Privacy - Summit Management Limited

Summit Management Limited (“Summit”) is a company incorporated under the laws of the Cayman Islands.

The Cayman Islands Data Protection Act, 2017 (“Act”) came into force in the Cayman Islands on 30 September 2019.

This privacy policy applies to you if:

you are a client of Summit;
your personal data has been provided to Summit in connection with services offered by Summit; and
Summit otherwise uses your personal data.

This privacy notice sets out the basis on which personal data about you will be processed by Summit.

Under the Act the following designations are made in respect of Summit:

Data controller: with obligations under the Act to be responsible for ensuring that Summit only uses your personal data in compliance with the Act.
Data processor: with obligations under the Act to process your personal data only in connection with services provided by Summit in accordance with your instructions and the requirements of applicable Acts and industry practice.

The personal data provided to Summit may be stored and processed by Summit for the following purposes:

assessing suitability for acceptance as a client of Summit;
providing the requested services by Summit;
ongoing due diligence processing by Summit;
receiving payments for the services provided by Summit;
compliance with anti-money laundering and counter terrorism financing laws and regulations verification checks and reporting obligations;
the audit of Summit’s financial statements;
compliance with FATCA and CRS verification checks and reporting obligations;
compliance with beneficial ownership reporting obligations;
cyber security monitoring as between communications with clients of Summit and service providers;
regulatory inquiries from a competent regulatory having authority over Summit;
commencing or defending legal proceedings;
entering into directors and officers insurance by Summit;
disclosure to third parties to further the operations and objectives of the services required of Summit (although they will then have responsibilities on the use of your information under the Act);
the personal data will be transferred outside the Cayman Islands to third parties as may be required by the services requested, and include administrators and auditors subject to Summit confirming that the transfer is subject to safeguards or is otherwise permitted under the Act; and
retaining your personal data for the required regulatory period as may be imposed on Summit.

The Act providers certain rights relating to your personal data including the right to:

receive a copy of the information held;
be informed how the data is being processed;
request rectification of personal data if it is inaccurate;
object to, and the right to request that Summit restricts its processing of your personal data in certain circumstances. Summit may be legally entitled to continue processing your personal data or to refuse such a request;
request that you do not receive direct marketing as a result of the provision of your personal data; and
make a complaint with the Cayman Islands Ombudsman Office.

If you would like further information on the Act or the use of your personal data, please contact Summit at info@sml.ky