privacy & cookies policy

AMCAP MANAGEMENT LTD (“us” or “we”) respects your privacy, is strongly committed to protect your privacy and wants to be transparent about the data it collects and how data is used. This Privacy and Cookies Policy applies to the personal data which is collected and processed through your use of this website www.amathus.capital including inter-alia any data that our website visitors and subscribers (“you”) may provide through this website. This Privacy and Cookies Policy does not apply to information collected and processed by other means (including inter-alia third party websites). By using our website, you consent to the data practices, described in this Privacy and Cookies Policy.

It is important that you read this Privacy and Cookies Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy and Cookies Policy supplements other notices and privacy policies and is not intended to override them.

We are a data controller in respect of such personal data. This means that we are responsible for determining the purposes and means of the processing of such personal data.

For the purposes of this Privacy and Cookies Policy, ‘Personal Data’ means any information relating to an identified or identifiable natural person and ‘Processing’ means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, storage, use, disclosure, erasure or destruction.

Pursuant to the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”) and The Protection of Natural Persons against the Processing of their Personal Data and the Free Movement of such Data Law of 2018 (L.125(I)/2018), as amended and other applicable data protection laws, as amended from time to time, we are required to notify you of the information contained herein.

This website is not addressed to anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18 and if we become aware that we have collected Personal Data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.

When we collect your Personal Data, we ensure that it is:

(i) Processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);

(ii) Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; (‘purpose limitation’);

(iii) Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);

(iv) Accurate and, where necessary, kept up to date; every reasonable step is taken to ensure that Personal Data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);

(v) Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the Personal Data are processed (‘storage limitation’);

(vi) Processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

We will process your Personal Data (as and where applicable) for the purposes of:

(i) the operation, management and control of the affairs of our business and its purposes including inter-alia our website;

(ii) maintaining and improving the contents of our website;

(iii) providing any information to you about our business and/or our affairs;

(iv) general planning and organisation of our business and/or our website;

(v) maintaining and developing our business relationship with you, the carrying out of surveys and direct marketing (including inter alia for subscription to our newsletters and/or other marketing material)

(vi) maintaining our IT systems, administrative and management systems, processes and policies; and

(vii) complying with any requirement of law and/or regulation and/or of any competent authority or professional body (where applicable) of which we are a member.

We may share your Personal Data with the following categories of recipients:

(i) other member companies and/or entities of and/or affiliated entities to the group of companies which we belong to;

(ii) our public relations and marketing service providers and third-party website providers;

(iii) our contractors, vendors and/or other business associates;

(iv) our IT service providers and other companies who assist us with the effective operation of our website by providing technological expertise, file storage and record management, logistic services and solutions and other subcontractors; and

(v) public and regulatory authorities and other competent authorities of which we are a member and/or are licensed under (where applicable), for the purposes described above.

When we transfer Personal Data to countries located outside of the EEA we carry out such transfers (i) to a recipient who is in a country which provides an adequate level of protection for Personal Data or (ii) to a recipient who is in a country which does not provide an adequate level of protection for Personal Data, under appropriate safeguards pursuant to the provisions of applicable data protection laws (e.g. under an agreement in the form of standard data protection clauses adopted by the European Commission), the form of which is available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en. In some (occasional) cases we may carry out such transfers where (a) we have obtained the explicit consent from the relevant data subject in respect of the proposed transfer, provided that the data subject has been informed of the possible risks of such transfer (due to the absence of an adequacy decision and appropriate safeguards); (b) the transfer is necessary for the performance of a contract between the data subject and us, or (c) the transfer is necessary for the performance of a contract concluded in the interest of the data subject between us and another person or (d) the transfer is necessary for the establishment exercise or defense of legal claims.

We shall process and store your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and/or as required under any applicable law. We may retain your Personal Data for longer periods for the purposes of our legitimate interests in case of any complaints or legal process commencing.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.