My Personal Data and Panthera
This document (our ‘Privacy Statement’) sets out how we (Panthera Private Office LLP, Panthera Investment Management Limited, Panthera Corporate Services Limited and Panthera International Asia Capital Pte. Ltd., together “Panthera”) ) use your personal data and what rights you have in relation to Panthera Controlling and Processing your data.
Personal data is information which directly or indirectly identifies you. We at Panthera are committed to processing your personal data in accordance with applicable data protection and privacy legislation in force from time to time in the UK, the Cayman Islands and Singapore including the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Data Protection Act 2018 (and regulations made thereunder) or any successor legislation, and all other legislation and regulatory requirements in force from time in the UK, Cayman Islands, Singapore and relevant jurisdictions to time which apply to a party relating to the use of personal data (including, without limitation, the privacy of electronic communications).
For the purposes of the data protection laws, Panthera Private Office LLP is the Data Controller in the UK, Panthera Investment Management Limited and Panthera Corporate Services (as relevant) is the Data Controller in the Cayman Islands, and Panthera International Asia Capital PTE. LTD is the Data Controller in Singapore.
It may be necessary for you to give us personal data so that we can provide you with the requested products and services, fulfil any contractual relationship with you, inform you of our services, comply with applicable laws, regulations and/or codes of practice and for the other purposes as set out in this notice where in our legitimate interests.
We recommend that you keep a copy of this Privacy Statement.
What personal information do we collect?
We may hold the following personal information about you and use it as we describe below:
your name, address, telephone numbers, email address(es), date of birth, place of birth, nationality, tax/residency status, passport, driving licence, utility bills, employment, banking and financial details;
demographic and lifestyle information;
information we receive when making a decision about you
information that you provide by completing forms that we provide to you;
information we obtain from running your accounts;
details of when you contact us and when we contact you (e.g. copies of any correspondence and recordings of telephone calls); and/or
together with any other information (including where obtained from third parties) which we reasonably need to operate your accounts, make decisions about you or fulfil our regulatory
You may also provide us with information about other people connected to you (such as your dependents, joint account holders or business and/or financial associates). Please ensure that you know they agree for this information to be shared with us, or that you are otherwise allowed to give us this information and direct them to our Privacy Statement. We will provide them with a copy of this Privacy Statement on request.
Special Categories of Personal Data
During our relationship with you, you may disclose to us personal information about you, your family, and your business and/or financial associates which is sensitive or intrinsically private. This includes in areas such as health, your political, religious, sexual or philosophical beliefs, or race and ethnic origin. This is known as Special Categories of Personal Data. If you disclose such information to us, we will only record this where we believe this helps us to understand your circumstances and to improve our relationship with you. There is no expectation from us that you need to provide such information by default.
You can withdraw your consent at any time by writing, emailing or telephoning us using the contact details given in the final section below.
Panthera Website
Our website does not use cookies and other device identification technologies to distinguish you from other users of our sites.
What sources do we use?
We may obtain personal information about you from a variety of sources, including:
you;
your family;
your employer (where we need relevant information to support our reporting);
people who have introduced you to us;
your business and/or financial associates;
identification and verification agencies;
credit reference agencies;
fraud prevention agencies;
electoral registers;
Companies House (and analogous registrars in the Cayman Islands and Singapore);
Where we have obtained data from a person other than yourself, and/or the source is not listed above, we will inform you of this where appropriate.
How do we use your personal information?
We will process the information we collect about you to allow us to enter into and perform a contract with you, to meet our legal and regulatory obligations, for the purpose of our legitimate interests (as detailed at the end of section 4) and where you have given us your consent. We will use it:
to process and complete your requests and/or applications for accounts and/or services;
for security and ID verification;
to process payments;
to detect and prevent criminal activity and fraudulent transactions;
to update our records and maintain your account(s) with us;
to develop and improve your accounts and/our services;
to protect ourselves against harm to our rights and property interests;
to provide specific information to our regulators and other government bodies to adhere to our regulatory, legal and compliance obligations;
Marketing messages
We will NOT send to you or your family information about products and services which we think may be of interest to you.
We will NOT send you or your family information from select organisations which we think may be of interest to you.
When is your personal information disclosed and who do we disclose it to?
People who support services we provide to third parties who are bound to keep such information secure and confidential, such as our suppliers, contractors, agents, and business partners (and their sub-contractors) who help us provide our services to you;
to payment-processing service providers;
to organisations or agencies who host or maintain data centres, service platforms and other infrastructure and systems on our behalf, where your personal information is processed and/or stored; or to our professional;
People we have obligations to give it to:
UK, Cayman Islands and Singapore regulators (as applicable) and overseas regulators and authorities in connection with their duties;
when we are required to do so as part of our duty to protect your accounts, for example Panthera Private Office LLP is required to disclose your information to the UK Financial Services Compensation Scheme (FSCS);
when we are required to comply with (i) a court order, (ii) a request from a law enforcement agency or (iii) other legal obligations;
when there is a public duty to disclose information; to comply with anti-money laundering legislation; when it is necessary to prevent bribery, fraud, terrorist financing and money laundering; to meet our obligations under the sanctions compliance regime; to reduce credit risk or recover any money you owe to us; when we may be required to share information about your accounts with the UK, Cayman Islands, Singapore or relevant tax authorities, either directly or via the local tax authority who may share that information with the appropriate tax authorities.
People you want us to give it to
to your advisers (such as accountants, lawyers, financial or other professional advisers) if you have authorised anyone like this to represent you, or any other person you have told us is authorised to give instructions or to use the account or services on your behalf (such as an attorney under a power of attorney); to a guarantor, where appropriate; when you have provided.
Our legitimate interests
in the event that we sell or buy any of our business or assets, in which case we may disclose your personal information (as a client) to the prospective seller or buyer of such business or assets, or to anyone funding the sale or purchase of such business or assets regardless of whether the sale or purchase is completed; to protect our rights, property, or safety of our employees, clients or others including in order to enforce our terms of use and other agreements.
How do we work with identity verification agencies?
We may perform searches about you using Identity Verification Agencies who supply us with identity information, as well as information about you from an Electoral Register, in order to verify your identity. Our search is not seen or used by lenders to assess your ability to obtain credit but a record is retained by the agency whether or not your application to become a client proceeds.
We will use this information to:
Verify the accuracy of the data you have provided to us; Prevent criminal activity, fraud and money laundering; Manage your account(s);
Transferring your data outside of the UK
Panthera Private Office LLP or third parties acting on our behalf, may transfer your personal information outside of the UK. We will protect your personal information in accordance with the standards set out under the UK GDPR. We do this by including strong undertakings in the contracts we put in place with those relevant parties. Additionally, we and other organisations we work with may access and use information recorded by fraud prevention agencies from other countries.
Transferring your data outside of the Cayman Islands
Panthera Investment Management Limited or Panthera Corporate Services Limited or third parties acting on our behalf, may transfer your personal information outside of the Cayman Islands. We will protect your personal information in accordance with the standards set out under the UK GDPR and applicable local legislation. We do this by including strong undertakings in the contracts we put in place with those relevant parties. Additionally, we and other organisations we work with may access and use information recorded by fraud prevention agencies from other countries.
Transferring your data outside of Singapore
Panthera International Asia Capital PTE. LTD or third parties acting on our behalf, may transfer your personal information outside of Singapore. We will protect your personal information in accordance with the standards set out under the UK GDPR and applicable local legislation. We do this by including strong undertakings in the contracts we put in place with those relevant parties. Additionally, we and other organisations we work with may access and use information recorded by fraud prevention agencies from other countries.
How long we keep your personal information for
Once your relationship with us ends, we will keep your information for a period no longer than is required by law or regulation.
If your application for an account or service is declined or you decide not to go ahead before becoming our client, we will keep your information for no longer than a period of 6 months.
Your rights
Access to your information – You have the right to request a copy of the personal information about you that we hold.
Correcting your information – We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information – You have the right to ask us to delete personal information about you where:
You consider that we no longer require the information for the purposes for which it was obtained;
We are using that information with your consent and you have withdrawn your consent;
You have validly objected to our use of your personal information – see Objecting to how we may use your information below;
Our use of your personal information is contrary to law or our other legal responsibilities.
Objecting to how we may use your information – You have the right at any time to require us to stop using your personal information.
Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking
the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information but you don’t want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
Contacting us
You may contact us, as the data controller, as follows,
Panthera Private Office LLP: Aldermary House 10-15 Queens Street London EC4N 1TX, or by calling us on 0203 861 9990. You can use these details to withdraw any of the above consents you have given us.
Panthera Investment Management Limited: Suite 6102, 62 Forum Lane, Camana Bay, Grand Cayman KY1-9006 or by calling us on +1 345 925 3111. You can use these details to withdraw any of the above consents you have given us.
Panthera Corporate Services Limited: Suite 6102, 62 Forum Lane, Camana Bay, Grand Cayman KY1-9006 or by calling us on +1 345 925 3111. You can use these details to withdraw any of the above consents you have given us.
Panthera International Asia Capital Pte. Ltd.: Level 35, The Gateway West, 150 Beach Road, Singapore 189720 or by calling us on +65 6727 4903. You can use these details to withdraw any of the above consents you have given us.
Panthera Private Office LLP
Registered office: Simpson Wreford and Partners, Suffolk House, George Street, Croydon, Surrey, CR0 0YN Registered in England No OC343083
Office Address: Panthera Private Office LLP Aldermary House 10 -15 Queen Street London EC4N 1TX
Panthera Private Office LLP is authorised and regulated by the Financial Conduct Authority. FCA
Panthera Investment Management Limited
Registered office: c/o Maples Corporate Services Limited, PO Box 309, Ugland House, Grand Cayman, KY1-1104, Cayman Islands
Office Address: Suite 6102, 62 Forum Lane, Camana Bay, Grand Cayman KY1-9006, Cayman Islands
Panthera Investment Management Limited is registered with and regulated by the Cayman Islands Monetary Authority (Registration Number 2070142).
Panthera Corporate Services Limited
Registered office and office address: Suite 6102, 62 Forum Lane, Camana Bay, Grand Cayman KY1-9006, Cayman Islands
Panthera Corporate Services Limited is licensed and regulated by the Cayman Islands Monetary Authority (Licence Number 2091040).
Panthera International Asia Capital Pte.Ltd.
Registered office and office address: Level 35, The Gateway West, 150 Beach Road, Singapore 189720.
Panthera International Asia Capital Pte.Ltd. is authorised and regulated by the Monetary Authority of Singapore (Licence Number CMS101735).
