Privacy Policy

1. Who we are

INV Global Group Ltd is a company that provides investment administration services. The firm keeps subscription papers, distribution calendars, portfolio filings, investor statements, registry corrections and annual return binders in order for investment managers, family offices and private holding companies. The registered and operating address is 124-128 City Road, London - EC1V 2NX, United Kingdom (GB). The contact email address for privacy matters is invest@invglobal.mom and the contact telephone number is +12344283220.

For the purposes of data protection law in the United Kingdom, INV Global Group Ltd is the data controller in respect of the personal information that it collects and uses in the course of running the filing room. Where the firm acts on the written instruction of a client in respect of that client own investor records, the firm acts as a processor for the client, and the client privacy notice governs the underlying relationship. This policy describes the firm own processing as a controller and explains how the firm handles personal information in either capacity.

The firm does not offer investment advice, does not manage portfolios and does not recommend any product to any person. Its work is administrative. That narrow scope matters for this policy because it limits the categories of personal information the firm needs and the reasons for which that information is used.

2. Information we collect

The firm collects only the personal information that is needed to run the filing room and to answer the people who contact it. The categories are described below. Not every category applies to every person, and the firm does not seek information that a particular task does not require.

Identity and contact details

• Full name, title and any former name recorded on a paper or a register.
• Postal address, email address and telephone number.
• Date of birth where a paper requires it for verification.
• Nationality and tax residence where a statutory form requires it.

Subscription and registry information

• Details of commitments, holdings, transfers and distributions recorded against a folio.
• Signatures, dates and the capacity in which a person signed a paper.
• Bank account details used for the payment of distributions, where provided for that purpose.
• Correspondence about a correction, a statement query or an annual return.

Technical and usage information

• The internet protocol address from which the website is accessed.
• The browser type, device type and operating system used to view the website.
• The pages viewed, the time of the visit and the referring page.
• Any message sent through the contact form, including the name and email address entered.

Special category information

The firm does not seek special category personal information such as health data, political opinions or religious beliefs. If such information is sent to the firm without request, the firm will handle it with the same care as other information, will limit its use to the purpose for which it was sent, and will delete it where it is not needed. Persons who are asked for such information by a third party in connection with a transaction should raise the request with that third party before sending anything to the filing room.

3. How we collect information

Most of the personal information held by the firm arrives on paper or in a signed electronic document. Subscription papers, statements, correction requests and annual return schedules are the normal sources. The firm also collects information when a person writes to invest@invglobal.mom, telephones +12344283220, completes the contact form on the website or attends an appointment at the City Road office.

Some information is received from a client rather than from the person concerned. For example, an investment manager may send a subscription paper that names several investors, or a family office may provide a schedule of holdings that includes the names and addresses of family members. Where the firm receives information in this way, it relies on the sending client to have a proper basis for sharing it and to have given the required notices to the persons concerned. The firm records the source of every paper so that the origin of an entry can be traced.

Technical information is collected automatically when the website is visited, as described in the section on cookies and similar tools below. The firm does not attempt to identify individual visitors from that technical information, and it does not combine it with the paper records held in the filing room.

4. Why we use information

The firm uses personal information for a short list of purposes, each of which is connected to the administration of an investment structure or to the operation of the website.

• To register, check and file the papers that arrive at the filing room.
• To prepare and release distributions in accordance with a published calendar.
• To produce and issue investor statements on an agreed cycle.
• To record corrections and maintain the accuracy of a register.
• To assemble and bind annual returns and to answer questions about them.
• To respond to enquiries made by email, telephone or the contact form.
• To meet accounting, tax and statutory record keeping obligations.
• To detect and prevent fraud, misuse of the practice and unauthorised access.
• To improve the clarity and accessibility of the website.
• To enforce the terms on which the firm provides its services.

The firm does not use personal information for automated decision making that produces legal effects for a person, and it does not build profiles of individuals for advertising. Where a client asks for a report that groups investors by size or type, that report is prepared from administrative data and is not used to make any decision about an individual.

5. Lawful basis for processing

The firm relies on one or more of the following lawful bases, depending on the activity. Performance of a contract applies where the firm is engaged to provide administration services and needs information to carry out that engagement. Legal obligation applies where a law requires the firm to keep a record, to report information or to verify identity. Legitimate interests applies to the running of the filing room, the protection of records and the answering of reasonable enquiries, where those interests are not overridden by the rights of the person concerned. Consent applies to any optional communication, such as a request to receive a newsletter, which the firm would offer only if a person asks for it and which can be withdrawn at any time.

Where the firm handles personal information as a processor on behalf of a client, the client is responsible for the lawful basis and for giving notice to the persons concerned. The firm processes that information only on documented instructions and in accordance with the contract between the firm and the client.

6. Cookies and similar tools

A cookie is a small file placed on a device by a website. The firm website is deliberately simple and uses only the minimum necessary to function. The firm does not use advertising cookies, does not run a behavioural tracking network and does not sell information gathered from visitors.

Where a strictly necessary cookie is used, it supports the basic operation of the site and is not used for any other purpose. Where an analytical tool is used, it is configured to avoid identifying individuals and to avoid collecting more information than is needed to understand whether the site is working. A visitor can block or delete cookies through the settings of the browser, and the site will continue to function.

The contact form on the website does not use a cookie to store the content of a message. When a visitor presses the send button, the browser opens a mail program on the visitor own device with the content addressed to invest@invglobal.mom. The firm receives the message only when the visitor chooses to send it from that program.

7. Sharing information

The firm shares personal information only where there is a reason to do so and only to the extent needed. The categories of recipient are described below.

• Service providers who support the filing room, such as secure hosting, printing, courier and document storage providers, under written terms that require confidentiality.
• Professional advisers, such as auditors, accountants and solicitors, where their work requires sight of a record.
• The client on whose instruction a paper is held, where the firm acts as a processor.
• Banks and payment providers, where a distribution or a subscription requires a payment to be made.
• Public authorities, courts and regulators, where a law requires disclosure or where disclosure is necessary to establish or defend a legal claim.
• A successor organisation, where the practice or a part of it is transferred, subject to equivalent protections.

The firm does not sell personal information and does not rent mailing lists. It does not share information with advertisers. Where a service provider needs access to records, the firm limits that access to the specific task, requires confidentiality, and reviews the arrangement from time to time. Where a request for information comes from a public authority, the firm checks that the request is properly made before responding and records the disclosure.

8. Transfers outside the United Kingdom

The filing room is in London and most records stay there. Some service providers may operate systems outside the United Kingdom, and where that happens the firm takes steps to ensure that the information continues to receive a comparable level of protection. Those steps may include the use of a contract approved by the appropriate authority, a documented assessment of the destination, or an arrangement within an organisation that applies binding rules.

Where a client instructs the firm to send information to a party outside the United Kingdom, the client is responsible for the legal basis and for any notice required in respect of that transfer. The firm will record the instruction and will send the information by the secure method agreed with the client. A person who wishes to know more about the safeguards used for a particular transfer may write to invest@invglobal.mom.

9. How long we keep information

Records are kept for as long as they are needed for the purpose for which they were created, and for the period required by law. Investment administration records are often needed long after a transaction has closed, because a question about a distribution or a register entry can arise years later. The firm therefore applies retention periods that reflect the long life of a filing.

• Subscription papers and registry records are kept for at least six years after the end of the relationship to which they relate, and longer where a holding remains open.
• Distribution calendars and release papers are kept for at least six years after the end of the financial period to which they relate.
• Annual return binders are kept for the period required by the applicable company or tax law.
• Enquiries that do not lead to an engagement are kept for twelve months and then deleted.
• Technical logs are kept for a short period sufficient to operate and protect the website.

At the end of the retention period a record is deleted or destroyed in a secure manner, unless there is a legal hold, a live complaint or an investigation that requires the record to be kept. Where a record is kept beyond the usual period for one of those reasons, the reason is noted so that the record can be disposed of once the matter is closed.

10. How we protect information

The firm protects personal information through a combination of physical and organisational measures. The filing room is a controlled space, papers are held in locked cabinets when the room is not attended, and access to the registry drawer board is limited to the staff who work on the relevant file. Electronic records are held in access controlled systems, are protected in transit, and are backed up so that a failure does not destroy a record.

Staff receive training on confidentiality and on the correction procedure. A correction to a register is made only with supporting evidence and is recorded on an amendment slip, which helps to prevent an unauthorised change from going unnoticed. Access rights are reviewed when a staff member changes role or leaves, and the review is documented.

No system is perfect. If a security incident occurs, the firm contains it, assesses its effect, records what happened and notifies the appropriate authority and any affected person where the law requires. The firm also takes steps to prevent a recurrence and reports the outcome internally. A person who believes that a communication pretending to be from the firm is not genuine should not act on it and should contact the firm at +12344283220.

11. Your rights

A person whose information is held by the firm has rights under data protection law. The firm will respond to a request within one month, and will explain if a longer period is needed. There is normally no charge, although a reasonable fee may be charged where a request is manifestly unfounded or excessive.

• The right to be informed about how information is used, which this policy provides.
• The right of access to the personal information held, together with an explanation of its use.
• The right to correction where information is inaccurate or incomplete.
• The right to erasure where there is no good reason for the firm to continue to hold the information.
• The right to restrict the use of information while a question about it is resolved.
• The right to object to processing based on legitimate interests.
• The right to data portability in respect of information provided to the firm, where that right applies.
• The right to withdraw consent where processing is based on consent, without affecting processing already carried out.
• The right not to be subject to a decision based solely on automated processing that produces legal effects.

A request may be made by writing to invest@invglobal.mom or by post to 124-128 City Road, London - EC1V 2NX, United Kingdom (GB). The firm will need to confirm identity before releasing information, and will ask for enough detail to locate the record. Some rights are limited where the firm is required by law to retain a record, or where a client instruction governs the record and the request must be passed to that client. In such a case the firm will explain the position and will assist the person in reaching the right party.

12. Marketing and preferences

The firm does not run a marketing campaign and does not send promotional email to persons who have not asked for it. If the firm ever offers a briefing or a note about filing practice, it will be sent only to persons who have asked to receive it, and every message will include a simple way to stop receiving it. A request to stop is honoured promptly and is recorded so that the preference is not lost.

Contact information given in the course of an engagement is used for the administration of that engagement and not for unrelated promotion. The firm will not pass an email address to an advertiser or a list broker. A person who receives an unexpected message that appears to come from the firm should check the sender address and report the message to invest@invglobal.mom before responding.

13. Privacy for children

The services of the firm are intended for adults and for organisations. The firm does not knowingly collect personal information from a child under the age of sixteen except where a statutory form or a family settlement requires a child to be named. Where such information is held, it is used only for the administration of the record and is protected in the same way as any other registry information.

If a parent or guardian believes that a child has sent personal information to the firm without appropriate consent, they should write to invest@invglobal.mom. The firm will look into the matter and, where the information is not required for a legal record, will delete it. Where the information forms part of a register that the firm is required to keep, the firm will explain what is held and will correct any error found.

14. Links to other websites

The website may contain links to other websites, for example the site of a regulator or a professional body. Those websites are not controlled by the firm and their privacy notices may differ from this one. The firm is not responsible for the content or the practices of another website, and a link does not imply endorsement of that website or of its handling of personal information.

A person who follows a link should read the privacy notice of the destination before providing personal information. If a link on the firm website appears to lead somewhere unexpected, the firm would welcome a note at invest@invglobal.mom so that the link can be checked.

15. Changes to this policy

The firm reviews this policy from time to time and updates it where the way information is handled changes or where the law requires a change. The date at the top of the page shows when the policy was last updated. Where a change is significant, the firm will take reasonable steps to bring it to the attention of clients and of persons whose information is held.

A person may ask for a copy of an earlier version of this policy by writing to invest@invglobal.mom. The firm keeps previous versions so that the history of its commitments remains clear. Continued use of the website or of the services after a change takes effect indicates acceptance of the updated policy, but the firm will not rely on that alone where a specific consent is required.

16. Complaints

The firm takes a complaint seriously whether it concerns a paper, a statement, a distribution or the handling of personal information. A complaint should be sent in writing to invest@invglobal.mom with a short description of the matter and any reference number that has been given. The firm will acknowledge the complaint, investigate it, and respond with an explanation and, where appropriate, a remedy.

Where a person is not satisfied with the response, they may raise the matter with the Information Commissioner Office, which is the supervisory authority for data protection in the United Kingdom. The firm would encourage a person to contact the firm first so that the matter can be resolved directly, but the right to approach the authority is not affected by doing so.

17. How to contact us

Questions about this policy, requests to exercise a right, and complaints about the handling of personal information should be sent to the firm at the following details. Please include a telephone number or an email address so that a reply can be sent promptly.

A letter sent to the City Road address reaches the filing room directly. An email to invest@invglobal.mom is read by a member of the registry desk on each working day. A telephone call outside business hours is answered on the next working morning. The firm aims to respond to privacy questions within five working days and to complete a formal request within one month.