Privacy
Privacy Policy
This policy sets out how personal data submitted through this website — including the enquiry form and the investor portal — is collected, used, shared, secured and retained.
Controller
Who is responsible for your data
ARGUS Private Partners SICAV p.l.c. (the "Company", "we", "us") is the controller of personal data processed through this website. Our registered office is Office 1, Piazzetta Business Plaza, Triq Ghar il-Lembi, Sliema SLM 1560, Malta. Processing is carried out in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) and the Maltese Data Protection Act (Chapter 586).
This policy applies to this website, the enquiry form and the investor portal. It does not apply to third-party websites we may link to, or to processing carried out by the Company's service providers under their own privacy notices.
Enquiry form
Data collected through the enquiry form
When you submit an enquiry we collect the name, email address, organisation, country and message content you provide, together with the date and time of submission and the technical metadata accompanying the request.
We use this data solely to respond to your enquiry, to assess whether documentation may lawfully be made available to you as a Qualifying and/or Professional Investor, and to keep a record of the correspondence. Enquiry submissions are delivered by email to the Company's investor relations mailbox through our email infrastructure provider and are stored in the Company's backend systems.
Submitting an enquiry does not create an investment relationship, and we do not use enquiry data for marketing or profiling. We do not sell personal data.
Investor portal
Data collected through the investor portal
Account data. When you register we collect your email address and authentication credentials. Passwords are handled and stored in hashed form by our authentication provider; we never see them in plain text.
Onboarding data. To process a subscription we collect identification, contact, residence, tax status, investor classification, suitability and source-of-wealth information, together with the supporting documents you upload (for example identification documents and proof of address) for anti-money laundering and know-your-customer purposes.
Account records. We process holding, subscription, redemption, statement and net asset value records associated with your account so that they can be displayed to you in the portal and reconciled with the Administrator's records.
Uploaded documents are held in private storage, are accessible only to your own account and to authorised Company personnel, and are served only through short-lived signed links.
Technical data
Cookies, local storage and logs
We do not use advertising, analytics or cross-site tracking cookies. Our hosting and security infrastructure processes IP addresses and standard server log data for availability, abuse prevention and security monitoring.
The website stores a small number of strictly necessary items on your device: your acknowledgement of the compliance notice, your website access confirmation, your language and theme selection, and — if you sign in — your authentication session token. Clearing your browser storage removes these and signs you out.
Lawful bases
Why we are permitted to process it
We rely on consent for website enquiries and any optional communications; on the performance of a contract, or steps taken at your request before entering into one, for investor registration, onboarding and portal access; on compliance with legal obligations for AML/KYC, sanctions screening, tax reporting, record keeping and the regulatory requirements applicable to a Notified Professional Investor Fund; and on our legitimate interests in securing and administering the website and investor portal.
Where processing is based on consent, you may withdraw it at any time; this does not affect processing already carried out. Where data is required by law or to process a subscription, failure to provide it may mean we cannot accept your application.
Recipients
Who we share data with
Personal data may be disclosed, where relevant to their function, to the service providers appointed to the Company and its sub-fund — including the Administrator, Registrar and Transfer Agent, the Investment Manager, the legal adviser and due diligence service provider, the auditors, and the brokerage and custody counterparties — and to our technology, hosting, database and email infrastructure providers acting as processors on our documented instructions.
Data may also be disclosed to competent authorities, including the Malta Financial Services Authority and the Financial Intelligence Analysis Unit, where required by law. Where personal data is transferred outside the European Economic Area, we rely on an adequacy decision or on standard contractual clauses together with appropriate supplementary measures.
Security
How we protect your data
Access to investor data is restricted by row-level access controls so that each account can reach only its own records, with administrative access limited to authorised personnel. Data is encrypted in transit, documents are stored in non-public storage, and access to backend systems requires authentication. No system can be guaranteed entirely secure; please contact us immediately if you believe your account has been compromised.
Retention
How long we keep it
Enquiry records are retained for up to 24 months unless a relationship progresses. Investor onboarding, AML/KYC and transaction records are retained for the period required by Maltese law, generally at least ten years from the end of the business relationship or the transaction. Portal account data is retained while the account remains active and thereafter for the applicable statutory period, after which it is deleted or anonymised.
Your rights
Rights, automated decisions and contact
You have the right to access, rectify, erase or restrict processing of your personal data, to object to processing based on legitimate interests, to data portability, and to withdraw consent at any time. Statutory retention and AML obligations may prevent erasure of certain records.
We do not carry out automated decision-making producing legal effects, or profiling, in relation to your data. The website and portal are not intended for children.
Requests may be made in writing to the registered office above, or by email to the investor relations address published on the Investors page. You may also lodge a complaint with the Office of the Information and Data Protection Commissioner in Malta.
We may update this policy from time to time. The version published on this page is the version in force.