This Data Protection Notice provides information about data that is collected, recorded, organized, structured, stored, altered, retrieved, used, or transmitted by Orchard Global Asset Management LLP, Orchard Global Asset Management (S) Pte Ltd, OGAM Ltd, and OGAM, LP, (collectively “Orchard Global” or the “Firms”), and Orchard Global’s commitment to appropriately using and protecting the data collected.
This Data Protection Notice applies to both clients and employees of Orchard Global. When you use our services and/or are under our employment, you acknowledge that you have read and understand the contents of this Data Protection Notice.
“We”, “us” and “our” as used in this statement refers to each and any of the Orchard Global entities and establishments listed (as the context requires) as responsible for data processing.
“You” and “your” as used in this statement refers to individuals:
- with whom we come into contact, or in respect of whom we obtain personal data, in the usual course of dealings with our clients, our service providers, and our other business counterparties or transaction participants, which may include, without limitation, employees, directors, officers, beneficial owners and other personnel of such clients, service providers, business counterparties or transaction participants, in all cases outside the Orchard Global group; or
- who themselves are our clients.
Why Does This Policy Exist?
This Data Protection Notice ensures Orchard Global:
- Complies with Data Protection laws and follows good practices
- Protects the rights of its clients, employees, and partners
- Is open about how OGAM stores and processes personal data
What Personal Information Do We Collect?
Orchard Global does not collect more information than is needed. The following are examples of the type of Personal Information that we may collect:
- Government Identification
- E-mail Address
- Job Title
- Birth Date
- Tax ID
- Bank Account Information
- Information about your financial situation (e.g., source of wealth, incomes, benefits, mortgage information, and shareholdings)
- Background Check Data
- Telephone Recordings
- CCTV Video Footage
- Medical Data
- Online information (e.g., cookies and IP address, if you visit the Orchard Global’s website)
- Other data similar to the broad categories mentioned above.
How Do We Collect Information?
- When you engage us for and in relation to any of our services, whether in writing, orally or through our website, and/or attend any of our events and/or meetings (e.g., registration forms, subscribe to our mailing list, and photographs, videos and/or audio recordings taken by us or our representatives at our events and/or meetings).
- When you interact with our staff, appointed service providers and other representatives, for example, via telephone calls, letters, fax, face-to-face meetings, and emails.
- When you submit your personal data to us for any other reason (whether voluntary or otherwise).
Information from Websites:
Some information may automatically be collected as you browse our website(s), such as type of browser, operating system, domain cookies or IP addresses. This information is stored in necessary session cookies, and is deleted whenever a session ends or the browser is closed. Orchard Global may also capture your image and/or footage through CCTV recordings when you participate in our hosted event(s) or are within our premises.
Where your use of Orchard Global’s website is concerned, you acknowledge and accept that certain functions, when activated or used by you, will operate to send or display information about yourself, including but not limited to, your personal data to certain third parties, and you agree to the sharing of such information with these third parties. You acknowledge and agree that we shall not be held responsible or accountable for any loss, injury or damage sustained by you for sharing the aforesaid information arising out of your activation or use of such features on the website.
Information from Other Sources: Orchard Global may also collect your personal information from other sources, such as public databases and domain, joint marketing partners, or through background checks.
Do We Need Consent to Collect Your Data?
There may be circumstances where Orchard Global asks for your consent to process your personal data. As long as you have granted us this consent, this processing is legal on the basis of that consent. You can withdraw your consent at any time by contacting the compliance team of Orchard Global via email (firstname.lastname@example.org). Withdrawal of consent does not affect the legality of data processing carried out prior to withdrawal.
How Do We Use Personal Information?
Personal information is used for specific business purposes and use is limited, where necessary. Additionally, employee access to personal information is granted on an as-needed basis. Orchard Global may use your personal information for the following purposes:
- To perform our obligations in the course of providing our services;
- To manage our relationship with you and facilitate the provision of our services;
- To facilitate business operation(s);
- To facilitate completion of any requests from you;
- To send you marketing communications in accordance with your communication preferences;
- For our business purposes, such as accounting, payroll, tax filings, and medical benefits;
- To conduct background and hiring checks;
- Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- Statistical, analysis, planning and reporting
- To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and
- Any other incidental purposes related to or in connection with the above. When the data is collected, this above information will be provided in greater detail and as it specifically pertains to your data.
Who Do We Share Personal Information With?
Privacy is an integral part of our organization. We never sell any of your personal information to third parties. Additionally, we will not share your personal information with third parties without your specific consent or unless Orchard Global is required to by law and/or government authorities or under any other legitimate purpose such as performance of a contract.
Third parties that we share personal information with are required to provide adequate protection and are prohibited from using your personal information for purposes other than those that were specified upon receipt of your data. Examples of third parties that we may share your personal information with include, but are not limited to:
- Our authorized service providers and suppliers who provide services, such as server and cloud hosting and storage, data analysis, email delivery, fund administration, payroll, medical insurance, and other similar services;
- Our affiliate entities and subsidiaries for the purposes described in this Data Protection Notice;
- A third party in the event of any contemplated or actual re-organization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stocks; and
- Government authorities in order to comply with appropriate laws and/or requests.
What Security Measures Do We Have?
Orchard Global has technical and administrative safeguards in place to help protect data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please contact us for a copy of Orchard Global’s policies for more information on our information security practices and procedures at email@example.com.
Will my data be transferred to a third country or an international organisation?
In certain circumstances, Orchard Global may transfer your data to another country outside of your country of residence. You understand that the data protection legislation in such other country may not give you as much protection as the data protection legislation in the country where you are located. In such instances, Orchard Global shall ensure that the transfer of your personal data is carried out in accordance with any applicable laws and that appropriate safeguards (e.g. contractual, technical and organisational measures) are put in place before such transfer takes place. In any event, for transfers to third countries which have not been determined as countries offering an adequate level of data protection, we will either rely on a derogation applicable to the specific situation (e.g. if the transfer is necessary to perform our contract with you such as when making an international payment), or implement standard contractual clauses to ensure the protection of your personal data.
How Long Do We Retain Personal Information?
We will retain your personal information for the period necessary to fulfill our services and the purposes outlined in this Data Protection Notice unless a longer retention period is required or permitted by law.
Do We Perform Automated Decision-Making and Profiling?
We do not use computer algorithms to make automatic decisions that are based on your personal information.
What Rights Do I Have?
We will always fulfill any rights that concern the protection of your personal information, including, but not limited to the:
- Right to withdraw your consent to the processing of your personal information;
- Right to object to the processing of your personal information for any purpose;
- Right to access your personal information free of charge for a single copy;
- Right to rectification of your personal information;
- Right to erasure of your personal information. We may continue to retain your personal data if Orchard Global is entitled or required to retain it;
- You have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller without hindrance from us;
- Please note that some of the above rights are subject to limitations in some situations, and that the exercise of the above rights may affect our ability to continue a business relationship with you; and
- If applicable, you also have a right to make a complaint to your local data protection supervisory authority.
If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you for the third-parties’ direct marketing purposes. If you wish to exercise this right, please email us at firstname.lastname@example.org. For additional information about your rights pursuant to California Consumer Privacy Act (“CCPA”), please look refer to the section below “Additional Information for California Resident”.
How Can You Manage Your Personal Information?
If you would like to request, delete, or update the personal information that you provided us, or exercise any of your data protection rights you may contact us via email at email@example.com. For your protection, we will need to verify your identity prior to complying with your request. Orchard Global does not charge for this service.
We will make a good faith effort to provide access to requested data without undue delay. However, Orchard Global reserves the right to limit or deny access to personal information where providing such information would be unreasonably burdensome or expensive or as otherwise permissible under relevant laws. If we determine that access cannot be provided in any particular instance, we will provide the individual requesting access with an explanation of why it has made that determination and a contact point for any further inquiries. For more information about this service, please contact us at firstname.lastname@example.org.
Additional Information for California Residents
- Notice at collection and use of personal information
We may collect the categories of personal information about you directly from you and/or your intermediaries through sources such as listed above in What Personal Information Do We Collect: (i) account applications, subscription agreements, and other forms; (ii) written, electronic, or verbal correspondence with use or our service providers; (iii) investor transactions; (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or (v) from information captured on applicable websites.
We may also collect your personal data through various sources such as (i) our affiliates, our service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or (iii) from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.
- Collection, use, disclosure and sharing of personal information
Orchard Global may also use the personal information collected for business purposes as ascribed above in How Do We Use Personal Information. We wish to emphasise that we do not and will not sell your personal information. In the preceding twelve (12) months, we may have disclosed for business purposes the following categories of personal information (described in more details above in What Personal Information Do We Collect and How Do We Use Personal Information for the following purpose:-
With Third Party Service Providers Performing Services on Our Behalf.
Orchard Global shares your personal data with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, provide data analysis and research Site, to send out email updates about the Site or remove repetitive information from our user lists.
For Legal Purposes.
We also may share personal data that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions.
Orchard Global will disclose personal data as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal data as required to pursue available remedies or limit damages we may sustain.
- California residents’ rights under CCPA
Should your information be subject to CCPA, you may have certain rights concerning that information which includes:-
- Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used;
- Request that we delete any personal information about you that we have collected or maintained, subject to certain exceptions (“request to delete”). We reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you where permitted by the CCPA or where another law or regulation is applicable;
- Request that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months (“Request to Know”); and
- Not be discriminated against because you exercised any of your rights under the CCPA
Please note that the CCPA does not apply to certain information, including, generally, personal information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations. Orchard Global also reserves the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.
- How to submit a request under CCPA
You may submit a Request to Know or Request to Delete, through email us email@example.com. We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. Any information gathered as part of the verification process will be used for verification purposes only.
Where Can This Data Protection Notice Be Accessed?
This Data Protection Notice is accessible through:
- Our website: and
- Our contracts, agreements, and other necessary documents.
If you have questions, concerns, or suggestions related to our Data Protection Notice or our privacy practices liaise with your normal coverage personnel at Orchard Global, or please navigate to our ‘Contact’ page and get in touch with your local office.
Changes to this Data Protection Notice
We reserve the right to change our Data Protection Notice from time to time. If we decide to change our Notice, we will notify you of these changes as appropriate through various possible channels (e.g., bulletin board in our website, email, “last updated” date at the end of this Notice).