Administrator means the administrator to the Funds, providing services that include transfer agency and valuation services.

Client(s) means any European Person the Investment Manager holds Personal Information on.

Data Controller means the individual or the legal person who controls and is responsible for the keeping and use of Personal Information.

Data Processor means a natural or legal person, public authority, agency or any other body which processes Personal Information on behalf of the Data Controller.

European Person means any person that is resident in a European Member State.

Fund(s) means any fund under the Investment Manager’s management.

GDPR means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Investment Advisor means the entity defined in each Fund’s Explanatory Appendix

Investment Manager means South Africa Alpha Capital Management Limited

Personal Data Breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored or otherwise processed.

Personal Information means any information that identifies or can be used to identify a Client directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.



This privacy policy explains the manner in which the Investment Manager collects, utilises and maintains Personal Information about the Investment Manager’s Clients, where the “Clients” are defined as both current and potential investors of the Funds.  As a matter of policy, the Investment Manager applies these restrictions to non-public information relating to all clients.  The Investment Manager intends to comply with GDPR as far as it is applicable to them.

With respect to investors in the Funds, the Funds are considered the Data Controllers and with respect to Clients of the Investment Manager, the Investment Manager is considered the Data Controller. The Funds have, by way of a Data Protection Agreement, delegated the responsibility of Data Controller to the Investment Manager. The Administrators to the funds under management are the Data Processors.

The Investment Manager obtains Personal Information about its Clients primarily through the following sources: (a) subscription forms, investor questionnaires and other information provided by the prospective investor in writing, in person, by telephone, electronically or by any other means, which information includes name, address, nationality, tax identification number, and financial and investment qualifications; and (b) transactions with the Fund, including account balances, investments and withdrawals.

The Investment Manager does not sell or rent Client information.  The Investment Manager does not disclose non-public Personal Information about its potential Clients or shareholders to non-affiliated third parties or to affiliated entities, except in limited instances where appropriate to its business and as permitted by law.  For example, the Investment Manager may share non-public Personal Information in the following situations: (a) with service providers in connection with the administration and servicing of the Fund, which may include attorneys, accountants, auditors and other professionals, or the servicing or processing of Fund transactions; (b) with affiliated companies in order to provide shareholders with on-going advice and assistance with respect to the services provided through the Fund and to introduce them to other services that may be of value to them; (c) to respond to a subpoena or court order, judicial process or regulatory authorities; (d) to protect against fraud, potential Client or authorised transactions (such as money laundering), claims or other liabilities; and (e) upon consent of a potential investor or a shareholder to release such information, including authorisation to disclose such information to persons acting in a fiduciary or representative capacity on behalf of such party.

The policy of the Investment Manager is to require that all employees, financial professionals and companies providing services on its behalf to keep Client information confidential.  The Investment Manager maintains safeguards to protect Client information.  The Investment Manager restricts access to the personal and account information on Clients to those employees who need to know that information in the course of their job responsibilities.  Third parties with whom the Investment Manager shares Client Personal Information must agree to follow appropriate standards of security and confidentiality.  The privacy policy of the Investment Manager applies to both current and former Clients.  The Investment Manager may disclose non-public Personal Information about a former Client to the same extent as for a current Client.

Each Fund investor will be required to acknowledge and consent that the Fund, the Investment Manager, the Investment Advisor and/or any Administrator may disclose to each other, to any regulatory body, to a delegate, agent or any other service provider to the Fund, the Investment Manager, the Investment Advisor and/or any Administrator, in any jurisdiction, copies of the potential Client’s or shareholder’s subscription documents and any information concerning the potential Client or shareholder, including any Personal Information, provided by the potential Clients or shareholder to the Fund, the Investment Manager, the Investment Advisor and/or any Administrator.  Any such disclosure shall not be treated as a breach of any restriction upon the disclosure of information imposed on such person by law or otherwise.

The Fund, the Investment Manager, the Investment Advisor and/or any Administrator, or any agent of the foregoing, may communicate with Clients (i.e. financial statements, performance reports, manager letters) by using a variety of means including, but not limited to, by telephone, e-mail, password protected Internet website, regular mail and facsimile.  A Client may, at any time, notify the Investment Manager that it does not wish to receive electronic communication and that it wishes to receive paper communication instead.

The Investment Manager may make changes to its privacy policy in the future.  The Investment Manager will not make any change affecting an individual Client without first delivering to such client a revised privacy policy describing the change.

The Investment Manager has in place the following measures to ensure GDPR compliance:

  • Appointments – the Investment Manager has appointed Sally Cousins as Data Protection Officer (“DPO”). The DPO will report to the board of directors of the funds under management on a quarterly basis or as required, with regard to data protection matters.
  • Breaches – should a data breach occur that is likely to result in a risk for the rights and freedoms of individuals, the Investment Manager will notify the Client within 72 hours of first becoming aware of the breach.
  • Right to access – the Clients have the right to obtain from the Investment Manager confirmation as to whether or not personal data concerning them is being processed, where and for what purpose. The Investment Manager will provide a copy of the personal data, free of charge, in electronic format.
  • Right to be forgotten – once the data of a Client is no longer relevant, the client has the right to request the data be erased.
  • Privacy – the Investment Manager has implemented appropriate measures to ensure the Client’s data is protected. Only the absolutely necessary information will be processed by the Investment Manager.