Amberstone Capital Group SPC Ltd. is the Data Controller for the personal data described in this Notice.
The Data Controller is registered through Quijano & Associates (BVI) Limited at Mandar House, 3rd Floor, Suite 301, P.O. Box 3159, Road Town, Tortola, British Virgin Islands. For all data-protection enquiries, please write to [[email protected]], marked for the attention of the Compliance Officer.
What we collect, and why we collect it.
| Category | Examples | Source |
|---|---|---|
| Identification data | Name, date of birth, nationality, place of residence, government identification numbers, photograph (where applicable) | You, your professional advisers, public registers |
| Contact data | Email address, postal address, telephone numbers, employer | You, your professional advisers |
| Financial & suitability data | Schedule 4 self-certification basis, source of funds, source of wealth, beneficial ownership chains, FATCA / CRS self-certifications | You, your professional advisers, screening providers |
| Compliance & screening data | PEP and sanctions screening results (OFAC, UN, EU, UK HMT, BVI local), adverse-media screening, enhanced due-diligence findings | Screening providers, public sources, Compliance Officer |
| Subscription & transaction data | Commitment amount, drawdown notices, distribution records, registered address, bank account details, tax-residence declarations | You, the Fund Administrator, the Banker / Escrow Bank |
| Website & technical data | IP address, browser type, device identifiers, country resolved by IP, Schedule 4 self-certification audit-log entries | Your browser, our hosting infrastructure |
| Correspondence | Emails, letters, recorded calls (where notice is given), meeting notes | You and our personnel |
Why we are entitled to process your data.
| Lawful basis (DPA, 2021) | Where it applies |
|---|---|
| Performance of a contract | To perform the Confidentiality Undertaking, the Subscription Agreement, and any other agreement to which you are party. |
| Compliance with a legal obligation | AML / CFT, Beneficial Ownership Secure Search System Act, FATCA & CRS reporting, statutory record-keeping. |
| Legitimate interests | To verify Schedule 4 status, prevent financial crime, manage relationships with prospective and current investors and service providers, and protect the Group's lawful business. |
| Consent | For Insights subscriptions and any other communication where consent is the appropriate basis. You may withdraw consent at any time without affecting the lawfulness of prior processing. |
| Public interest / vital interests | Where processing is necessary to comply with a regulatory request, to investigate suspected wrongdoing, or to protect a person from harm. |
Who we share data with.
Personal data is shared only with parties whose engagement is necessary to operate the Group, satisfy a legal obligation, or protect a legitimate interest. Each recipient is bound by written confidentiality and data-protection obligations.
| Registered Agent | Quijano & Associates (BVI) Limited — corporate-secretarial and Registered Agent functions. |
| Authorised Representative & BVI Legal Counsel | For BVI FSC liaison, regulatory submissions, and ongoing legal support. |
| Fund Administrator | NAV calculation, register of members, AML / KYC processing, subscription and redemption administration. |
| Auditor | Annual audit of the Fund's financial statements and IPEV-aligned valuations. |
| Banker / Escrow Bank | Operating, drawdown, and escrow account administration. |
| Screening providers | PEP, sanctions, and adverse-media screening at onboarding, on change of circumstances, and at least annually. |
| Tax authorities | FATCA reports filed via the BVI International Tax Authority; CRS reports filed via the BVI International Tax Authority. |
| Regulators | BVI Financial Services Commission, the BVI International Tax Authority, the BVI Financial Investigation Agency, and other competent authorities, where required by law. |
| Professional advisers | External counsel, accountants, and consultants engaged on a need-to-know basis. |
Cross-border processing.
The Group operates across the British Virgin Islands and, in respect of the Guarant Segregated Portfolio, the Turks and Caicos Islands. Service providers may also be located in the United Kingdom, the United States, and other jurisdictions. Where personal data is transferred outside the BVI, the Group ensures that an equivalent or higher standard of protection applies, by reference to (i) jurisdictions assessed by the Compliance Officer as offering adequate protection, (ii) contractual safeguards (including standard contractual data-protection clauses), or (iii) the explicit consent of the data subject where appropriate.
How long we keep your data.
Personal data is retained only for as long as is necessary to satisfy the purposes for which it was collected and the Group's legal-and-regulatory obligations. Indicative retention periods are below; specific periods may be longer where required by statute or by regulatory request.
| Schedule 4 self-certification audit log | [__ years] from the date of the certification |
| AML / KYC records | At least seven (7) years from the end of the business relationship |
| FATCA & CRS records | At least six (6) years from the end of the relevant reporting period |
| Subscription & transaction records | The life of the Fund plus seven (7) years |
| Investor correspondence | The life of the Fund plus three (3) years |
| Website & technical data | Up to twenty-four (24) months, unless retained for fraud-prevention or legal-defence purposes |
Rights under the BVI Data Protection Act, 2021.
| Right to be informed | You are entitled to clear information about how your data is processed — this Notice is part of how we provide that information. |
| Right of access | You may request a copy of the personal data we hold about you, subject to identity verification. |
| Right to rectification | You may request that inaccurate or incomplete data be corrected. |
| Right to erasure | You may request the deletion of personal data, subject to our legal-and-regulatory retention obligations. |
| Right to restrict processing | You may request a temporary or permanent restriction on processing in certain circumstances. |
| Right to object | You may object to processing on grounds relating to your particular situation. |
| Right to data portability | Where applicable, you may receive your data in a structured, commonly-used and machine-readable format. |
| Right to lodge a complaint | You may lodge a complaint with the BVI Information Commissioner if you believe your rights have been infringed. |
To exercise any right, please contact the Compliance Officer at [[email protected]]. We will respond within thirty (30) days, or as required by law if shorter.
This Notice is reviewed annually.
The Compliance Officer reviews this Notice at least annually at the Q4 governance cycle, and ad hoc on any material change in processing or applicable law. The current version and effective date are stated at the top of this page. Material changes are communicated to current investors in writing.