Privacy Notice

This Privacy Notice (the “Notice”) and any agreement entered into by you and Higher Ground SICAV plc sets out the basis on which Higher Ground SICAV plc uses your personal information. For the purposes of the General Data Protection Regulation (“GDPR”) the data controller is Higher Ground SICAV plc, 171 Old Bakery Street, Valletta, VLT 1455, Malta.

Higher Ground SICAV plcis committed to protecting your personal information and respecting your privacy. Higher Ground SICAV plcwill use your personal information fairly and lawfully.

If you are viewing this Notice on www.higherground.mt (the “Site”), you accept that your use of the Site indicates your consent to the practices described in this Notice.

Whose personal information is collected?

Higher Ground SICAV plc collects and uses information about the following groups of individuals:

  • Clients, investors and beneficiaries (current, prospective and former) and any of their directors, officers, employees, partners, shareholders or agents;
  • Suppliers and service providers;
  • Professional advisers and consultants;
  • Individuals who contact Higher Ground SICAV plc and its Administrator (Apex Financial Services (Malta) Ltd.) by email, phone or otherwise and any visitors to the Site;
  • Employees, contractors and other members of staff (current, prospective and former); and

Types of personal information

Higher Ground SICAV plc may collect and use personal information that is:

  • Directly provided by you;
  • Related to services provided to you by Higher Ground SICAV plc;
  • Received from your representatives or advisers;
  • Received from third parties, including administrators of products advised by Higher Ground SICAV plc;
  • Collected using cookies and other technologies when visiting the Site; or
  • Sourced from public sources.

Purposes for collection of personal information

Higher Ground SICAV plc may use the information held about you to:

  • Provide you with information about Higher Ground SICAV plc performance and newsletters;
  • Process your subscription or investment in Higher Ground SICAV plc sub-funds;
  • Fulfil any contract between you and Higher Ground SICAV plc;
  • Fulfil any legal, regulatory or self-regulatory requirement that applies to Higher Ground SICAV plc;
  • Ensure that the Site is effectively presented for you and for your computer or device;
  • Administer the Site; and
  • Respond to any enquiry or complaint raised by you.

Higher Ground SICAV plc may also combine any information that you provide with the information received from other sources. This combined information may be used for the purposes set out above.

Sharing your information

Higher Ground SICAV plc may share your personal information with any other company associated with Higher Ground SICAV plc for the purposes set out above.

Higher Ground SICAV plc may share your personal information with selected third parties including:

  • Business partners, suppliers and sub-contractors for the performance of any contract Higher Ground SICAV plc enters into with them or you;
  • Marketing providers that assist with the delivery of information to you;
  • Analytics providers that assist in the improvement of the Site; and
  • Administrators, custodians, depositaries and directors of Higher Ground SICAV plc in connection with your subscription or investment.

If applicable, where you have notified us of your adviser, information provided may be shared with such adviser. You must notify us in writing if you no longer wish us to share information with your adviser or of any change to your adviser. Your adviser should have its own arrangements with you about its use of your information.

Higher Ground SICAV plc may also share your personal information with third parties in the following circumstance:

  • If there is a duty to share your personal information in order to fulfil any legal, regulatory or self-regulatory requirement that applies to Higher Ground SICAV plc.

The security of your information

Higher Ground SICAV plc is committed to protecting information that you provide. Physical, electronic and procedural safeguards are used to protect your information against unauthorised access, disclosure or loss. Authorised access to personal information is limited to only those employees, contractors and agents with a need to know, and is subject to strict confidentiality obligations.

Where Higher Ground SICAV plc stores your personal information

The information that Higher Ground SICAV plc collects from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by Higher Ground SICAV plc or Higher Ground SICAV plc’s suppliers operating outside of the EEA for the purposes set out above. By submitting your personal information to Higher Ground SICAV plc, you agree to this transfer, storing or processing. Higher Ground SICAV plc will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with the Notice.

Your rights

The Act gives you the right to access information held about you and to request that such information is not used for any particular purpose (for example to provide you with information about performance of our investment programs, publications, or research). You can exercise these rights by writing to:

The Compliance Officer,
Apex Financial Services (Malta) Ltd.
obo Higher Ground SICAV plc
Central North Business Centre
Level 1 Sqaq
il-Fawwara
Sliema SLM1670
Malta

Changes to this Notice

Any changes Higher Ground SICAV plc may make to this Notice will be posted on the Site. Please check back frequently to see any updates or changes to this Notice.

Issued: May 2018