Privacy Policy

1. Who we are and what we do

VCG Asset Management Ltd is an asset management company with a specialized concentration on the meticulous management of assets, catering to the distinct needs of high-net-worth individuals and institutional clients alike. Please see "Who is the data controller of your personal data" below for more information on the entities that control and process personal data within VCG Asset Management Ltd.

2. What personal data we collect about you

We may collect and process different types of personal data while operating our business and providing our services. These include:

• Basic personal details such as your name and job title.
• Contact data such as your telephone number and postal or email address.
• Financial data such as payment-related information or bank account details.
• Demographic data such as your address, preferences, or interests.
• Website usage and other technical data such as details of your visits to our websites or information collected through cookies and other tracking technologies.
• Personal data provided to us by or on behalf of investors or generated by us in the course of providing our services, which may, where relevant, include special categories of personal data.
• Identification and other background verification data such as a copy of passports or utility bills or evidence of beneficial ownership or the source of funds to comply with client due diligence/” know your client”/anti-money laundering laws and collected as part of our client acceptance and ongoing monitoring procedures.
• Recruitment-related data such as your curriculum vitae, your education and employment history, details of professional memberships, and other information relevant to potential recruitment to VCG Asset Management Ltd.
• Data that you may provide to us in the course of registering for and attending events or meetings.
• Any other personal data relating to you that you may provide.

3. How we obtain the personal data about you

We may collect or receive your personal data in several ways:

• Where you provide it to us directly, for example by corresponding with us by email, or via other direct interactions with us such as completing a form manually or on our website or registering for and using one of our online tools.
• Where we monitor use of, or interactions with, our websites, any marketing we may send to you, or other email communications sent from or received by VCG Asset Management Ltd.
• Third party sources, for example, where we collect information about you to assist with “know your client” checks as part of our client acceptance procedures or where we receive information about you from recruitment agencies for recruitment purposes.
• Publicly available sources - we may, for example, use such sources to help us keep the contact details we already hold for you accurate and up to date or for professional networking purposes, e.g., LinkedIn.

4. How we use your personal data

We will only use your personal data where we are permitted to do so by applicable law. Under the Kenyan Data Protection Act 2019, the use of personal data must be justified under one of several legal grounds. The principal legal grounds that justify our use of your personal data are:

• Contract performance: where your information is necessary to enter or perform our contract with you.
• Legal obligation: where we need to use your information to comply with our legal obligations.
• Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
• Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
• Consent: where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility).

5. Who we share your personal data with

We may share your personal data with a variety of the following categories of third parties:

• Our professional advisors (e.g., transactions, legal, financial, tax, risk management or other advisors), bankers, and auditors.
• Our insurers and insurance brokers.
• Other third-party external advisors or experts engaged in the course of the services we provide to our clients and with their prior consent, such as technology service providers.

6.Which countries we transfer your personal data to

Regardless of the location of our processing, we will impose the same data protection safeguards that we deploy within our jurisdiction and implement appropriate measures to ensure that your personal data is protected in accordance with applicable data protection laws.

VCG Asset Management Ltd has a data sharing agreement in place signed by all its related entities with standard contractual clauses. Similarly, where a third-party service provider processes the personal data of Kenyan residents on our behalf, we will ensure that appropriate measures are in place to ensure an adequate level of protection for your personal data, usually by including standard contractual clauses in our agreements with such third-party service providers (alongside other supplementary technical or contractual measures where necessary).

Please contact us as directed below if you would like to see a copy of the specific safeguards applied to the export of your personal data.

7. How long we keep your personal data

We will retain your personal data for as long as is necessary to fulfil the purpose for which this data was collected and any other permitted linked purpose.

If your personal data is used for two purposes, we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires. Our retention periods are also based on our business needs and good practice for at least 7 years.

8. How we protect your personal data

We recognize that information security is an integral element of data privacy. While no data transmission (including over the Internet or any website) can be guaranteed to be secure from intrusion, we implement a range of commercially reasonable physical, technical, and procedural measures to help protect personal data from unauthorized access, use, disclosure, alteration, or destruction in accordance with data protection law requirements.

Information that you provide to us is stored on our or our service providers’ secure servers and accessed and used subject to our security policies and standards, or those agreed with our service providers.

Everyone at VCG Asset Management Ltd and any third-party service providers we may engage that process personal data on our behalf (for the purposes listed above) are also contractually obligated to respect the confidentiality of personal data.

Alongside our role, please also note that where we have given you (or where you have chosen) a password which enables you to access certain parts of our online services, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

9. What rights you have in relation to your personal data

If you have any questions about our use of your personal data, you should first contact us via the details provided in section 11 below.

Under certain circumstances and in accordance with Kenya Data Protection Act, 2019, or other applicable data protection laws, you may have the right to require us to:

• provide you with further details on the use we make of your information.
• provide you with a copy of information that we hold about you.
• update any inaccuracies in the personal data we hold.
• delete any personal data that we no longer have a lawful ground to use.
• where processing is based on consent, to withdraw your consent so that we stop that processing.
• object to any processing based on the legitimate interests’ ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights.
• restrict how we use your information whilst a complaint is being investigated.

10. What rights you have in relation to your personal data

When you visit our websites, we may send a cookie to your computer. This is a small data file stored by your computer to help improve functionality or tailor information to provide visitors with more relevant pages. For details of the cookies employed by us, please see our Cookie Policy, which forms part of this Privacy notice. We may also analyze website traffic to identify what visitors find most interesting so we can tailor our websites accordingly.

11. What rights you have in relation to your personal data

If you have any questions about this Privacy notice or how we process your personal data, please contact us by sending an email to: info@vcgassetmanagement.com or by writing to:

Data Protection Officer
VCG Asset Management Limited
12^th Floor, Delta Corner Towers, Oracle Tower, Westlands, Nairobi Kenya.
14747 – 00800 Nairobi

12. What rights you have in relation to your personal data

We may change the content of our websites and how we use cookies without notice and consequently our Privacy notice and Cookie Policy may change from time to time in the future. We, therefore, encourage you to review them when you visit the website to stay informed of how we are using personal data.