The Arabesque Group is committed to protecting and respecting your private data and information. Accordingly, this Policy sets out the basis upon which any personal data and information that the Arabesque Group collects from you, or that you provide to the Arabesque Group, will be processed by us. Reference to the Arabesque Group herein refers to the following entities: Arabesque Asset Management Limited & Arabesque AI Limited (Jamestown Wharf, 32 Jamestown Road, London, NW1 7BY, United Kingdom); Arabesque Deutschland GmbH (Lindleystr. 8A, Frankfurt am Main, Germany); and Arabesque Asset Management Singapore Pte. Limited (18A Gemmill Lane, Singapore, 069255) and branches of the foregoing (“Arabesque” or “Arabesque Group”).
- Who are we and what do we do?
The Arabesque Group consists of two core operational divisions: asset management and artificial intelligence. In conducting its activities, the Arabesque Group collects personal data and information from the following types of people in order to enable the Arabesque Group to offer and provide our services:
- Investors and potential investors in collective investment schemes and/or managed accounts for which we act as investment manager;
- Fund distributors and other business partners (e.g. local paying agents, fund trading platforms, consultants);
- Clients and prospective clients to which we provide artificial intelligence products and services;
- Supplier and vendor contacts to support the services that we provide; and
- Employees, consultants, temporary workers and potential employees.
2. Information you give to us or we collect about you
This includes any data and information about yourself that you give to the Arabesque Group in connection with the provision of our services and/or by corresponding with us by telephone, email, in writing or otherwise.
It can include data and information that you provide to us when you enquire about, or invest in, a collective investment scheme for which we act as investment manager, subscribe to our mailing lists and/or attend events or meetings organised by us in connection with our asset management activities. It includes information that you provide to us when you appoint us as the investment manager of your managed account, and/or attend events or meetings organised by us in connection with our financial services business. It includes information that you provide to us in connection with our artificial intelligence business.
The information that you provide to the Arabesque Group, or that we collect from you, may include your name, address, date of birth, private and/or corporate email address, private and/or corporate telephone number, specific and general financial information, sensitive documentation and other data and information which relates to, amongst other things, your background, circumstances, investment experience, and information pertaining to your employment including obtaining information from public registers with governmental and/or quasi-governmental organisations (e.g. the Financial Conduct Authority), copies of identification documents such as a passport or driving licence, photographs, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, other forms of social media and/or a corporate website.
The Arabesque Group also uses ‘Cookies’ to automatically collect certain information about visits to the Website which helps us to make improvements relating to Website content and navigation. It may include your IP address, the date, times, and frequency with which you access the Website, and the way you use and interact with its contents. Please refer to our Cookies Policy set out on our website.
3. Purposes of the processing and legal basis for the processing
The Arabesque Group uses the data and information that we hold in relation to you, in the following ways:
- To enable us to carry out our discretionary investment management activities;
- To enable us to conduct our artificial intelligence business activities;
- To enable us to comply with our regulatory and legal record-keeping obligations;
- To provide you with periodic updates as to the performance of the collective investment schemes or managed accounts in respect of which the Arabesque Group acts as investment manager;
- To carry out our obligations arising from any contractual obligations amongst us, arising through us acting as an investment manager;
- To provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to you, your organisation and/or the shares/units that you hold in a collective investment scheme or managed account for which Arabesque acts as investment manager;
- To provide you with information about other products and services that the Arabesque Group offers that are similar, or ancillary, to those that you have already been provided with or have enquired about.
The key legal basis for the processing of your personal data and information is our legitimate business interest, described in more detail below. Furthermore we may also, in certain circumstances, rely on a contractual or legal obligation and/or consent for specific uses of data and information. Where we retain your data and information in fulfilment of a legal and/or regulatory obligation, in doing so, we will rely on legal obligation to hold such data and information.
4. Our legitimate business interests
The asset management division of the Arabesque Group provides a range of investment management services to a number of collective investment schemes and a number of managed accounts. In this capacity, the exchange of personal data and information between: us; you; the collective investment schemes and/or managed accounts (for which we act as investment manager); certain third parties (appointed to provide ancillary services directly related to the provision of our discretionary investment management activities); and global governmental and quasi-governmental agencies, is a fundamental and essential part of our business. In order to support those collective investment schemes and managed accounts for which we act as investment manager, we maintain databases of personal data and information of investors or prospective investors in such collective investment schemes and managed accounts which contain both current and historical information of the kind described within section 2 above. In order to maintain, expand and develop our business we must record the personal data and information of investors and prospective investors in the collective investment schemes that we manage.
The artificial intelligence division of the Arabesque Group offers and provides artificial intelligence products and services to a range of corporate clients. In this capacity, the exchange of personal data and information between us, you, third party vendors, and other third parties (appointed to provide ancillary services directly relate to the provision of our artificial intelligence services) is a fundamental and essential part of our business. In order to support our artificial intelligence business activities, we maintain databases of personal data and information relating to clients and prospective clients which contain both current and historical information of the kind described within section 2 above. In order to maintain, expand and develop our business we must record the personal data and information of clients and prospective clients of the artificial intelligence products and services that we provide.
5. Disclosure of your information inside and outside of the EEA
The Arabesque Group may disclose information about you to our affiliates, and/or third parties.
For the purposes of the Arabesque Group’s business activities this may include, but is not limited to: the administrator, the prime brokers and the custodians of the collective investment schemes and/or managed accounts that are managed by the Arabesque Group, third parties which facilitate the provision of our artificial intelligence products and services. Moreover, your data and information will be used for our everyday business purposes, such as the provision of asset management activities; the maintenance of your account(s) or responding to court orders and legal investigations. It may also be necessary, under anti-money laundering and other regulations and laws, to disclose information about you to regulatory authorities and other relevant governmental and quasi-governmental organisations. We will also release information about you if you direct us to do so.
We do not share your information with non-affiliates for them to market to you.
In addition to the above, we may also disclose your personal information to third parties in the following circumstances:
- Where the Arabesque Group buys or sells a business and/or asset, we may disclose your personal data and information to a prospective buyer or seller of such a business or assets;
- If the Arabesque Group or substantially all of its assets are acquired by a third party, the personal data and information held by us about our customers and/or investors will be one of assets transferred as a result thereof.
The lawful basis for the third-party processing will include:
- The third party’s own legitimate business interests in processing your personal data and information, in most cases to facilitate the provision of the ancillary services to us and/or the collective investment schemes and/or managed accounts for which we act as investment manager;
- Satisfaction of a third party’s contractual obligations to us as our data processor;
- For the purpose of a contract in place or in contemplation with a third party;
- To fulfil a third party’s legal and/or regulatory obligations.
6. Where we store and process your personal data and information
The data and information that the Arabesque Group collects from you may be transferred to, and/or stored at, a destination outside of the European Economic Area (“EEA”). It may be transferred to third parties outside of the EEA to enable us to provide our discretionary investment management services and/or artificial intelligence products and services. Your data and information may also be processed by staff operating outside of the EEA who work for the Arabesque Group or for one of our suppliers. This includes staff engaged in, amongst other things, the provision of discretionary investment management services, the provision of and/or artificial intelligence products and services. By submitting your personal data and information, you agree to this transfer, storing and/or processing. The Arabesque Group will take all reasonable steps to ensure that your data and information is treated securely and in accordance with this Policy.
7. Retention of your data and information
The Arabesque Group understands that is has a legal duty to retain accurate data and information and to only retain personal data and information for as long as it is required for the legitimate business interests, as outlined herein, and only where you are happy for us to do so. Accordingly, we maintain a data retention policy to ensure that we only retain data and information in accordance with this Policy.
8. Your rights
The GDPR provides you with the following rights:
- To request the correction of the personal data and information that we hold about you. This is to ensure that the data and information that we hold in relation to you in complete and accurate.
- To request the erasure of your personal information thus enabling you to ask the Arabesque Group to delete or remove personal data and information in circumstances where there is no legitimate purpose for the Arabesque Group to continue holding such data and information. You also have the right to ask the Arabesque Group to delete or remove your personal information where you have exercised your right to object to processing (per the provisions set forth below).
- To object to processing of your personal information in circumstances in which we are relying on a legitimate interest and/or those of a third party, as outlined herein above, and there is something in respect of your specific circumstances which provides you with grounds to object to the processing of your data and information. You also have the right to object where we are processing your personal information for direct marketing purposes.
- To request that the Arabesque Group restricts the processing of your personal data and information. This would enable you to ask the Arabesque Group to suspend the processing of your personal data and information, for example if you want us to establish its accuracy or the purpose for such data and information being processed.
- To request the transfer of your personal information to another party in certain formats, if practicable.
- To make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office (https://ico.org.uk) and in Germany is the German Federal Commissioner for Data Protection and Freedom of Information (BfDI) (BfDI – Startseite (bund.de)) or the Hessian Commissioner for Data Protection and Freedom of Information (Startseite | datenschutz. hessen.de)
9. Access to information
The Data Laws give you the right to access your data and information held by the Arabesque Group. Your right of access can be exercised in accordance with the Data Laws, as described herein. Subject access request should be submitted to firstname.lastname@example.org.
11. Contact details
For the purposes of data protection legislation in force from time to time the data controller is Arabesque Holding Ltd and its affiliates within the Arabesque Group.