1. INTRODUCTION
At OneIM, we respect your privacy and are committed to protecting your personal data (that being any information about you from which you can be identified, but does not include data where your identity has been anonymised). This policy: explains when and why we collect personal data about you and other people who visithttps://www.oneimgroup.com/ (the “Website”); how we use it; the circumstances when we may disclose it to others; and how we keep it secure. This only applies to the collection of your personal data by OneIM and the use of that information by OneIM and those whom we share it with. does not cover third party websites to which we may provide links, nor does it cover advertisers. They may have their own privacy policies and/or terms and conditions of use which you should review and understand separately.This privacy policy is provided in a layered format so you can click through to the specific are asset out below. Please read this policy carefully to understand our practices regarding your personal data.
2. WHO ARE WE?
OneIM Group is the controller of, and is responsible for, your personal data (referred to as “OneIM”,“we”, “us” or “our” in this privacy policy). When we use the word “you” or “your” in this policy, it means you as a visitor of the Website, or as a person who provides their details to us when contacting us using the details provided on the Website. This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
3. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows: Identity Data includes first names, last name, username or similar identifier, title and date of birth. Contact Data includes email address and telephone numbers. Technical Data includes information about how you use our Website including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity and/or Contact and Financial Data by corresponding with us by email or otherwise. Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details. Third parties or publicly available sources. We may receive personal data about you from various third parties and publicly available sources including Technical Data from analytics providers, advertising networks and search information providers such as Google.
5. WHAT LAWFUL BASIS DO WE RELY ON FOR PROCESSING YOUR PERSONAL DATA?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:• where you have provided your consent. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. where we need to comply with a legal obligation. Where we rely on our legitimate interests, we make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you(unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
6. HOW DO WE USE YOUR PERSONAL DATA?
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Cookies We use a cookies tool on our Website to obtain your consent for the optional cookies we may use. Cookies that are necessary for functionality, security and accessibility are set and are not deleted by the tool. You can read more about how we use cookies, and how to change your cookies preferences, in our cookie policy. Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose in which case we will provide you will further details. Please note that we may process your personal data without your knowledge or consent, in compliance with this policy, where this is required or permitted by law.
7. WHO DO WE SHARE YOUR DATA WITH?
We may share your personal data with third parties for the purposes set out in the table at Section 6 (How Do We Use Your Personal Data?) and to any third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties that process your personal data on our behalf to respect the security of your personal data, to treat it in accordance with the law and only process your personal data for specified purposes and in accordance with our instructions.
8. INTERNATIONALDATA TRANSFERS
We may share your personal data with third parties based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: The country of the recipient has been deemed to provide an adequate level of protection for personal data by the UK Government. Where we use certain service providers, we may use standard contractual clauses approved by the UK Government which give personal data the same protection it has in theUK.Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
9. HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
We have appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.If we identify a personal data breach, we will notify you and any applicable regulator of that breach where we are legally required to do so.
10. HOW LONG DO WEKEEP YOUR PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.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.
11. WHAT ARE YOUR LEGAL RIGHTS?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights. Request access to your personal data. Commonly known as a data subject access request, this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data. Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you may do so. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request transfer of your personal data. Commonly known as the right to data portability, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use (e.g., cookie information). Right to withdraw consent. Where we are relying on consent to process your personal data, such as for direct marketing, you can withdraw that consent at any time. 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. Right to make a complaint. You can make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Exercising your rights. If you wish to exercise any of the rights set out above, you can email us at contact@oneimgroup.
12. CHANGES TO THIS POLICY
We keep our privacy policy under regular review. This version was last updated on 22 November 2022
We may update this policy from time to time and will post any changes on the Website. You should check back occasionally and read through it again.
USA
One Investment Management US LLC ("OneIM US") is a limited liability company registered in Delaware. The principal place of business is at Lever House, 390 Park Avenue, New York, 10022 NY, US. OneIM US is registered with the United States Securities and Exchange Commission ("SEC") as an investment adviser under the US Investment Advisers Act of 1940, as amended. Additional information about OneIM US is available on the SEC’s website www.adviserinfo.sec.gov.
Registration with the SEC does not imply a certain level of skill or training.Information contained on this website is not an advertisement and does not constitute an offer of any securities or investment advisory services. Any offering may only be made pursuant to applicable securities laws, an offering document and related subscription materials all of which must be read and completed in their entirety. This is not an offering of investment services or any interest in any fund or product managed or advised by OneIM US. Any market prices, data and other information are not warranted as to completeness or accuracy and are subject to change without notice. Any comments or statements made herein do not necessarily reflect those of OneIM US.Please see the important information, including regarding the processing of personal data by OneIM US, at oneimgroup.com/privacy.
UK
One Investment Management Group UK Ltd is registered in England and Wales with company number 14373773, its registered office is at 25 Park Lane, London, United Kingdom, W1K 1RA. One Investment Management Group UK Ltd (FRN: 995823) is an appointed representative of Kroll Securities Ltd. (FRN 466588) which is authorised and regulated by the Financial Conduct Authority.
Nothing on this website is intended as, or constitutes, marketing of any financial products or services, including of any fund in the United Kingdom or any member state of the European Economic Area within the meaning of the Directive 2011/61/EU on Alternative Investment Fund Managers.
None of the information on this website constitutes a financial promotion within the meaning of section 21 of the UK Financial Service and Markets Act 2000. Such information is exclusively intended for, and directed only at, persons who meet the definition of a professional client under Article 2(1)(8) of Regulation (EU) No 600/2014 on markets in financial instruments as it forms part of the laws of England and Wales by virtue of the European Union (Withdrawal) Act 2018 and as amended, and who are: (i) Investment Professionals within the meaning of Article 19 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (the “FPO”); (ii) High Net Worth Companies and certain other entities falling within Article 49 of the FPO; or (iii) any other persons to whom such information may be lawfully provided.
Nothing on this website constitutes investment advice, an investment recommendation, or an offer of any services or products for sale and it is not intended to provide a sufficient basis on which to make an investment decision.
The information contained on this website may not be treated as an offer or solicitation in any jurisdiction where such an offer or solicitation is contrary to law.
ADGM
The information contained on this website may not be treated as an offer or solicitation in any jurisdiction where such an offer or solicitation is contrary to law. One Investment Management Ltd is registered in the Abu Dhabi Global Market with company number 000009021, its registered office is at Suites 505, 506, 507, 11th Floor, Al Sarab Tower, Adgm Square, Al Maryah Island, Abu Dhabi, United Arab Emirates. One Investment Management Ltd is regulated by the ADGM Financial Services Regulatory Authority (FSRA). Nothing on this website is intended as, or constitutes, marketing or offer of any financial services or products. None of the information on this website constitutes a financial promotion, offer of units or offer of securities within the meaning of the ADGM’s Financial Services and Markets Regulations 2015 and the FSRA’s rulebooks. Such information is exclusively intended for, and directed only at, persons who meet the definition of a professional client under the FSRA’s Conduct of Business Rulebook. Nothing on this website constitutes investment advice, an investment recommendation, or an offer of any services or products for sale and it is not intended to provide a sufficient basis on which to make an investment decision. The information contained on this website may not be treated as an offer or solicitation in any jurisdiction where such an offer or solicitation is contrary to law.