Privacy Policy

Our primary commitment to you

Calidris Investment Partners Ltd. (“CIPL”, the “Company” or “we”) is committed to respecting and protecting the privacy of every individual whose personal data we process, including clients, investors, vendors, and business partners.

We maintain strict safeguards, outlined in this written notice (the “Privacy Notice), to ensure confidential treatment and secure handling of all personal information collected or controlled by CIPL.

Our appointed Privacy Officer supervises the collection, use, sharing, and protection of your personal data

CIPL adopts robust privacy practices to meet legal obligations and uphold the rights of individuals across the various jurisdictions where we operate and where the individuals reside.

Our Privacy Officer oversees the collection, use, sharing and protection of your personal information. If you have questions about this Privacy Notice, your rights or you wish to make a complaint, please contact the Privacy Officer.

Email address: compliance@calidris.bm

CIPL complies with all relevant data protection laws and strives for consistency and high standards wherever we do business.

This Privacy Notice explains:

• What personal information we may hold or collect;
• How we may use your personal information;
• Who we may disclose your personal information to;
• Contacting us and your rights to access and update your personal information; and
• How changes to this Privacy Notice will be communicated.

What personal information do we hold or collect?

Depending on our business relationship with you, we may process:

• Your name, date of birth, nationality, residential address, source of wealth and contact details;
• Records of your visits to our website, including use of cookies, device and browser identifiers, IP addresses, web logs and usage statistics.

Sensitive data may include:

• Information relating to any criminal or fraudulent activities provided to us;
• Information used for financial crime prevention or sanctions screening.

We obtain this information directly from you and, where relevant, from public sources.

How we use your personal information

We will only process your personal information for specific, lawful purposes, including:

• To fulfil the contract we are about to enter into or have entered into with you to provide products and services;
• Where there is a reasonable expectation on our part that you would not ask us not to begin or to cease our use of your personal information;
• Where we need to comply with a legal or regulatory obligation.

 

Why we process your data

We process your personal data for the following purposes:

• To provide financial payments;
• Compliance with applicable laws and regulations as well as security, and compliance with corporate financial responsibilities;
• Website engagement and communications (see our Cookie Policy); and
• For financial Crime prevention, know your client, and anti-money laundering and anti-terrorist financing purposes.

 

With whom will the personal information be shared?

We may share your personal data with business partners, banks and service providers involved in our operations. In addition, we may share data when required by law or regulation, including authorities, courts, and auditors.

All third parties must follow our security requirements and only use information as instructed for agreed purposes. We do not permit use for unauthorised activities.

If your personal data is transferred outside Bermuda, we ensure equivalent or stronger data protection using contractual or operational safeguards

 

How long will the personal information be retained?

 

We only retain personal information for as long as necessary for stated business or legal purposes. Our retention policy varies depending on the categories of information we collect and according to applicable law. We generally hold personal information for five years, unless law or unresolved disputes with you require longer retention.

You may request deletion of your personal data–please contact the Privacy Officer for more information about your rights.

Information Security

We have put in place appropriate security measures to prevent loss, unauthorized access, alteration, or disclosure of your data. Access is restricted to authorised employees. We have breach procedures in place and will notify you and any regulators as legally required.

Your Legal Rights

Under Bermuda’s privacy laws, you have rights to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction or update of the personal information that we hold about you. We may need to verify the accuracy of the new information you provide to us.
• Request deletion of your personal information. This enables you to ask us to delete or remove personal information where there is no valid reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see “Restrict Processing” below), where we may have processed your information unlawfully or where we are required to delete your personal information to comply with local law. Note, however, that we may not always be able to comply with your deletion request for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Restrict processing of your personal information. This enables you to ask us to suspend the processing of your personal information for the purposes of advertising, marketing or public relations, or where the use of the personal information is causing or is likely to cause substantial damage or distress to you or to another individual.
• Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact the Privacy Officer by email at compliance@calidris.bm.

We may need to verify your identity before acting on any request. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.

Making a Complaint

For complaints, please contact our Privacy officer in writing at the mailing address or email provided in this Privacy Notice.

Time Limit to Respond

We aim to respond to all legitimate requests within 45 days It may take us longer for complex requests or if you have made several requests. We will notify you in these instances that we will extend the response time by up to an additional 30 days, and will keep you informed Changes to the Privacy Notice and your duty to inform us of changes

We reserve the right to make changes to this Privacy Notice without notifying you. Any changes made will become effective when the revised Privacy Notice is published on our website (www.calidris.bm/privacy).

It is important that the personal information we hold about you is accurate and up to date. Please inform us if your personal information changes during your relationship with us.