PRIVACY POLICY
PRIVACY POLICY
Last updated: March 2025
This Website, activumsg.geniumcreative.com (including any other media form, media channel, mobile website, or mobile application related or connected thereto) (the “Website”), is operated by Activum SG Capital Management Limited. We take your privacy seriously and urge you to read this Website Privacy Policy (“Privacy Policy”) carefully as it contains important information about:
- Who we are,
- How and why we collect, store, share and otherwise use your Personal Data, defined as “any information which is related to an identified or identifiable natural person.”
- The rights you have in respect of your Personal Data, and
- How to contact us and supervisory authorities in the event you have a complaint.
Who we are
Activum SG Capital Management Limited (“Activum”, “we”, “our” or “us”) collect, use and are responsible for certain Personal Data about you that we collect, or you provide us with, through your use of this Website. We do so in accordance with our obligations as a “controller” of that Personal Data under applicable data protection laws in Jersey, the United Kingdom and the European Union.
What Personal Data we collect
When you visit our Website, we may collect and use your Personal Data. The Personal Data we process includes:
- Identity data: name, email address and phone number;
- Marketing preferences: if you choose to receive our marketing communication, we will ask for, and store, your preferences; and
- Online identifying data: we use tracking technologies to collect certain online identifiers (e.g. IP addresses, log-in information) about you. Please see “Cookies and similar technologies” below for more information.
How we use your Personal Data
We collect the Personal Data described above for the following reasons:
- to provide you with our Website services;
- to respond to any queries, questions or comments you may send to, or ask of, us via the Website, or by email, telephone or in writing;
- to gain a better understanding of how our Website is being used. This understanding informs any improvements we undertake and ensures that the Website and its contents continue to best serve the needs of our visitors.
We rely on the following lawful grounds to process your Personal Data:
- your consent, for example when we want to send you marketing communications;
- the performance of a contract we are party to with you or when taking steps to enter into a contract with you, for example when you contact us about our services; and
- our legitimate interests or those of a third party, namely when we process your Personal Data to improve our Website, to secure our Website and the information provided via our Website, and, in certain circumstances, to provide you with marketing communications.
Cookies and Similar Technologies
As stated above, we may collect Personal Data of you in the form of online identifiers. We do this through the use of cookies and other similar technologies. A cookie is a small text file which is placed onto your computer or electronic device when you access our Website. Similar technologies include web beacons, action tags, local shared objects (“flash cookies”) and single-pixel gifs. Such technologies can be used to track users’ actions and activities and to store information about them. We use these cookies and/or similar technologies on this Website.
For more information on the cookies and other tracking technologies we use, please refer to our Cookies Policy.
Who your Personal Data may be shared with
We may share your Personal Data for the following reasons:
- we may share your Personal Data with law enforcement agencies, officials, regulatory agencies or other bodies which we are legally required to share the information within connection with any investigation to help prevent unlawful activity;
- we may share your Personal Data with certain service providers or group companies to analyse the Website and our services so we can improve and provide the best Website and services to you and others; and/or
- we may share your Personal Data if we undergo a merger, acquisition or other form or reorganisation and pursuant to such, a third party will become the controller of your Personal Data.
We will not generally share your Personal Data with any other third parties.
How long will your Personal Data be kept
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. To determine the appropriate retention period for information, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Keeping your Personal Data safe
We have appropriate security measures in place to prevent Personal Data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your Personal Data to those who have a genuine need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We will also use appropriate technological and organisation measures to keep your Personal Data secure. We implement and maintain physical, electronic, and procedural safeguards and security measures that are reasonably designed to protect your Personal Data from unauthorized access, modification, or disclosure.
We also have procedures in place to deal with any suspected incident. We will notify you and any applicable regulator of a suspected data breach and/or security breach where we are legally required to do so.
While we will use all reasonable efforts to secure your Personal Data, in using the Website you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Personal Data that is transferred from you or to you via the internet. If you have any particular concerns about your Personal Data please contact us using the details below.
Transfers of your Personal Data
We generally do not transfer your Personal Data outside of the European Economic Area, the United Kingdom or Jersey. However, any data transfers we initiate will comply with applicable data protection laws.
Your rights and your Personal Data
Subject to any applicable exemptions under applicable data protection laws, you have the following rights with respect to your Personal Data:
- The right to request a copy of your Personal Data which we hold about you;
- The right to request that we correct any Personal Data if it is found to be inaccurate or out of date;
- The right to request your Personal Data is erased where it is no longer necessary for us to retain such Personal Data;
- If we rely on your consent to process your Personal Data, the right to withdraw your consent to the processing at any time;
- The right to request that we provide you with your Personal Data and where possible, to transmit that Personal Data directly to another data controller, (known as the right to data portability);
- The right, where there is a dispute in relation to the accuracy or processing of your Personal Data, to request a restriction is placed on further processing;
- The right to object to the processing of Personal Data;
- The right to lodge a complaint with a relevant supervisory authority. In Jersey, this is the Jersey Data Protection Authority. In the UK, the relevant authority is the Information Commissioner’s Office or ICO and in the European Union it will be your national data protection authority.
If you would like to exercise any of these rights please:
- Email or write to us using the contact details provided;
- Provide us with proof of your identity (a copy of your driving licence or passport). We retain the right to request additional information in this regard if we are unable to confirm your identity; and
- Let us know the information to which your request relates.
From time to time we may also have other methods to unsubscribe (opt-out) from any direct marketing including for example, unsubscribe buttons or web links. If such are offered, please note that there may be a period after selecting to unsubscribe in which marketing may still be received while your request is being processed.
Third party websites
Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Data about you. We do not control these third-party websites, plug-ins and/or applications and are not responsible for their privacy statements, and we encourage you to read the privacy policy of any such third-party website or application you visit or use.
Changes to the Privacy Policy
This privacy policy was last updated on the date stated above.
We may change this Privacy Policy from time to time. You are encouraged to periodically review this privacy policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised privacy policy by your continued use of the Website after the date such revised privacy policy is posted.
Contact us
If you have any questions about this policy, or wish to exercise any of your rights, please write or email us using the contact information on the Website. You may also contact the Jersey Data Protection Authority (via (https://jerseyoic.org/) or, if you live in the United Kingdom or the European Union, the supervisory authority where you live to raise any privacy concerns or exercise your rights.
PRIVACY POLICY AND NOTICE OF COLLECTION FOR CALIFORNIA CONSUMERS
The California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time “CCPA”) imposes certain obligations on Activum SG (collectively, “Activum”, “we”, “our” or “us”) as a “business” and grants certain rights to California Residents (“California Resident,” “you” or “your”) with regard to “Personal Data.” This privacy policy for California Consumers (“California Privacy Policy”) contains disclosures required by the CCPA, including our Notice at Collection, information surrounding how and why we collect, use, and disclose Personal Data and your potential rights under the CCPA. This California Privacy Policy is only relevant to residents of California and applies only to the collection or other use of Personal Data that is subject to the CCPA. Personal Data is defined Terms used herein have the meaning ascribed to them in the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Notice of Collection and Use of Personal Data
Information We Collect. Depending on how you interact with us we may collect the following categories of Personal Data from or about you, including:
| Category of Personal Data | Types of Personal Data Collected | Sources of Personal Data |
| Identifiers | Names, Email addresses, Phone numbers | You |
| Online Information | IP addresses, Log-in information | Cookies, Trackers |
Purpose for Collecting and Using Personal Data. Depending on how you interact with us, we may use and collect the Personal Data we collect for one or more of the following purposes, including:
- to provide you with services on our Website;
- to respond to any queries, questions or comments you may send to, or ask of, us via the Website, or by email, telephone or in writing;
- to gain a better understanding of how our Website is being used. This understanding informs any improvements we undertake and ensures that the Website and its contents continue to best serve the needs of our visitors.
How Long We Retain Information. Activum and those third parties to whom Ppersonal Ddata is transferred will retain Personal Data as long as is necessary for the purposes set out above.
Sale or Sharing of Personal Data. We do not sell or share your Personal Data (as such terms are defined under the CCPA).
For more information about our privacy practices, please review our Notice of Collection, which is available at the top of this page.
Our Collection, Use, and Disclosure, of Personal Data and Sensitive Personal Data
Information We Have Collected. In the preceding 12 months, and depending on how you interact with us, we may have collected the categories of Personal Data listed above in “Information We Collect.”
Sources of Personal Data. We may collect Personal Data from certain categories of sources as listed above in “Information We Collect.”
Purposes for Collecting and Using Personal Data. We may collect your Personal Data for the business or commercial purposes described above in “Use of Collected Personal Data.”
Our Disclosure of Personal Data. We do not sell our Personal Data (as that term is defined under the CCPA). We do not knowingly sell or share the Personal Data of California Residents under 16 years old. In the preceding 12 months, we may have disclosed for a business purpose the following categories of Personal Data to the following categories of third parties, as described in the following chart
| Category of Personal Data Sold or Shared | Categories of Third Parties to Which Personal Data is Shared | Business or Commercial Purposes |
| Identifiers
Online Information |
|
|
In addition, we may disclose and in the preceding 12 months, may have disclosed all of the categories of Personal Data identified above in the section, “Information We Collect,” to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose Personal Data to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in “Purposes for Collecting and Using Personal Data.”
Use and Disclosure of Sensitive Personal Data. As noted above in “Personal Data We Collect”, under the CCPA, certain Personal Data we collect, and process may be considered “sensitive Personal Data.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive Personal Data in certain circumstances. Currently, we are not using your sensitive Personal Data for purposes that would require that we provide you with a right to limit.
Rights of California Consumers. The CCPA provides California consumers the following rights, subject to certain exceptions and limitations:
- Be Informed. To be informed, at or before the point of collection, of the categories of Personal Data to be collected and the purposes for which the categories of Personal Data shall be used.
- Request to Know. The right to request (a) the categories and specific pieces of Personal Data we collect, use, disclose, and sell about you, (b) the categories of sources from which we collected your Personal Data, (c) our purposes for collecting or selling your Personal Data, (d) the categories of your Personal Data (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we disclosed or sold Personal Data;
- Request to Delete. Request that we delete the Personal Data we have collected from you or maintain about you (subject to certain exceptions);
- Request to Correct. Request that we correct inaccurate Personal Data;
- Opt-Out of Sale. Request that we do not “sell” (as that term is defined in the CCPA) your Personal Data; (we do not);
- Opt-Out of Sharing. Request to opt-out of the “sharing” (as that term is defined in the CCPA) of your Personal Data if a business shares your Personal Data with third parties (we do not);
- Limit Use and Disclosure of Sensitive Personal Data. Request that limits the use and disclosure of sensitive Personal Data where required by the CCPA (please note that we are not using your sensitive Personal Data for purposes that would require that we provide you with such right to request to limit); and
- Not to Be Discriminated Against. Not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like Personal Data collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain Personal Data after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.
Shine the Light. For certain categories of Personal Data, the right to request a list of what Personal Data (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties.
How to Submit a Request. You may submit Request to Know, Request to Correct or a Request to Delete (“Consumer Rights Request”), as described above or other applicable California law to us:
- via phone: +44 (0) 1534 825200
- email dataprotection@rjh.je
Verifying Requests. We are only required to respond to verifiable Consumer Rights Requests made by you or your legally authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request, which may include, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
Authorized Agents. You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
Changes to this California Policy. We may update this California Privacy Policy from time to time and to reflect changes in our Personal Data practices. We encourage you to review the most current California Privacy Policy provided to you.
Contact for More Information. If you have any questions or concerns about this California Privacy Policy, or to request this California Privacy Policy in an alternative format, please contact us at:
- Post: at R&H Fund Services (Jersey) Limited, Ordnance House, 31 Pier Road, St Helier, Jersey, JE4 8PZ, Channel Islands
- Email: at dataprotection@rjh.je
