Cubera – Privacy notice
Cubera is a group of companies located in Norway and Sweden, providing fund advisory and management services through the legal entities Cubera Private AS (989 580 353) and Cubera Private Equity AB.
The information contained in this privacy notice is aimed at individuals who are the contact person of any of Cubera’s clients, for those who seek work with Cubera or otherwise individuals contacting Cubera and thus share personal information with Cubera. Any capitalised letters shall be understood as defined in this privacy notice.
The “owner” of the personal data, the company to which a person has submitted such information (the data controller), may be Cubera or a client of Cubera. In the latter case, Cubera will act in the role as data processor. We will handle personal data in accordance with an agreement with the data controller.
Cubera may collect personal data from many sources, both public and private. The information may be used by Cubera to enhance our service offerings, and otherwise to communicate with our clients and network and to transmit newsletters. Over time, Cubera also create personal data by documenting our interactions with you, from updating your accounts etc. The term personal data typically includes:
· Contact details, name, address, email addresses, telephone numbers etc.;
· Information required to meet legal and regulatory requirements in respect of anti-money laundering legislation, including details such as gender, date of birth, passport number(s), other government issued number(s), nationality, images of passports and driving licences, signatures, occupation, source of funds and source of wealth;
· Information required to meet legal and regulatory requirements relating to the automatic exchange of tax information (e.g. FATCA and CRS), including details of tax residency, tax classification and tax identification numbers;
· Financial details, including billing address; bank account numbers; instruction records; transaction details and counterparty details;
· Details of meetings and telephone calls with our office and employees; and
· Any other information you may provide to us or might be provided to us by our clients, third parties etc.
Cubera will normally not hold information which is considered sensitive personal data. This includes information on racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Cubera will only disclose personal data to third parties if it is i) specifically agreed between Cubera and the relevant individual, ii) necessary within the scope of a specific engagement agreement to safeguard individuals’ rights, iii) necessary for Cubera to comply with a legal obligation or decision from a public body/authority or court decision or iv) following signed non-disclosure agreements, to third parties conducting a due diligence process on Cubera. Cubera is obliged to report suspicions of money-laundering to public authorities (No. Økokrim / Sw. Finanspolisen).
Cubera will only store personal data for as long as it is necessary to fulfil a legitimate purpose for which Cubera collected it, or as necessary for fulfilling any statutory retention period according to for example anti-money laundering-, bookkeeping- or accountancy legislation. After any statutory retention period, Cubera will either delete or destroy the relevant personal data permanently or irreversibly anonymise this information.
Handling personal data – data processing
Cubera will primarily process your personal data within the EU/EEA. If Cubera engages third-party service providers domiciled outside the EU/EEA, Cubera will act with due diligence to ensure that your personal data is processed in a manner that ensures security and confidentiality. Should in our opinion this not be possible, Cubera will not share your personal data without your consent.
If Cubera holds any of your personal data, you:
· may request information from Cubera on how we process your personal data
· may request that Cubera amends, completes and rectifies your personal data should you believe information is wrong or misleading
· may request that Cubera does not use your personal data for direct marketing
· may request that Cubera disclose designated parts of your personal data to a third party that you instruct.
· may request that Cubera deletes personal data. Note however, that Cubera may be obligated by law to keep certain information for a certain period of time.
· have the right to be notified by Cubera of a personal data breach which is likely to result in your personal data being available for unwanted third parties.
If you are dissatisfied with Cubera’s processing of your personal data you may file a complaint with the Data Supervisory Authority of the country where you live or work, or with those regulating any of Cubera’s entities.
Cubera is required by law to control the identity of its clients and their ultimate beneficial owners, and from time to time their source of wealth and other related information. This is an example of a legitimate purpose of which there are several.
There are a number of legitimate purposes in the operation of Cubera’s business:
· Financial crime prevention
· FATCA/CRS reporting
· Client / investor onboarding
· Issuing contractually agreed reports etc. to you
· Legal compliance
· Legal proceedings
· Risk management
· Relationship management
Security, work related to securing data, electronic systems etc.
Please note that Cubera does not require your consent to process your personal data when there is a legitimate purpose.
If you apply for a job position in Cubera, the information you submit will not be shared with any third parties. Access to the information will be restricted to Cubera employees involved in the recruitment process. If you are not hired, Cubera will delete all personal data.
When communicating with Cubera, you are responsible for ensuring that the Personal Data you send is sent securely.
Any questions relating to this privacy notice or requests in respect of information which may identify you as an individual (personal data) processed by Cubera should be directed to firstname.lastname@example.org. Cubera reserves the right to modify or amend this document at any time and an updated version of it will be placed on our website www.cubera.no.