1. Introduction

Welcome to CCFunds™ SICAV plc privacy notice (the “Notice”).

CCFunds™ SICAV plc (SV186) of Ewropa Business Centre, Triq Dun Karm, Birkirkara, Malta (“we”; “us”; “our” “the Company”) respects your privacy and is committed to protecting your personal information or, as otherwise termed, your “personal data”. The purpose of this Notice is to set out the basis on which we will process your data, mainly:

• When you visit our website https://www.ccfunds.com.mt (hereinafter the “Website” and or the “Site”);
• When you provide us with any application forms, change of detail forms, stock transfer forms and other internal forms;
• Through calls, meetings, emails and other forms of communication;

It is important that you read this Notice together with any other policy which we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Notice supplements the other notices and is not intended to override them.

We are committed to protecting our client’s privacy and we will not collect any personal information about you unless you provide it voluntarily or unless we have a legitimate interest to do so. This policy describes and explains how information is collected and retained by the Company. This information helps us improve our service to existing and potential customers.

Any personal information you communicate to us is kept within our own records in accordance with this Privacy Policy, the Terms and Conditions and as required by the GDPR (as defined below)

2. Important information and who we are information collected

i. Purpose of this Privacy Policy

We process your personal data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 440 of the Laws of Malta) (the “Act”), as may be amended or replaced from time to time, and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR” or the “Regulation”).

In that respect, “personal data” means data relating to a living individual who can be identified from the information (data) we hold and/or possess. This includes, but is not limited to, your name and surname (including maiden surname where applicable), address, date of birth, nationality, gender, civil status, tax status, spouse’s name, identity card number & passport number, contact details (including mobile and home phone number and personal email address), bank account details as well as online identifiers. The term ‘personal information’, where and when used in this Notice, shall be taken to have the same meaning as personal data.

This Notice aims to give information on how the Company collects and processes your personal data in the scenarios outlined above namely, through the processes outlined above, including any data that you may provide to us, or which we may receive about you. It is imperative that the personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to provide you with our Services which you have requested (amongst other potential and salient issues). Please keep us informed if your personal data changes during your relationship with us.

It is important that you read this Notice together with any other privacy notice or policy which we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Notice supplements the other notices and is not intended to override them.

The Company does not sell your Personal Information, although this information may be shared between the Calamatta Cuschieri Group companies (composed of Calamatta Cuschieri plc (C 70064) and/or any of its subsidiaries) and other third parties, including service providers including service providers in the rendering of our services to you. These third parties have been carefully scrutinized to assess that they use appropriate security measures to protect the confidentiality and security of Personal Information.

This version of the Privacy Policy was last updated on the 24/05/2018.

ii. Controller

CCIS (as defined above) is the controller and responsible for your personal data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Notice and our processing activities in general. If you have any questions or requests, including any requests to exercise your legal rights as a data subject, please contact the DPO using the details set out below.

Contact details

Full name of legal entity:
CCFunds™ SICAV plc (SV186)
Email address:
[email protected]

Postal address:
Level 0, Ewropa Business Centre, Triq Dun Karm, Birkirkara, BKR9034
Telephone number:
+356 25 688 688

You have the right to lodge a complaint at any time with a competent supervisory authority on data protection matters (for example, with the supervisory authority in your place of habitual residence). In the case of Malta, this would be the Office of the Information and Data Protection Commissioner (https://idpc.org.mt/en/Pages/Home.aspx). We would, however, appreciate the opportunity to deal with your concerns before you approach that supervisory authority, so please contact us in the first instance.

iii. Third-party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices, statements or policies.

We encourage you to read the privacy notice of every website you visit.

3. Personal Data

Personal data, or personal information, means any information about an individual from which that person can be identified (as stated above). It does not include data where the identity has been removed (anonymous data).

In the course of our relationship (including during account registration and opening stage), we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

- Identity Data: includes your first name, maiden name (where applicable), last name, address, company name, username or similar identifier, marital status, title, nationality, date of birth, gender, identity document type and identity document number, tax domicile, employment status, employer and occupation.

- Contact Information: includes your billing address, email address and contact number (telephone and/or mobile).

- Account and portfolio data: refers to your portfolio and account information.

- Transaction Data: includes details about:

1. your orders, such as the nature of the order (e.g. whether it is an order to buy or an order to sell), the order volume, price, value and, where applicable, the proceeds derived; and

2. your trading and transactional history.

- Payment Data: includes details about the payments that you receive through us (e.g. withdrawals) or which we receive, or otherwise, charge you.

- AML and Risk Data: for example, copies of I.D. card or passport, proof of residence, source of wealth, criminal records check, ‘suitability’ and ‘appropriateness’.

- Technical Data: includes IP address, device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other technology on the devices you use to access the Site as the case may be.

- Usage Data: includes information about how you use the Site

- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the Site. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We collect special categories of personal data about you, primarily as a result of the documentation and information that we collect and process in terms of AML and risk data. In essence, “special categories of personal data” or, as otherwise termed, “sensitive personal data”, refers to and includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings.

The collection and processing of this sensitive personal data about you is necessary for us to be able to, amongst other things to conduct our internal AML and KYC checks and due diligence on you.

Where we need to collect personal data about you:

- by law; or

- under the terms of, or in connection with, the contract that we have with you (as outlined above); or

- as part of our legitimate business interests to verify the identity of our applicants and/or clients, mitigate against risks (such as potential or suspected fraud) and in particular, to assess your on boarding with us (as subject to our internal client acceptance criteria and policies).

and you either fail to provide that data when requested, or else provide insufficient or unsatisfactory data, we may not be able to perform or conclude the contract that we have with you or which we are otherwise trying to enter into with you (namely, regarding account openings with us).

4. How your Personal Data is collected

The Company collects personal information, mainly, in the following ways:

- When you register to open an account with us;

- When you submit AML and risk data;

- During the performance of services to our clients;

- Through the orders raised with us; and

- Through the collection, generation and compiling of your financial, payment instructions portfolio and transaction data.

We may also collect or may collect personal information in our direct communication with you:

- If you contact us with a query;

- When you report any issues;

- Provide us with feedback; and

- Submit an additional AML and risk data documentation.

Additionally, as you interact with us through the Site, we may keep technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Your data may also be collected from publicly available sources such as company registration databases, court databases or general online searches.

5. How we use your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you in respect of your customer relationship with us.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to your receipt of marketing material. You have the right to withdraw consent to such marketing at any time by contacting us on the contact information included below.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us on [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.