable law, including FATCA or CRS;
  • to the Central Bank of Ireland, auditors, or other competent regulatory authorities and bodies as requested or required by law;
  • to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
  • to credit reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations; and
  • to other members of our corporate group.

 

Transfers of data outside the European Economic Area

In connection with the above purposes we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

 

Retention

We will retain your personal data for the duration of your or your company’s investment in the Fund and for such a period of time after the investment ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise.

 

Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

  • the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
  • the right to require us to rectify any inaccuracies in your personal data;
  • the right to require us to erase your personal data;
  • the right to request that we no longer process your personal data for particular purposes;
  • where the legal basis for processing is consent, the right to withdraw your consent at any time;
  • the right to object to our use of your personal data or the way in which we process it; and
  • in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with the Irish Data Protection Commission (info@dataprotection.ie) or your local supervisory authority.

Contact Details

Should you have any questions in relation to this notice, please contact AMX via our website or by post at 51 Lime Street, London, EC3M 7DQ.

 

Last Updated: May 2018
Investors in Asset Management Exchange CCF

Changes to Data Protection Laws – Privacy Notice

Introduction

As you will be aware, there have recently been some significant developments in European data protection law. Of particular importance is the adoption of the General Data Protection Regulation (“GDPR”). The GDPR will be effective from 25 May 2018.

In order to comply with our obligations under GDPR, this notice sets out details of how and why The Asset Management Exchange (Ireland) Limited of Riverside One, Sir John Rogerson’s Quay, Dublin 2, D02 X576, Ireland , acting on behalf of Asset Management Exchange CCF (the “Company”, “we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with investments in Asset Management Exchange CCF (the “Fund”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to any individual investor in the Fund and personal information relating to individuals associated with corporate investors in the Fund, such as a corporate investor’s directors, shareholders, employees, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a corporate investor with which an individual is associated. Corporate investors should ensure that this notice is provided to any individual whose personal data the corporate investor has provided to us, such as its directors, shareholders, employees, and other personnel, within one month of the date of this letter.

We also refer you to our CRS Customer Information Notice contained in our subscription application form and the information under the heading “FATCA & CRS Self-Certification” and “Individual (Controlling Person’s) Self-Certification” in the subscription application form which contain certain further information relating to our use of your personal information.

About Us

The Company is the controller of the personal data collected via the subscription application form, which means that it determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

Personal Data that we Process

We collect personal data relating to you that is provided to us in the subscription application form and in connection with our dealings with you or your company in relation to investments in the Fund, including your name, signature, postal address, email address, fax number, date of birth, and other contact details.

We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including PPS number, passport number, photographic identification and verification such as copies of your passport and address verification. For the purposes of carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.

We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls, and in connection with our administration of you or your company’s investment in the Fund. We may record telephone calls for the purposes of record keeping, security and training.

In addition, we may collect personal data relating to you from third party sources in connection with complying with legislation relating to anti-money laundering, taxation, and other legislation applicable to investment funds.

We require you to complete the mandatory fields identified in our subscription application form for the purpose of entering into a contract with you or your company. Please note that some of the information required by our subscription application forms is necessary in order for us to administer your or your company’s investment in the Fund. The Administrator has the discretion to decline an application for investment in the Fund in the event that the required details are not provided.

Purposes of Processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

  • processing your or your company’s application to become an investor in the Fund;
  • establishing your identity, and providing, servicing and administering your or your company’s investment;
  • complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
  • for direct marketing purposes, subject to any preferences you communicate to us;
  • if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
  • to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Deed of Constitution;
  • maintaining appropriate business records, including maintaining appropriate registers of unitholders;
  • statistical analysis and market research;
  • internal training and management of personnel;
  • to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
  • internal and external audits and, where necessary, investigations; and
  • establishing, exercising or defending legal claims.

Recipients of Data

We may disclose your personal data to various recipients in connection with the above purposes, including:

  • to the Administrator;
  • to The Asset Management Exchange (Ireland) Limited, the Fund’s investment manager;
  • to the Fund’s distributors;
  • to the Fund’s depositary;
  • to the Revenue Commissioners and other tax authorities as required by applicable law, including FATCA or CRS;
  • to the Central Bank of Ireland, auditors, or other competent regulatory authorities and bodies as requested or required by law;
  • to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
  • to credit reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations; and
  • to other members of our corporate group.

Transfers of data outside the European Economic Area

In connection with the above purposes we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

Retention

We will retain your personal data for the duration of your or your company’s investment in the Fund and for such a period of time after the investment ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise.

Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

  • the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
  • the right to require us to rectify any inaccuracies in your personal data;
  • the right to require us to erase your personal data;
  • the right to request that we no longer process your personal data for particular purposes;
  • where the legal basis for processing is consent, the right to withdraw your consent at any time;
  • the right to object to our use of your personal data or the way in which we process it; and
  • in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with the Irish Data Protection Commission (info@dataprotection.ie) or your local supervisory authority.

Contact Details

Should you have any questions in relation to this notice, please contact AMX via our website or by post at 51 Lime Street, London, EC3M 7DQ.

 

Manager privacy notice

 

Last Updated: July 2019
Employees of Current and Prospective Sub-Investment Managers for the AMX Platform

Changes to Data Protection Laws – Privacy Notice

Introduction

As you will be aware, there have recently been some significant developments in European data protection law. Of particular importance is the adoption of the General Data Protection Regulation (“GDPR”).

In order to comply with our obligations under GDPR, this notice sets out details of how and why The Asset Management Exchange of 51 Lime Street, London, EC3M 7DQ. (“we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with its engagement with current and prospective sub-investment managers (“Sub-Investment Managers”) for the Asset Management Exchange CCF and the Asset Management Exchange Master ICAV (the “Funds”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to employees of Sub-Investment Managers. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a Sub-Investment Manager with which an individual is associated.

Personal Data that we Process

We collect personal data relating to you in connection with our dealings with you or your company, including your name, signature, email address, and other contact details.

Purposes of Processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

  • processing your company’s application to become a Sub-Investment Manager in connection with the Funds;
  • complying with our legislative and regulatory obligations in connection with our dealings with you or your company;
  • for direct marketing purposes, subject to any preferences you communicate to us;
  • maintaining appropriate business records;
  • statistical analysis and market research;
  • internal training and management of personnel;
  • to respond to or evaluate any queries or complaints in relation to your company;
  • internal and external audits and, where necessary, investigations; and
  • establishing, exercising or defending legal claims.

Legal basis for Processing

The legal grounds that we rely on to process your personal data are:

  • that this is necessary to comply with our legal obligations;
  • that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
    • promoting our business, and operating as the investment manager in relation to the Funds;
    • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
    • pursuing our corporate and social responsibility objectives;

Recipients of Data

We may disclose your personal data to various recipients in connection with the above purposes, including:

  • to the Funds’ Administrator;
  • to The Asset Management Exchange (Ireland) Limited, the Funds’ AIFM;
  • to the Funds’ distributors;
  • to the Funds’ depositary;
  • to auditors, or other competent regulatory authorities and bodies as requested or required by law;
  • to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
  • to other members of our corporate group.

Transfers of data outside the European Economic Area

In connection with the above purposes we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

  • the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
  • the right to require us to rectify any inaccuracies in your personal data;
  • the right to require us to erase your personal data;
  • the right to request that we no longer process your personal data for particular purposes;
  • where the legal basis for processing is consent, the right to withdraw your consent at any time;
  • the right to object to our use of your personal data or the way in which we process it; and
  • in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk) or your local supervisory authority.

Contact Details

Should you have any questions in relation to this notice, please contact  AMX via our website or by post at 51 Lime Street, London, EC3M 7DQ.

Privacy notice

On this page there are three privacy notices:

  • Privacy and cookies
  • Investor privacy notice
  • Asset manager privacy notice

Privacy and cookies

This privacy notice describes how The Asset Management Exchange (“AMX”) generally collects and processes personal information collected through www.theAMX.com and other websites controlled by AMX. The Asset Management Exchange and AMX are trading names of The Asset Management Exchange (Ireland) Limited (registered in Ireland, No. 632258; authorised and regulated by the Central Bank of Ireland), The Asset Management Exchange (UK) Limited (registered in England, No. 11555138; authorised and regulated by the Financial Conduct Authority No. 823316) and The Asset Management Exchange (IP Co.) Limited (registered in England, No. 11686713) (the “AMX Entities”). The AMX Entities are wholly owned subsidiaries of Willis Towers Watson.

This privacy notice may be revised from time to time to reflect changes in law or changes in AMX’s business operation. This privacy notice was last updated on 30 July 2021.

1. Scope of this privacy notice

This privacy notice only applies to www.theAMX.com and any other AMX website where a link to this privacy notice is provided.

Websites and specific web pages linked from www.theAMX.com may be subject to separate terms of use (including separate privacy notices). You must not use those websites (or provide Personal Information) if you do not accept such terms of use.

Where links from www.theAMX.com are provided to non-AMX websites, AMX is not responsible for those websites. These third-party websites will be governed by different terms of use (including privacy notices) and you are solely responsible for viewing and using each such websites in accordance with the applicable terms of use. AMX is not responsible for how your Personal Information is handled by such third-party websites.

2. Information we may collect from you

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.
The Personal Information we may collect through our websites includes:

  1. your name, address, occupation and other contact information;
  2. information regarding your dealings with us;
  3. any interest you have in relation to our services or our practice areas (including job openings);
  4. any information you may voluntarily submit to us by completing any form on our websites; and
  5. details of your visits to and usage of our website including the date and time of your visit, the internet address from which you visited and the resources on our website that you viewed.

We collect Personal Information in various ways:

  1. from any form you may complete and submit through our websites, for example information collected from the “Contact Us” page of our website;
  2. from the content of surveys that you may complete on our website;
  3. from ‘cookies’ and other similar tools deployed on our websites (for further information regarding cookies used on our websites, please see Section 7 below); and
  4. when you provide information as a client of an AMX entity in connection with it providing professional services to you. Such information may be collected through www.theAMX.com when clients access AMX client links within this website. Access will be subject to the terms of business AMX has with clients and any additional terms and conditions of use attached to those sites.
  5. from setting up a user profile and facilitating your access to AMXConnect.

3. Legal basis for processing personal information

We must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:

  1. for our legitimate interests, for example to provide services to our clients, to ensure that the services we provide are appropriate for our clients’ requirements, to improve our services, to enable us to comply with regulatory and governance requirements and to manage our business in an efficient way;
  2. for the legitimate interests of our clients and other third parties, for example to ensure that any financial services we provide to clients are suitable, to verify that our services are only made available to certain categories of investor and to provide a high quality of service; and/or
  3. to comply with our legal obligations, regulatory requirements and governance procedures.

When we process Personal Information to meet our legitimate interests or those of a third party, we put in place robust safeguards to ensure that the privacy of individuals is protected and to ensure that those legitimate interests are not overridden by the interests or fundamental rights and freedoms of individuals.

4. What we may do with your personal information

We may use your Personal Information in the following ways and for purposes specified in the relevant parts of the website:

  1. to facilitate your participation in interactive features you may choose to use on our websites;
  2. to correspond with you, notify you of events or changes to our services, or otherwise to respond to your queries and requests for information, which may include marketing to you;
  3. for the purposes of AMX providing professional services to you via AMX applications; such services will be subject to additional terms and conditions of use including privacy;
  4. for data analysis, audits, fraud monitoring and prevention,
  5. to enable us to comply with our legal obligations; and
  6. to monitor website usage to help us enhance, improve or modify our website and to identifying usage trends that help us determine the effectiveness of our promotional campaigns and help us to develop new products and services.

5. Disclosure of your information

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above. We may also disclose your Personal Information to independent third parties as follows:

  1. to third party service providers such as entities providing customer service, email delivery, auditing, hosting our website, our marketing activities and other services;
  2. to third parties involved with events that you register for, to facilitate your participation in those events;
  3. if we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence;
  4. in order to enforce or apply our website terms of use, or to protect the rights, privacy, safety or property of AMX, our clients, affiliates or other parties;
  5. in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
  6. in accordance with the separate terms and conditions of use that may attach to AMX website links.

6. Cross border transfer

In connection with the above purposes we may transfer your Personal Information outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.

Further details of the measures that we have taken in this regard and the territories to which your Personal Information may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Cookies and information collected from your computer

When you visit our website, our server may record your IP address for the purposes of systems administration. In most cases, your IP address is not linked to any of your Personal Information, but in limited circumstances (e.g. if you log into restricted parts of our website), your IP address can be linked to your Personal Information. AMX may also gather other non-personal information from you (from which AMX cannot identify you), such as the type of your internet browser, which AMX uses to provide you with a more effective service.

Additionally, when you visit our websites, AMX may store a ‘cookie’ on the hard drive of your computer.

Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on websites, pages visited, language preferences, and other traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using our websites and to recognize your computer in order to assist your use our websites. We also gather statistical information about use of our websites in order to improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

There are different types of cookies, for example:

  1. Cookies served directly by AMX (‘first party cookies’) and cookies served on our behalf, for example by advertisers and data analytics companies (‘third party cookies’)
  2. Cookies which endure for different periods of time, including those that only last only as long as your browser is open (referred to as ‘session cookies’) These are deleted automatically once you close your browser. Other cookies are ‘persistent cookies’, meaning that they survive after your browser is closed. For example, they recognise your device when you open your browser and browse the internet again

In order to help us improve our websites and the services we provide and to improve your experience of using our websites, our websites use several types of cookies:

Session cookies.

This type of cookie is used only on those parts of our websites that are restricted and can only be accessed by authorized users who typically authenticate themselves through their user IDs and passwords (e.g. our online client/carrier tools). This type of cookie is essential to keep authenticated users logged into our websites and to enable them to visit different parts of our websites. It will be stored on your computer for a short period (typically 48 hours) and the information held in it will be accessed automatically to authenticate you when you visit the website again. Otherwise, this cookie will be deleted when you log out and close the browser.

Google Analytics.

This cookie is provided by Google, and we use them on our websites in order to analyze how visitors use our websites, thereby helping us to improve our websites. Google Analytics collects information in an anonymous form, including the number of visitors to our websites, how visitors have arrived to our websites, and which pages on our websites the visitors have viewed.
You have the right to choose whether or not to accept cookies. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen. Go to the ‘options’ or ‘preferences’ menu on your browser to change your settings.

Hubspot.

These cookies are provided by Hubspot and we use them on our website to enable some functionality, analyse how visitors use our website and display targeted promotions. Read this article to find out more about the Hubspot cookies.

Remove Hubspot cookies
 

 

Advertising cookies.

Advertising cookies are set to display targeted promotions or advertisements based upon your interests on the sites or to manage our advertising. These cookies collect information about your activities on these and other sites to provide you targeted advertising. You can find information about advertising cookies, including how to see what cookies have been set on your device and how to manage and delete them at www.aboutcookies.orgwww.allaboutcookies.org, or www.youronlinechoices.eu.

These are the services we use and how you can control their cookies.

  • Google Ads: Google Ads is an advertising service for businesses to show ads on Google and its advertising network. Opt-out.
  • LinkedIn: LinkedIn is a business social network that allows business to show ads on its platform and advertising network. Opt-out.
  • Twitter: Twitter is a social network that allows business to show ads on its platform and advertising network. Opt-out.
  • Bing Ads: Bing Ads is an advertising service for businesses to show ads on the Bing and Yahoo ad networks. Opt-out.

Please note that if you choose not to accept cookies, this may affect the functioning of our websites.

8. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your Personal Information for as long as is necessary for the provision of any services we provide to you. When we no longer need your Personal Information in connection with any services, we will retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations or governance requirements and to defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

9. Choices and access

AMX is the controller responsible for the Personal Information we collect and process.

If you would like to review, correct, update, suppress, object to or restrict the processing of your Personal Information or request a copy of Personal Information about you, you may contact us using the details found in the “Contact” section below.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to undertake any services or requests that you initiated prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. Where that is the case, we will implement reasonable measures to ensure that this data remains secure and is not accessed or used in any way.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Information Commissioner’s Office, at www.ico.org.uk/concerns.

10. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

11. Contact

If you have any questions or comments regarding this privacy notice, please contact us at: The Asset Management Exchange, 51 Lime St, London EC3M 7DQ, or through our website.

 

Investor privacy notice

Last Updated: July 2019
Investors in Asset Management Exchange Feeder ICAV

 

Changes to Data Protection Laws – Privacy Notice

 

Introduction

As you will be aware, there have recently been some significant developments in European data protection law. Of particular importance is the adoption of the General Data Protection Regulation (“GDPR”). The GDPR will be effective from 25 May 2018.

In order to comply with our obligations under GDPR, this notice sets out details of how and why Asset Management Exchange Feeder ICAV of Riverside One, Sir John Rogerson’s Quay, Dublin 2, D02 X576, Ireland (the “Company”, “we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with investments in Asset Management Exchange Feeder ICAV (the “Fund”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to any individual investor in the Fund and personal information relating to individuals associated with corporate investors in the Fund, such as a corporate investor’s directors, shareholders, employees, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a corporate investor with which an individual is associated. Corporate investors should ensure that this notice is provided to any individual whose personal data the corporate investor has provided to us, such as its directors, shareholders, employees, and other personnel, within one month of the date of this letter.

We also refer you to our CRS Customer Information Notice contained in our subscription application form and the information under the heading “FATCA & CRS Self-Certification” and “Individual (Controlling Person’s) Self-Certification” in the subscription application form which contain certain further information relating to our use of your personal information.

 

About Us

The Company is the controller of the personal data collected via the subscription application form, which means that it determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

 

Personal Data that we Process

We collect personal data relating to you that is provided to us in the subscription application form and in connection with our dealings with you or your company in relation to investments in the Fund, including your name, signature, postal address, email address, fax number, date of birth, and other contact details.

We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including PPS number, passport number, photographic identification and verification such as copies of your passport and address verification. For the purposes of carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.

We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls, and in connection with our administration of you or your company’s investment in the Fund. We may record telephone calls for the purposes of record keeping, security and training.

In addition, we may collect personal data relating to you from third party sources in connection with complying with legislation relating to anti-money laundering, taxation, and other legislation applicable to investment funds.

We require you to complete the mandatory fields identified in our subscription application form for the purpose of entering into a contract with you or your company. Please note that some of the information required by our subscription application forms is necessary in order for us to administer your or your company’s investment in the Fund. The Administrator has the discretion to decline an application for investment in the Fund in the event that the required details are not provided.

 

Purposes of Processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

  • processing your or your company’s application to become an investor in the Fund;
  • establishing your identity, and providing, servicing and administering your or your company’s investment;
  • complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
  • for direct marketing purposes, subject to any preferences you communicate to us;
  • if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
  • to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Instrument of Incorporation;
  • maintaining appropriate business records, including maintaining appropriate registers of shareholders;
  • statistical analysis and market research;
  • internal training and management of personnel;
  • to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
  • internal and external audits and, where necessary, investigations; and
  • establishing, exercising or defending legal claims.

 

Legal basis for Processing

The legal grounds that we rely on to process your personal data are:

  • that this is necessary to comply with our legal obligations;
  • that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
    • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
    • preventing, investigating or detecting theft, fraud or other criminal activity;
    • pursuing our corporate and social responsibility objectives;
  • where you are an individual investor, that this is necessary to take steps at your request prior to entering into our contract with you and for the performance of our contract with you;
  • in certain limited circumstances, your consent.

 

Recipients of Data

We may disclose your personal data to various recipients in connection with the above purposes, including:

  • to the Administrator;
  • to The Asset Management Exchange (Ireland) Limited, the Fund’s AIFM;
  • to the Fund’s distributors;
  • to the Fund’s depositary;
  • to the Revenue Commissioners and other tax authorities as required by applicable law, including FATCA or CRS;
  • to the Central Bank of Ireland, auditors, or other competent regulatory authorities and bodies as requested or required by law;
  • to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
  • to credit reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations; and
  • to other members of our corporate group.

 

Transfers of data outside the European Economic Area

In connection with the above purposes we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

 

Retention

We will retain your personal data for the duration of your or your company’s investment in the Fund and for such a period of time after the investment ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise.

 

Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

  • the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
  • the right to require us to rectify any inaccuracies in your personal data;
  • the right to require us to erase your personal data;
  • the right to request that we no longer process your personal data for particular purposes;
  • where the legal basis for processing is consent, the right to withdraw your consent at any time;
  • the right to object to our use of your personal data or the way in which we process it; and
  • in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with the Irish Data Protection Commission (info@dataprotection.ie) or your local supervisory authority.

Contact Details

Should you have any questions in relation to this notice, please contact AMX via our website or by post at 51 Lime Street, London, EC3M 7DQ.

 

Last Updated: May 2018
Investors in Asset Management Exchange CCF

Changes to Data Protection Laws – Privacy Notice

Introduction

As you will be aware, there have recently been some significant developments in European data protection law. Of particular importance is the adoption of the General Data Protection Regulation (“GDPR”). The GDPR will be effective from 25 May 2018.

In order to comply with our obligations under GDPR, this notice sets out details of how and why The Asset Management Exchange (Ireland) Limited of Riverside One, Sir John Rogerson’s Quay, Dublin 2, D02 X576, Ireland , acting on behalf of Asset Management Exchange CCF (the “Company”, “we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with investments in Asset Management Exchange CCF (the “Fund”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to any individual investor in the Fund and personal information relating to individuals associated with corporate investors in the Fund, such as a corporate investor’s directors, shareholders, employees, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a corporate investor with which an individual is associated. Corporate investors should ensure that this notice is provided to any individual whose personal data the corporate investor has provided to us, such as its directors, shareholders, employees, and other personnel, within one month of the date of this letter.

We also refer you to our CRS Customer Information Notice contained in our subscription application form and the information under the heading “FATCA & CRS Self-Certification” and “Individual (Controlling Person’s) Self-Certification” in the subscription application form which contain certain further information relating to our use of your personal information.

About Us

The Company is the controller of the personal data collected via the subscription application form, which means that it determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

Personal Data that we Process

We collect personal data relating to you that is provided to us in the subscription application form and in connection with our dealings with you or your company in relation to investments in the Fund, including your name, signature, postal address, email address, fax number, date of birth, and other contact details.

We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including PPS number, passport number, photographic identification and verification such as copies of your passport and address verification. For the purposes of carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.

We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls, and in connection with our administration of you or your company’s investment in the Fund. We may record telephone calls for the purposes of record keeping, security and training.

In addition, we may collect personal data relating to you from third party sources in connection with complying with legislation relating to anti-money laundering, taxation, and other legislation applicable to investment funds.

We require you to complete the mandatory fields identified in our subscription application form for the purpose of entering into a contract with you or your company. Please note that some of the information required by our subscription application forms is necessary in order for us to administer your or your company’s investment in the Fund. The Administrator has the discretion to decline an application for investment in the Fund in the event that the required details are not provided.

Purposes of Processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

  • processing your or your company’s application to become an investor in the Fund;
  • establishing your identity, and providing, servicing and administering your or your company’s investment;
  • complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
  • for direct marketing purposes, subject to any preferences you communicate to us;
  • if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
  • to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Deed of Constitution;
  • maintaining appropriate business records, including maintaining appropriate registers of unitholders;
  • statistical analysis and market research;
  • internal training and management of personnel;
  • to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
  • internal and external audits and, where necessary, investigations; and
  • establishing, exercising or defending legal claims.

Recipients of Data

We may disclose your personal data to various recipients in connection with the above purposes, including:

  • to the Administrator;
  • to The Asset Management Exchange (Ireland) Limited, the Fund’s investment manager;
  • to the Fund’s distributors;
  • to the Fund’s depositary;
  • to the Revenue Commissioners and other tax authorities as required by applicable law, including FATCA or CRS;
  • to the Central Bank of Ireland, auditors, or other competent regulatory authorities and bodies as requested or required by law;
  • to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
  • to credit reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations; and
  • to other members of our corporate group.

Transfers of data outside the European Economic Area

In connection with the above purposes we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

Retention

We will retain your personal data for the duration of your or your company’s investment in the Fund and for such a period of time after the investment ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise.

Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

  • the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
  • the right to require us to rectify any inaccuracies in your personal data;
  • the right to require us to erase your personal data;
  • the right to request that we no longer process your personal data for particular purposes;
  • where the legal basis for processing is consent, the right to withdraw your consent at any time;
  • the right to object to our use of your personal data or the way in which we process it; and
  • in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with the Irish Data Protection Commission (info@dataprotection.ie) or your local supervisory authority.

Contact Details

Should you have any questions in relation to this notice, please contact AMX via our website or by post at 51 Lime Street, London, EC3M 7DQ.

 

Manager privacy notice

 

Last Updated: July 2019
Employees of Current and Prospective Sub-Investment Managers for the AMX Platform

Changes to Data Protection Laws – Privacy Notice

Introduction

As you will be aware, there have recently been some significant developments in European data protection law. Of particular importance is the adoption of the General Data Protection Regulation (“GDPR”).

In order to comply with our obligations under GDPR, this notice sets out details of how and why The Asset Management Exchange of 51 Lime Street, London, EC3M 7DQ. (“we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with its engagement with current and prospective sub-investment managers (“Sub-Investment Managers”) for the Asset Management Exchange CCF and the Asset Management Exchange Master ICAV (the “Funds”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to employees of Sub-Investment Managers. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a Sub-Investment Manager with which an individual is associated.

Personal Data that we Process

We collect personal data relating to you in connection with our dealings with you or your company, including your name, signature, email address, and other contact details.

Purposes of Processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

  • processing your company’s application to become a Sub-Investment Manager in connection with the Funds;
  • complying with our legislative and regulatory obligations in connection with our dealings with you or your company;
  • for direct marketing purposes, subject to any preferences you communicate to us;
  • maintaining appropriate business records;
  • statistical analysis and market research;
  • internal training and management of personnel;
  • to respond to or evaluate any queries or complaints in relation to your company;
  • internal and external audits and, where necessary, investigations; and
  • establishing, exercising or defending legal claims.

Legal basis for Processing

The legal grounds that we rely on to process your personal data are:

  • that this is necessary to comply with our legal obligations;
  • that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
    • promoting our business, and operating as the investment manager in relation to the Funds;
    • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
    • pursuing our corporate and social responsibility objectives;

Recipients of Data

We may disclose your personal data to various recipients in connection with the above purposes, including:

  • to the Funds’ Administrator;
  • to The Asset Management Exchange (Ireland) Limited, the Funds’ AIFM;
  • to the Funds’ distributors;
  • to the Funds’ depositary;
  • to auditors, or other competent regulatory authorities and bodies as requested or required by law;
  • to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
  • to other members of our corporate group.

Transfers of data outside the European Economic Area

In connection with the above purposes we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

  • the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
  • the right to require us to rectify any inaccuracies in your personal data;
  • the right to require us to erase your personal data;
  • the right to request that we no longer process your personal data for particular purposes;
  • where the legal basis for processing is consent, the right to withdraw your consent at any time;
  • the right to object to our use of your personal data or the way in which we process it; and
  • in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk) or your local supervisory authority.

Contact Details

Should you have any questions in relation to this notice, please contact  AMX via our website or by post at 51 Lime Street, London, EC3M 7DQ.

Privacy notice

On this page there are three privacy notices:

  • Privacy and cookies
  • Investor privacy notice
  • Asset manager privacy notice

Privacy and cookies

This privacy notice describes how The Asset Management Exchange (“AMX”) generally collects and processes personal information collected through www.theAMX.com and other websites controlled by AMX. The Asset Management Exchange and AMX are trading names of The Asset Management Exchange (Ireland) Limited (registered in Ireland, No. 632258; authorised and regulated by the Central Bank of Ireland), The Asset Management Exchange (UK) Limited (registered in England, No. 11555138; authorised and regulated by the Financial Conduct Authority No. 823316) and The Asset Management Exchange (IP Co.) Limited (registered in England, No. 11686713) (the “AMX Entities”). The AMX Entities are wholly owned subsidiaries of Willis Towers Watson.

This privacy notice may be revised from time to time to reflect changes in law or changes in AMX’s business operation. This privacy notice was last updated on 30 July 2021.

1. Scope of this privacy notice

This privacy notice only applies to www.theAMX.com and any other AMX website where a link to this privacy notice is provided.

Websites and specific web pages linked from www.theAMX.com may be subject to separate terms of use (including separate privacy notices). You must not use those websites (or provide Personal Information) if you do not accept such terms of use.

Where links from www.theAMX.com are provided to non-AMX websites, AMX is not responsible for those websites. These third-party websites will be governed by different terms of use (including privacy notices) and you are solely responsible for viewing and using each such websites in accordance with the applicable terms of use. AMX is not responsible for how your Personal Information is handled by such third-party websites.

2. Information we may collect from you

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.
The Personal Information we may collect through our websites includes:

  1. your name, address, occupation and other contact information;
  2. information regarding your dealings with us;
  3. any interest you have in relation to our services or our practice areas (including job openings);
  4. any information you may voluntarily submit to us by completing any form on our websites; and
  5. details of your visits to and usage of our website including the date and time of your visit, the internet address from which you visited and the resources on our website that you viewed.

We collect Personal Information in various ways:

  1. from any form you may complete and submit through our websites, for example information collected from the “Contact Us” page of our website;
  2. from the content of surveys that you may complete on our website;
  3. from ‘cookies’ and other similar tools deployed on our websites (for further information regarding cookies used on our websites, please see Section 7 below); and
  4. when you provide information as a client of an AMX entity in connection with it providing professional services to you. Such information may be collected through www.theAMX.com when clients access AMX client links within this website. Access will be subject to the terms of business AMX has with clients and any additional terms and conditions of use attached to those sites.
  5. from setting up a user profile and facilitating your access to AMXConnect.

3. Legal basis for processing personal information

We must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:

  1. for our legitimate interests, for example to provide services to our clients, to ensure that the services we provide are appropriate for our clients’ requirements, to improve our services, to enable us to comply with regulatory and governance requirements and to manage our business in an efficient way;
  2. for the legitimate interests of our clients and other third parties, for example to ensure that any financial services we provide to clients are suitable, to verify that our services are only made available to certain categories of investor and to provide a high quality of service; and/or
  3. to comply with our legal obligations, regulatory requirements and governance procedures.

When we process Personal Information to meet our legitimate interests or those of a third party, we put in place robust safeguards to ensure that the privacy of individuals is protected and to ensure that those legitimate interests are not overridden by the interests or fundamental rights and freedoms of individuals.

4. What we may do with your personal information

We may use your Personal Information in the following ways and for purposes specified in the relevant parts of the website:

  1. to facilitate your participation in interactive features you may choose to use on our websites;
  2. to correspond with you, notify you of events or changes to our services, or otherwise to respond to your queries and requests for information, which may include marketing to you;
  3. for the purposes of AMX providing professional services to you via AMX applications; such services will be subject to additional terms and conditions of use including privacy;
  4. for data analysis, audits, fraud monitoring and prevention,
  5. to enable us to comply with our legal obligations; and
  6. to monitor website usage to help us enhance, improve or modify our website and to identifying usage trends that help us determine the effectiveness of our promotional campaigns and help us to develop new products and services.

5. Disclosure of your information

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above. We may also disclose your Personal Information to independent third parties as follows:

  1. to third party service providers such as entities providing customer service, email delivery, auditing, hosting our website, our marketing activities and other services;
  2. to third parties involved with events that you register for, to facilitate your participation in those events;
  3. if we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence;
  4. in order to enforce or apply our website terms of use, or to protect the rights, privacy, safety or property of AMX, our clients, affiliates or other parties;
  5. in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
  6. in accordance with the separate terms and conditions of use that may attach to AMX website links.

6. Cross border transfer

In connection with the above purposes we may transfer your Personal Information outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.

Further details of the measures that we have taken in this regard and the territories to which your Personal Information may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Cookies and information collected from your computer

When you visit our website, our server may record your IP address for the purposes of systems administration. In most cases, your IP address is not linked to any of your Personal Information, but in limited circumstances (e.g. if you log into restricted parts of our website), your IP address can be linked to your Personal Information. AMX may also gather other non-personal information from you (from which AMX cannot identify you), such as the type of your internet browser, which AMX uses to provide you with a more effective service.

Additionally, when you visit our websites, AMX may store a ‘cookie’ on the hard drive of your computer.

Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on websites, pages visited, language preferences, and other traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using our websites and to recognize your computer in order to assist your use our websites. We also gather statistical information about use of our websites in order to improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

There are different types of cookies, for example:

  1. Cookies served directly by AMX (‘first party cookies’) and cookies served on our behalf, for example by advertisers and data analytics companies (‘third party cookies’)
  2. Cookies which endure for different periods of time, including those that only last only as long as your browser is open (referred to as ‘session cookies’) These are deleted automatically once you close your browser. Other cookies are ‘persistent cookies’, meaning that they survive after your browser is closed. For example, they recognise your device when you open your browser and browse the internet again

In order to help us improve our websites and the services we provide and to improve your experience of using our websites, our websites use several types of cookies:

Session cookies.

This type of cookie is used only on those parts of our websites that are restricted and can only be accessed by authorized users who typically authenticate themselves through their user IDs and passwords (e.g. our online client/carrier tools). This type of cookie is essential to keep authenticated users logged into our websites and to enable them to visit different parts of our websites. It will be stored on your computer for a short period (typically 48 hours) and the information held in it will be accessed automatically to authenticate you when you visit the website again. Otherwise, this cookie will be deleted when you log out and close the browser.

Google Analytics.

This cookie is provided by Google, and we use them on our websites in order to analyze how visitors use our websites, thereby helping us to improve our websites. Google Analytics collects information in an anonymous form, including the number of visitors to our websites, how visitors have arrived to our websites, and which pages on our websites the visitors have viewed.
You have the right to choose whether or not to accept cookies. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen. Go to the ‘options’ or ‘preferences’ menu on your browser to change your settings.

Hubspot.

These cookies are provided by Hubspot and we use them on our website to enable some functionality, analyse how visitors use our website and display targeted promotions. Read this article to find out more about the Hubspot cookies.

Remove Hubspot cookies
 

 

Advertising cookies.

Advertising cookies are set to display targeted promotions or advertisements based upon your interests on the sites or to manage our advertising. These cookies collect information about your activities on these and other sites to provide you targeted advertising. You can find information about advertising cookies, including how to see what cookies have been set on your device and how to manage and delete them at www.aboutcookies.orgwww.allaboutcookies.org, or www.youronlinechoices.eu.

These are the services we use and how you can control their cookies.

  • Google Ads: Google Ads is an advertising service for businesses to show ads on Google and its advertising network. Opt-out.
  • LinkedIn: LinkedIn is a business social network that allows business to show ads on its platform and advertising network. Opt-out.
  • Twitter: Twitter is a social network that allows business to show ads on its platform and advertising network. Opt-out.
  • Bing Ads: Bing Ads is an advertising service for businesses to show ads on the Bing and Yahoo ad networks. Opt-out.

Please note that if you choose not to accept cookies, this may affect the functioning of our websites.

8. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your Personal Information for as long as is necessary for the provision of any services we provide to you. When we no longer need your Personal Information in connection with any services, we will retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations or governance requirements and to defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

9. Choices and access

AMX is the controller responsible for the Personal Information we collect and process.

If you would like to review, correct, update, suppress, object to or restrict the processing of your Personal Information or request a copy of Personal Information about you, you may contact us using the details found in the “Contact” section below.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to undertake any services or requests that you initiated prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. Where that is the case, we will implement reasonable measures to ensure that this data remains secure and is not accessed or used in any way.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Information Commissioner’s Office, at www.ico.org.uk/concerns.

10. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

11. Contact

If you have any questions or comments regarding this privacy notice, please contact us at: The Asset Management Exchange, 51 Lime St, London EC3M 7DQ, or through our website.

Cookie Notice

© 2021 AMX. Rights reserved.