Website Privacy Policy


Last updated: 9th April 2020


This Website, (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 very serious, therefore we urge you to read this policy care as it contains important information on:


  • Who we are,
  • How and why we collect, store, share and otherwise use your personal information,
  • The rights you have in respect of your personal information, 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 information about you that we collect, or you provide us with, through your use of this Website. When we do so, we are regulated under the General Data Protection Regulation (the “GDPR”) and other applicable data protection legislation which apply across the European Union and the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.


What personal information we collect


When you visit our Website, we collect and use certain personal information of yours.  The personal information 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 about you.  Please see “Cookies and similar technologies” below for more information.


How we use your personal information 

We collect the personal information described above for the following reasons:

  • to provide you with 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. 

We rely on the following lawful grounds to process your personal information:

  • your consent, for example when we 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 information 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 is stated above, we may collect personal information 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 we use, please refer to our Cookies Policy.


Who your personal information may be shared with


We may share your personal information for the following reasons:

  • we may share your personal information with law enforcement agencies, officials, regulatory agencies or other bodies which we are legally required to share the information with in connection with any investigation to help prevent unlawful activity;
  • we may share your personal information 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 information 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 information.


We will not share your personal information with any other third parties.


How long will your personal information be kept

We will only retain your personal information 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 information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 


Keeping your personal information safe


We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information 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 information secure.


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 information, 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 information that is transferred from you or to you via the internet. If you have any particular concerns about your personal information please contact us using the details below.


Transfers of your personal information out of the EEA


We will not transfer your personal information outside of the European Economic Area at any time.


Your rights and your personal information

Unless subject to an exemption under the GDPR or other applicable data protection legislation, you have the following rights with respect to your personal information:

  • The right to request a copy of your personal information which we hold about you;
  • The right to request that we correct any personal information if it is found to be inaccurate or out of date;
  • The right to request your personal information is erased where it is no longer necessary for us to retain such personal information;
  • If we rely on your consent to process your personal information, the right to withdraw your consent to the processing at any time;
  • The right to request that we provide you with your personal information and where possible, to transmit that personal information 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 information, to request a restriction is placed on further processing;
  • The right to object to the processing of personal information;
  • The right to lodge a complaint with a supervisory authority.  The supervisory authority in the UK is the Information Commissioners Office.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the GDPR.

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 information about you. We do not control these third-party websites, plug-ins and/or applications and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website or application you visit or use.

Changes to the privacy policy

This privacy policy was last updated on the data 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.