Introduction The purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Law (as Revised) of the Cayman Islands (the “DPL“). In this document, “we”, “us” and “our” refers to Union Cayman Limited and Union Protocol Foundation (together the “Company“) and its affiliates and/or delegates. Purchaser Data By virtue of making a purchase from the Company and your associated interactions with us (including any subscription (whether past, present of future), including the recording of electronic communications or phone calls where applicable) or by virtue of you otherwise providing us with personal information on individuals connected with you as a purchaser (for example directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents), you will provide us with certain personal information which constitutes personal data within the meaning of the DPL (“Purchaser Data“). We may also obtain Purchaser Data from other public sources. Purchaser Data includes, without limitation, the following information relating to you and/or any individuals connected with you as a purchaser: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your purchase activity. In our use of Purchaser Data, the Company will be characterised as a “data controller” for the purposes of the DPL. The Company’s affiliates and delegates may act as “data processors” for the purposes of the DPL. Who this Affects If you are a natural person, this will affect you directly. If you are a corporate purchaser (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with Purchaser Data on individuals connected to you for any reason in relation to your purchaser with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content. How We May Use Your Personal Data The Company, as the data controller, may collect, store and use Purchaser Data for lawful purposes, including, in particular:
- where this is necessary for the performance of our rights and obligations under the Subscription Agreement and/or the constitutional and operational documents of the Company;
- where this is necessary for compliance with a legal and regulatory obligation to which the Company is subject (such as compliance with anti-money laundering and FATCA/CRS requirements); and/or
- where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.
Should we wish to use Purchaser Data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you. Why We May Transfer Your Personal Data In certain circumstances we and/or our authorised affiliates or delegates may be legally obliged to share Purchaser Data and other information with respect to your interest in the Company with the relevant regulatory authorities such as the Cayman Islands Monetary Authority or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities. We anticipate disclosing Purchaser Data to the following parties who provide services to the Company and their respective affiliates (which may include certain entities located outside the Cayman Islands or the European Economic Area), who will process your personal data on our behalf:
- Synaps.io; and
- Stuarts Corporate Services Ltd.
The Data Protection Measures We Take Any transfer of Purchaser Data by us or our duly authorised affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL. We and our duly authorised affiliates and/or delegates shall apply appropriate technical and organisational information security measures designed to protect against unauthorised or unlawful processing of Purchaser Data, and against accidental loss or destruction of, or damage to, Purchaser Data. We shall notify you of any Purchaser Data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant Purchaser Data relates. Getting In Touch Should you have any queries or wish to discuss your data protection rights with us, please contact our compliance officer at firstname.lastname@example.org.