How we handle personal data on this site.

This notice

This notice is provided by Mk Timothy & Company for itself and its divisions, branches, subsidiaries, affiliates, and associated entities (together, “Mk Timothy & Company”, “we”, “us”, or “our”).

It is written for people outside our organisation: visitors to this website, people who contact us, investors and prospective investors in our funds or investment vehicles, and individuals who act for those investors.

The notice will change when the law changes or when our handling of personal data changes. If you have an ongoing relationship with us, check this page from time to time.

Overview

If you are looking for how we process information about investors in our funds or other investment products, read the sections below on collection, lawful bases, and recipients. If you are in the network of an Mk Timothy & Company employee, we may store and use your personal data for internal business purposes.

If you send us information through this website, for example by email, we use it for the purpose you sent it. That includes answering you, and any investigation or research that answer requires. We may also keep it to improve the site and our services.

We do not disclose your information outside Mk Timothy & Company except to service providers, investment advisers, professional advisers, and their agents or employees under confidentiality duties; where the law, legal proceedings, or a governmental or regulatory request requires it; or where we believe it is necessary to protect our rights or property.

If we later send you information about Mk Timothy & Company that you did not ask for, you can tell us to stop. Use the verified WhatsApp Business channel published on this site, +256 200 902 209.

Words we use

Entities in the European Economic Area are subject to the GDPR. If you live elsewhere, other laws may use different terms. In this notice:

• Adequacy decision means a European Commission decision that a country outside the EEA protects personal data to an adequate level.
• Criminal offences data means personal data about actual or alleged convictions or offences, and related security measures.
• Data controller means the Mk Timothy entity that decides how and why personal data is processed.
• Personal data means information from which a natural person can be identified.
• Processing means anything done with personal data, automated or not, including collection, storage, use, disclosure, restriction, and erasure.
• Processor means a person or entity that processes personal data on behalf of a controller.
• Sensitive personal data means data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health, sexual life, criminal offences, or other information treated as sensitive under applicable law.

Who controls the data

The general partner of an Mk Timothy Partners investment fund in which you are invested is a data controller. A fund manager, investment adviser, or portfolio manager engaged in that chain may also process your data as an independent controller.

Where personal data comes from

• From you, in calls, voicemails, letters, and email.
• From your business with us, including a subscription, anti-money-laundering identification, source-of-funds information, an investor questionnaire, or a request to be treated as a professional client.
• From your visit to this website, including registration details and cookies.
• From public sources, including the internet, publications, directories, and registries.
• From third parties such as tax authorities, regulators, credit agencies, and fraud-prevention organisations.

What we collect

What we collect depends on your relationship with us. For an investment in a fund or other vehicle, that can include:

• Name, date and place of birth, and contact and professional addresses.
• Account data, payment instructions, and information in documents you or an adviser provide.
• Risk tolerance, transaction history, investment experience, and the experience of people who decide for an organisation.
• Status under applicable laws, including tax status, income, and assets where required.
• Accounts and transactions with other institutions.
• Your interest in Mk Timothy funds, including ownership, capital, income, and losses.
• Citizenship and residence.
• Source of funds.
• Anti-money-laundering identification and, where relevant, politically exposed person information.

Why we collect it

We need a lawful basis. More than one can apply. The table summarises common activities. We process sensitive personal data only where the law requires it, and only with your express consent. If you do not provide data we need for these purposes, we may be unable to provide the service.

Recipients

Where EU data protection law allows, we may disclose personal data to other entities in the Mk Timothy group and to professional advisers, lenders, processors, and other people engaged for the purposes in this notice. That includes administrators to Mk Timothy & Partner funds and their processing or payment agents. We may also share data with competent regulators, tax authorities, auditors, and tax advisers where necessary or required by law.

International transfers

Our business is international. We may transfer personal data to countries that do not provide the same safeguards, including other members of the group and the third parties described above. Where we transfer data outside the European Economic Area we do so on an adequacy decision, model contract clauses, or another valid transfer mechanism. Ask us if you want more detail on those safeguards.

Because we use a shared IT environment, authorised people in countries whose laws differ from the EEA may access information you provide. We keep organisational and security measures across the organisation.

Cookies and site use

We do not try to identify ordinary visitors. We do record usage such as visitor numbers and frequency, the sites you come from and go to, your browser, and your IP address. If we use that data, we use it in aggregate and do not disclose information that identifies you, except to IT providers or where the law requires it.

This site uses cookies so it can recognise a return visit without identifying you. If you do not want cookies, use your browser’s controls to refuse them.

Security and retention

We use technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, and unauthorised access.

We keep personal data for as long as a legitimate business purpose, a contract, a legal or regulatory duty, or a limitation period requires. Investment data is kept through the life of the investment and no longer than that purpose needs. Some data remains after you cease to be an investor.

Your rights

• Access, or a copy of, your data.
• Rectification.
• Restriction of processing.
• Erasure, where that right applies. It is not absolute, including where we must keep data for a legal duty.
• Data portability.
• Withdrawal of consent, where we rely on consent.
• Not to be subject to automated decision-making. We do not use automated decision-making.

Complaints

If you are concerned about how we use your personal data, contact us on the verified WhatsApp Business channel +256 200 902 209. You may also contact the data protection authority in your country.