Last Updated: September 2021

Apex Group Ltd. is comprised of various entities across multiple jurisdictions (collectively, the “Apex Group” or “Apex”). This Privacy Policy applies to the use of Apex Group website’s (as listed in the website section below) and to the Apex Group’s use of data / information gathered. If you would like to request an organisational chart for the Apex Group please contact enquiries@apex.bm

APEX PRIVACY PLEDGE

The Apex Group’s fundamental goal is to provide asset managers around the world with comprehensive fund administration and middle office solutions. Our products and services deliver cross-jurisdictional reporting capabilities, fund administration services, middle office solutions and more to enable your fund to focus on what matters, performance. As we build on the Apex suite of services, we are committed to the principles of respecting your privacy, keeping your data safe and keeping the decision as to how your information is used and shared in your hands.

Our privacy pledge:

  • Apex will only collect data that is of legitimate interest and which is useful and necessary for improving its products, services and your experience.
  • Apex will maintain fairness and transparency at all times with regards to how we collect and process data at all times.
  • Apex will never sell your data and will only share your personal data when given your explicit consent to do so for a specific reason.
  • Apex will never make decisions based solely on automated processing or profiling of data.
  • Apex will always take the security of your data seriously.


To learn more about the data collected by Apex, please read our full Privacy Policy below.

DATA COLLECTION AND PROCESSING

Subject to the relevant local laws, Apex may process certain information about you if this information is of Legitimate Interest. This data may include what is known as Personal Data under GDPR and/or Personally Identifiable Information (PII).

Apex processes your personal information in line with its Privacy Policy and T&C’s to provide you with the information that is of most interest to you, and deliver the services you have requested.

AUTOMATED PROFILING

Apex does not carry out automated profiling and will not make any decisions based on the automated processing of data.

SENSITIVE DATA

Apex does not seek to collect special categories of personal data (“sensitive data”), including but not limited to data revealing racial, or ethnic origin, political opinions, gender, religious or philosophical beliefs, health, genetic and biometric data, or trade union memberships, through this site. Please note that, by freely providing Apex with an unsolicited sensitive data, subject to the relevant laws, you are consenting Apex to use the said data in conformity with this Privacy Policy.

Apex understands the importance of protecting children’s privacy. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.

EMAIL MARKETING

If you are subscribed to one of Apex’s marketing lists we may occasionally send you relevant updates. When you receive marketing emails Apex, we may use web beacons, customised links, or similar technologies to determine whether the e-mail has been opened and on which links you click, to provide you more focused e-mail communications or other information in the future.

Apex uses Salesforce Pardot for email marketing; you can opt out at any point. See Salesforce Pardot Privacy Policy here.

UNSUBSCRIPTION

You can stop the delivery of marketing emails from Apex at any time by Unsubscribing/Opting Out. We include a link at the bottom of every marketing email which you can utilise to update your preferences by selecting and deselecting lists based on your personal interests, or you can unsubscribe from ALL marketing communications if you so wish. Alternatively you can make a direct request to unsubscribe by emailing the following address: enquiries@apex.bm

Please note, that by unsubscribing from ALL marketing emails Apex will proceed to remove your contact details from all mailing lists and place you on a “no mail” list. Alternatively you can update your subscription preferences to unsubscribe from certain mailing lists and remain on others that you feel are more relevant. If you wish to amend or update your subscription preferences at any time please use the link at the bottom of any Apex marketing email or contact enquiries@apex.bm

CROSS BORDER TRANSFERS AND THIRD PARTIES

Apex may share your personal data with:

  • Apex Group, which includes any Apex subsidiaries and affiliates part of the Apex network of companies;
  • Apex services providers (third parties) who process information on Apex behalf, including providers of information technology, identity management, website hosting and management, data analysis, data back-up, security and storage services; or,
  • Other third parties where you have given your consent to the disclosure (either to Apex or the third party).

Apex Group operates in compliance with the relevant data protection laws and regulations. Apex services providers are legally obliged to follow Apex express instructions in respect of the use of your personal information and they must comply with appropriate security measures to protect your personal information.

In case Apex transfers your personal information to countries that may not have the same level of data protection provided in your home country,

We have internal policies and procedures in place in an effort to achieve an equivalent level of protection across our organization. The transfer of personal information to other countries is based on a business need or to comply with applicable laws.

Personal information stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction. By providing your information to Apex in the course of your access and use of the Site or the Services, you agree that your personal information, for the purposes explained in this Privacy Notice, may be transferred to and stored in other countries where Apex does business, which may not have the same data protection laws as the country in which you reside.

INFORMATION SECURITY

Apex is committed to protecting the security of your personal information. Apex has implemented generally accepted standards of technology and operational security in order to protect personal data and information from loss, misuse, alteration or destruction. Apex ensures that all appropriate confidentiality obligations and technical and organisational security measure are in place to prevent any unauthorised or unlawful disclosure or processing of such information and data and the accidental loss or destruction of or damage to such information and data.

Only authorised Apex employees and services providers are allowed to access the data and they are legally obliged to ensure confidentiality of this information.

DATA RETENTION

The data you submit to Apex will only be retained for as long as is required for the purposes for which it was collected or as required by the relevant laws. When the data is no longer necessary to the purpose for which it was collected; Apex will proceed to erase all your personal data held in its systems without undue delay.

RIGHT OF ACCESS AND CORRECTION

Subject to the relevant laws, you have the right to know what personal information we hold about you. If you would like a copy of the information you are entitled to, you may contact Apex by email to enquiries@apex.bm. Please note that for the execution of this request, you must provide with a clear identification of yourself and the information you require.

Also, you have the right to request rectification of inaccurate personal data concerning to you. If you would like to exercise this right, you may provide Apex with a supplementary statement by email to enquiries@apex.bm . Please note Apex does not assume responsibility for verifying the ongoing accuracy of the personal information provided.

RIGHT TO BE FORGOTTEN

If at any point you wish to withdraw your consent for Apex holding your data you can contact us and request this via the following email address: enquiries@apex.bm

Please note, if you wish to exercise your “right to be forgotten” we recommend that you authorise Apex to retain your information on its “no mail” list. If you are totally removed from the system you could be legitimately and legally added back into the system at some point in the future and therefore could receive future communications from Apex. If your data is kept on the “no mail” list you will never receive marketing communications from Apex again, unless you change your preferences and explicitly request it.

LEGAL DISCLOSURE

Apex may disclose your personal information to law enforcement, regulatory, or other government agencies or to other third parties are required by, and in accordance with, applicable laws or regulations.

PRIVACY NOTICE FOR CORPORATE AND PRIVATE CLIENTS

Hungary

Ireland 

Jersey

London

Trusts and Escrow

Netherlands

Luxembourg

Throgmorton

AMENDMENTS

Apex may update the terms of this Privacy Policy, as our services and privacy practices change, or as required by applicable legal or regulatory requirements. We may also notify you in other ways for time to time about the processing of your personal information. We encourage you to periodically review this Privacy Statement to be informed about how we are protecting your information.

CONTACT

If you have any questions about this Privacy Policy, you may contact us via enquiries@apex.bm or via regular mail to:

Apex Fund Services Ltd. | Vallis Building, 4th Floor | 58 Par-la-Ville Road | Hamilton, HM11 | Bermuda

Ipes was acquired by the Apex Group, the deal reached final close in January 2019 and the Ipes brand no longer exists. Please Click Here to read the legacy Ipes Policy.

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