Global Privacy Notice

The protection of your personal data is important to us. We process your data in accordance with the EU General Data Protection Regulation (“GDPR”), and the Irish Data Protection Act together with applicable data protection laws in the jurisdictions where Innocap Global conducts its business.

This Privacy Notice applies to the website of Innocap Group (the “Website”). It has been prepared to provide you with information on the processing of personal data by the Innocap Group, as a data controller. We reserve the right to change this Privacy Notice at our sole discretion without prior notice. Any amendments become applicable from the time they are published on our Website. Your continued use of our website after amendments are made is deemed acceptance of those changes.

Where Innocap Group are appointed by clients, we may process Personal Data as a data processor, acting upon instruction by clients acting in their capacity as data controllers. This activity is outside the scope of this Privacy Notice. The Personal Data collected, the purpose of collecting, the means of collecting and the retention period are all determined by our clients, the data controllers and outlined in their respective Data Protection Information Notices or similar documents.

Innocap group has separate privacy notices for the processing of personal data of employees and contractors.

This is the Global Privacy Notice of the Innocap Group, which includes the following entities:
•  Innocap Investment Management Inc. (“Innocap Inc.”)
•  Innocap Global Investment Management (Ireland) Ltd
•  Hedgemark Advisors LLC
•  Hedgemark Risk Analytics LLC
•  Hedgemark Securities LLC
•  Hedgemark Technologies Private Limited
•  Innocap Poland sp.z.o.o.

Data protection related queries may be directed to Innocap Inc.’s privacy officer at dataprotection@innocap.com.

References in this notice to “Innocap”, “we”, “us” or “our” are references to the Innocap Group and, where relevant, of the above-mentioned entities.

We are committed to processing your personal data in a responsible and transparent manner.

References in this notice to “you” or “your” are references to individuals whose personal data Innocap processes in connection with client services, supplier services, or visitor services.

For the avoidance of doubt, any reference in this policy to our “clients” or “third party/ies” includes their employees or other staff whose personal data we might process.

The scope of information collected and the basis for processing will vary depending on the purpose for such processing.

Innocap relies on the following lawful bases for the processing of Personal Data:

• where necessary for the performance of a contract.
• where necessary for compliance with a legal obligation to which innocap is subject.
• Your consent (e.g. when you sign up for marketing material or ask us to contact you, this consent can be withdrawn at any time)
• where necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom your personal data is provided. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:

○ Conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
○ Preventing, investigating or detecting theft, fraud or other criminal activity;
○ Pursuing our corporate and social responsibility objectives

For website visitors, cookies use is limited to language preferences only. In addition, Google Analytics and the hosting server are collecting certain data for statistical and error log purposes only. For more information on how Google Analytics collects and processes data you may refer to: https://policies.google.com/technologies/partner-sites.

For current and potential clients, Personal Data may also be collected from you and processed as part of our due diligence and onboarding process and to comply with our legal and regulatory obligations. Such data may include some or all of the following: name, signature, postal address, email address, date and place of birth, nationality, professional or employment related information, source of funds details, tax identification, signatures, other contact details, account numbers (or functional equivalent) and transaction details, your tax or social security ID number or equivalent, utility bills for the purposes of address verification, photographic identification and verification such as copies of your passport, passport number and driver’s license, information relating to your status as an ultimate beneficial owner of an entity, a politically exposed person or a designated individual on a sanctions list.

We process your Personal Data for the purposes of delivering a service to you, for the purposes of maintaining appropriate business records, including maintaining appropriate registers and documentation required under applicable law and regulation, for the purposes of quality control, business and statistical analysis.

We may collect and process Personal Data relating to you in connection with our on-going relationship with you, such as via correspondence and calls, and in connection with the administration of our relationship with you.

For job applicant, process may vary from an Innocap entity to another. Please refer to this job applicant data privacy notice.

Applications are generally made directly to Innocap or our partner recruitment agencies. If you apply for a role directly with Innocap, you will generally receive written notification from Innocap of receipt of your application. The Global Privacy Notice will be included as part of the job posting and the latest version is also always accessible on Innocap’s website. Your CV will be reviewed, and should your skill set, and experience match a current vacancy your application may be progressed to interview stage.

Innocap holds applications and additional information which may be obtained during the course of the interview process, such as interview notes, education qualifications etc. electronically and/or manually.

Your information may be shared within entities of the Innocap Group, and our agents or partners in connection with services that these individuals or entities perform for the relevant Innocap entity, including recruitment agencies. These agents or partners are restricted from using this personal data in any way other than to provide specified recruitment related services to the relevant Innocap entity.

We will retain all data in accordance with our Retention of Records Policy and to the extent permitted by law. Retention periods will vary depending on the purpose for which we are using your data and applicable laws and regulations.

As a firm with a global presence, we offer our clients a follow-the-sun model and, as a result, personal data collected in one jurisdiction may be transferred, stored and processed in another jurisdiction by any entity of the Innocap Group (including to non-EEA countries). Such transfer will only occur in compliance with applicable data privacy regulations and may be subject to safeguards, including but not limited to inclusion of confidentiality clauses in the agreements between relevant Innocap Group entities.

Data privacy regulations applicable to our activities have several key common principles including lawfulness, fairness and transparency in the processing of personal data, purpose limitation, storage limitation, integrity, confidentiality and accountability. Key rights for individuals are presented below per country/region of residence.

EU Residents

The General Data Protection Regulation includes the following rights for individuals in relation to their personal data, in certain circumstances and subject to certain exemptions:

•  right to access the data – you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
•  right to rectification – you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
•  right to erasure – you have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.

•  right to restriction of processing or to object to processing – you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
•  right to data portability – you have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format.

In order to exercise any of the rights set out above, please contact Innocap Inc.’s Privacy Officer: dataprotection@innocap.com.

If we are processing personal data based on your consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing which took place prior to its withdrawal.

If you are unhappy with how we process personal data, we ask you to contact us so that we can rectify the situation.

You may lodge a complaint with a supervisory authority. The Irish supervisory authority is the Data Protection Commission. You may refer to section 8. below for information on data protection regulation applicable in our other locations.

You may browse our website without providing us with any personal data and this will not affect your ability to view our website.

However, if you do not provide us with your information for the purposes described above, we may not be able to provide you with requested services, including access to client portal.

We do not use any personal data for the purpose of automated decision-making or profiling.

Our website may contain links to external websites. If you click on one of these links, please refer to their own data privacy notices. We do not accept any responsibility or liability for those notices. Please refer to such notices prior to sharing any personal data on such external websites.

Canada (Quebec)
Act Respecting the Protection of Personal Information in the Private Sector (as amended)
Commission d’accès à l’information (in French)
Cayman Islands
Data Protection Act (as amended)
Cayman Islands Ombudsman
USA (California)
California Consumer Privacy Act (as amended)
California Privacy Protection Agency