Privacy Policy

Nautico Wealth Ltd (“Nautico”) is an FSC licensed Investment Adviser (Restricted), License no. GB21026487. Nautico provides non-binding investment to Clients (individuals, Trusts and Companies) on securities as defined in the Securities Act, 2005.

Nautico is a registered Data Controller with the Data protection Office in Mauritius as per the Data Protection Act, 2017 bearing registration number: C12861.

Nautico determines the purposes and means of the processing of personal data and has decision making power with respect to the processing.

This Policy sets out the categories of personal information that Nautico may collect from you, before, during and following the business relationship, in accordance with the Data Protection Act, 2017 and the EU General Data Protection Regulation 679/2016, and explains how Nautico processes and protects that personal information.

If you have any questions regarding this Policy or your personal information, please see our contact details below. Nautico may amend this Policy from time to time and it is your responsibility to ensure that you are aware of any changes that may have been made. Should Nautico make any material changes to this Policy, we will notify you

Should you have any questions or require any further information, you may contact us at:

Nautico may collect the following information from you for the purposes outlined below:

• A list of products or services that you express an interest in.
• Your name, address, date of birth, place of birth, identity/passport number, marital details, gender, residency details, education, bank details, details about your employment, tax information and financial information.
• KYC documentation such as your identity/passport/proof of address/bank account documents, letters of reference, source of funds/wealth documents and employment details.
• Records of correspondence from you or anyone acting on your behalf.
• Details on transactions you carry out with us.

To the extent permissible by law, Nautico may implement systems designed to intercept and monitor your communications with Nautico. As part of this process of intercepting and monitoring these communications, we may record such communications for disclosure on the basis set out in this Policy.

“Special categories” of particularly sensitive personal information are subject to higher levels of protection. Nautico may process special categories of personal information only if necessary and in the following circumstances:

• With your explicit written consent.
• Where we need to carry out our legal obligations and in line with applicable legislation.

Nautico works with entities or organisations that provide professional advice or services to us and our clients, those that supervise and regulate us, and other suppliers of products and services to our business. We may collect personal data about you if you work for one of these organisations.

The personal data that we collect will include professional and/or personal contact details, including addresses, telephone numbers and email addresses, and records of communications that take place between you and/or others at the organisation for which you work and us, including emails, letters, minutes of meetings and recordings of telephone calls (where made) and voicemails. In addition, we also, we collect personal data that you provide us with or that is created by us during our relationship with the entity or organisation for which you work.

If you are an applicant for employment with Nautico, we will process the following personal information:

1. your name, address, and contact details, including telephone numbers and email address(es);
2. details of your qualifications, skills, experience, and employment history;
3. information about your current level of remuneration, including entitlement to benefits;
4. information provided in your CV.

If your application for employment is unsuccessful, we may retain your personal data for a period not exceeding 6 months after the date on which we inform you that your application was unsuccessful, unless you ask us to retain your details on file for a longer period. We will delete any personal information no longer required and will do so in an appropriate and secure manner.

If your application for a job with us is successful, our retention of your personal data will be governed by our separate policy on staff personal data.

Nautico may collect your information in several ways that include:

1. Information that you volunteer
   During the onboarding process, you may be required to provide certain information to enable Nautico to process your information to:

   • Provide you with the product(s)/service(s) that you have requested, managing our relationship with you, acting on your instructions and notifying you of any changes to our services.
   • Verify your identity in terms of our obligation under the FIAMLA, FIAMLA Regulations and the FSC Handbook.
   • Detect and prevent fraud to the extent that we are able to do so.
   • Comply with any laws or regulations, including law enforcement, government and tax collection agencies, treaties, and codes.
   • Assist in improving our products and/or services; and
   • Refer you to one of our Trusted Partners.
     
     

2. Intercepted communications
   Throughout the course of the relationship, Nautico may intercept and record your information as mentioned above to accurately carry out your instructions, ensure the level of service provided is of the highest standard and comply with any legislation/regulations.

3. Automatic collection
   As and when you make use of the Website, Nautico automatically receives and records information on our server logs from your browser or mobile platform, including your location, IP address, cookie information, and the page you requested. We treat this data as non-personal information, except where we are compelled to do otherwise by law or legal authority.

   Nautico only aggregate this data to better understand the traffic to the Website and how we may improve the Website.

4. Cookies
   Nautico does not make use of any cookies or track visitor behaviour to Nautico Websites nor does Nautico record or store any visitor information other than that information which the visitor volunteers by way of completing an expression of interest form.

As a data subject, you have the right to object to Nautico processing of your personal information. Should you wish to exercise this right, please contact Nautico at the details provided above.

Nautico is required to ensure that your personal information is accurate and maintained in a secure environment for a period no longer than is necessary for the purposes for which we are processing your personal information.

Generally, this means that Nautico will retain your information for a period of 7 years after the termination of our services with you. However, Nautico may be required to retain your information for longer where we are required to do so for tax, legal, regulatory, complaints or accounting purposes.

During the relationship, Nautico may disclose your information to the following third parties:

• Trusted Partners.
• Third parties that provide Nautico with services, including technical support, products, hosting services, reporting services and general services that may be related to the product/service that we provide you.
• Professional advisers, judicial, regulatory and law enforcement bodies; and
• A third party that may acquire all or part of our assets or shares, or that succeeds us in carrying on all or part of our business.

We prioritize the security and protection of your personal information. To ensure this, we employ suitable technical and organizational safeguards to prevent unauthorized access, disclosure, alteration, or destruction of your data.

You have a number of rights under data protection law which are as follows:

• Access: You have the right to access the personal data we may hold about you as well as obtain information on the purposes for which we are using it. We may ask for proof of your identity. On receipt of such a request we will endeavour to respond to you as soon as possible.
• You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.
• Rectification: You have the right to request that we amend any personal data which is incorrect or requires updating.
• Erasure: You have the right to request that we delete any personal information pertaining to you. We will assess any deletion request on a case-by-case basis and will endeavour to respond to you as soon as possible. It should be noted that Nautico is obligated by law to retain certain information. Where this information falls part of a request to erase the information, same will only be done after all legal obligations have been satisfied.
• Object: You have the absolute right to object to receiving direct marketing from us. You also have the right to raise an objection about how we are handling your personal data.

You, at all times, have the right to withdraw your consent for any specific processing that Nautico conducts on your personal information. To withdraw your consent, please contact the Data Protection Officer.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Please be aware that our website may include links to other sites that might be of interest to you. However, once you click on these links and leave our site, Nautico does not have any control over these external websites. Consequently, Nautico cannot be held accountable for the protection and privacy of any information you provide while visiting these sites, as they are not governed by our privacy policy.

Should you have an issue with Nautico processing your personal information or would like to make a complaint in relation to the personal information held and processed by Nautico you may contact the Nautico Data Protection Officer. All complaints should be resolved within fifteen (15) business days.

All processing of personal data by Nautico will be done in compliance with the Data Protection Act 2017.

This policy will be revised as needed to align with the latest best practices in data management, security, and control, and to ensure it complies with any updates or changes to the Data Protection Act 2017.