Overseas Asset Management Cayman Ltd. (“OAM”). Privacy Statement

The Cayman Islands Data Protection Law (as revised) (“DPL”) governs the use of Personal Data by Cayman Islands entities. We recognise the importance of protecting the privacy of subscribers and shareholders in the OAM Funds and hereby, in accordance with the DPL, set out our Privacy Policy in relation to Personal Data. Any terminology and capitalised terms used in this Notice bear the meanings as prescribed in the DPL unless the context requires otherwise.

It should be noted that OAM does not transfer personal information you provide to any third parties for their own direct marketing use.

OAM may Process the following types of Personal Data:

(a) Personal Data provided by you (including within forms, correspondence, transactions and remittance instructions) to OAM including: your name, address, contact information, birthdate, gender, nationality, photograph, signature, occupational history, job title, income, assets, holdings in the OAM Funds, historical and pending transactions in the OAM Fund’s shares and the values thereof, other financial information, source of funds, bank details, credit and investment history, source of funds, tax residency, and tax identification information;

(b) Personal Data collected or generated by OAM including: information related to your emails (and related data), correspondence, call recordings, and website usage data; and

(c) Personal Data obtained by OAM from other sources, including: know your client (Know Your Client) (“KYC”) / client due diligence procedures (anti-money laundering (“AML”), counter-terrorist financing, proliferation financing, sanctions, politically exposed persons), tax purposes (US Foreign Account Tax Compliance Act (“FATCA”), OECD Common Reporting Standard (“CRS”)), future regulatory, securities and tax requirements, information from public websites, public sources of information (bankruptcy registers, credit reference agencies), publicly accessible directories, and information received from your advisors or intermediaries.

Please ensure that you provide a copy of this Data Protection Privacy Policy to any third parties whose Personal Data you provide to OAM. This Data Protection Privacy Policy may be updated at any time and OAM will notify you in writing of any changes.

Purposes of Processing and Legal Basis for Processing 

Personal Data provided by you, collected or generated by OAM, or obtained by OAM from other sources in relation to your application to subscribe for Participating Shares in the OAM Funds will be held, disclosed, and Processed by OAM for the following purposes:

This use of your Personal Data is necessary for performance of your contract with us.  

This use of your Personal Data is necessary in order for us to comply with any legal or regulatory obligations. 

The day to day running and management of OAM including to: 

This use of your Personal Data is necessary for our legitimate business interest in managing our business including legal, personnel, administrative and management purposes and for the prevention and detection of crime provided our interests are not overridden by your interests.

Recipients of Personal Data and International Transfer of Data 

OAM may disclose your Personal Data as follows

In relation to any other third parties, we will only disclose your information in the following circumstances:

(a)             where you have given your consent;
(b)             where we are required to do so by law or enforceable request by a regulatory body; 
(c)             where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights; or
(d)             if we transfer management or control of the OAM Funds.

International Transfers 

Personal Data will be held in, and may be freely transferred between, countries that are located inside the European Union (EU) and third countries that have adequate protection for your rights in relation to the Processing of your Personal Data, and otherwise where the transfer is:

(a)             made with your consent;

(b)             necessary for the performance of a contract between the individual and the organisation, or for pre-contractual steps taken at the individual’s request;

(c)             necessary for the performance of a contract made in the interests of the individual between the controller and another person; 

(d)             necessary for the establishment, exercise or defence of legal claims;

(e)             made in regard to public data on a public register, and any conditions subject to which the register is open to inspection are complied with; 

(f)              made on terms of a kind approved by the Ombudsman as ensuring adequate safeguards for the individual(s);

(g)             authorised by the Ombudsman as ensuring adequate safeguards for the individual(s); or,

(h)             required under international cooperation arrangements between intelligence agencies or regulatory agencies, if permitted or require under an enactment or an order issued by the Grand Court of the Cayman Islands.

Where a Personal Data transfer is made to a jurisdiction which provides a level of data protection lower than that prescribed by the DPL, OAM will take steps to ensure the security and confidentiality of your Personal Data in accordance with the DPL. Such steps may include establishing contractual undertakings with service providers who process Personal Data on our behalf.

Retention period 

OAM will retain your Personal Data for a minimum period of 7 years from the date on which you redeem all of your Participating Shares in the OAM Funds or for as long as required for OAM to perform the services or comply with applicable legal/regulatory obligations.

Consequences of not Providing Required Data

Where OAM requires your Personal Data to comply with AML or other legal, regulatory and tax requirements which arise from collecting fees and making investments as described in the OAM Fund’s offering documents, failure to provide this information means OAM may not be able to accept you as an investor in the OAM Funds and/or may be unable to process, or release your investment in the OAM Funds. This may result in OAM terminating its relationship with you. We will tell you when we ask for your information whether it is a statutory or contractual requirement to give us the information and the consequences of not providing the information.


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Data Subject Rights   

You have various rights in relation to your Personal Data, including the right to request access to your personal information, correct any mistakes on our records, erase or restrict records where they are no longer required, object to use of personal information based on legitimate business interests, ask not to be subject to automated decision making if the decision produces legal or other significant effects on you, and the right to submit a complaint.

We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after of receipt of your request. In exceptional cases, we may extend this period by two months and we will tell you why. We may request proof of identification to verify your request. For more details in relation to your rights, including how to exercise them, please see our full privacy policy or contact us at This email address is being protected from spambots. You need JavaScript enabled to view it..

You may lodge a complaint with the Cayman Islands Ombudsman at This email address is being protected from spambots. You need JavaScript enabled to view it.. For further information regarding your Personal Data rights, please see the Ombudsman’s website at www.ombudsman.ky