Privacy Policy

Privacy Policy for EnigmaTCG Investment Managers Ltd

Effective Date: 6th of January 2025

At EnigmaTCG Investment Managers Ltd ("EnigmaTCG", "we", "our", or "us"), we are committed to protecting your privacy and ensuring that your personal data is handled in a secure and responsible manner. This Privacy Policy outlines how we collect, use, store, and protect your personal information when you engage with our services.

1. Information We Collect We collect personal information from you in the course of providing our investment management services, including:

• Personal Identifiable Information (PII): This includes your name, address, email address, phone number, date of birth, financial information, and other details required for investment management.
• Investment Data: Information about your investments, investment preferences, and financial situation to help us tailor our services to your needs.
• Communication Data: Any communications between you and EnigmaTCG, including email, phone calls, or other methods of contact.
• Website Usage Data: Data regarding your interaction with our website, including IP address, browser type, pages visited, and time spent on our site. We use cookies to enhance your experience.

2. How We Use Your Information We use your personal information for the following purposes:

• To provide investment management services and investment opportunities.
• To comply with legal and regulatory obligations, including those required by the Financial Services Commission (FSC) of Mauritius and the Financial Conduct Authority (FCA) of the United Kingdom.
• To process transactions and manage your investment portfolio.
• To communicate with you regarding our services, updates, and any important information related to your investments.
• To improve our services and website functionality.

3. Legal Basis for Processing Your Information We process your personal data based on the following legal grounds:

• Contractual Necessity: To fulfill our obligations under any agreements we have with you, such as managing your investments.
• Legal Obligation: To comply with applicable laws, including those set by regulatory authorities such as the FSC and FCA.
• Legitimate Interest: To improve our services, manage our website, and communicate effectively with you.
• Consent: Where required, we will seek your consent before collecting or processing certain types of data, particularly for marketing purposes.

4. Sharing Your Information We do not sell, rent, or share your personal information with third parties for marketing purposes. However, we may disclose your personal data to the following parties:

• Regulatory Authorities: To comply with legal and regulatory requirements, including the FSC, FCA, and other relevant bodies.
• Service Providers: We may share your information with trusted third-party service providers who assist us in providing our services, such as custodians, auditors, and legal advisors.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of our business, your personal data may be transferred as part of the transaction.

5. Data Security We employ robust security measures to protect your personal information from unauthorized access, use, or disclosure. These measures include encryption, secure servers, firewalls, and other physical and technical safeguards. While we strive to protect your data, please note that no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

6. Retention of Data We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including complying with legal, regulatory, and reporting obligations. After this period, your data will be securely deleted or anonymized.

7. Your Rights You have the following rights regarding your personal information:

• Access: You can request a copy of the personal data we hold about you.
• Correction: You can request that we correct any inaccurate or incomplete data.
• Deletion: You can request that we delete your personal data, subject to certain conditions.
• Restriction of Processing: You can request that we restrict the processing of your personal data in specific circumstances.
• Objection: You can object to the processing of your personal data in certain situations.
• Data Portability: You can request that we transfer your personal data to another service provider in a structured, commonly used, and machine-readable format.

To exercise your rights or if you have any questions about how we handle your personal information, please contact us at the details below.

8. International Transfers As part of our services, your personal data may be transferred to and stored in countries outside the European Economic Area (EEA), including Mauritius. When we transfer personal data outside the EEA, we ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws.

9. Cookies and Tracking Technologies Our website uses cookies and similar tracking technologies to improve user experience, analyze website traffic, and for marketing purposes. You can control cookies through your browser settings. For more information, please refer to our Cookie Policy.

10. Updates to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting an updated version on our website or contacting you directly.

11. Contact Information If you have any questions or concerns about this Privacy Policy or our data practices, or if you wish to exercise your rights, please contact us at:

EnigmaTCG Investment Managers Ltd
Email: support@enigmatcg.com