Omba Advisory & Investments Ltd (“Omba”) is committed to protecting your personal information and respecting applicable data protection laws around the world.

This privacy policy explains how we do this, and it applies to your use of our websites, products, and services.

How we use your personal information

We use personal information in order to promote and provide Omba products and services, to ensure the security of our websites, and to run our business. We have set out below more information on the categories of personal information that we collect, the specific ways in which that personal information is processed by us, the legal bases which permit us to do this, and the types of partners with whom we share your personal information.

In some cases where we ask for your personal information, we do so in order for us to fulfil your request or order (e.g. needing your email address to communicate with you). If you do not provide that personal information we will not be able to process your request or order.

What information does Omba collect?

We collect and process personal data about you when you purchase our services and interact with us and our websites. This information includes:

• Your marketing preferences, including any consents you have given us
• Information related to the browser or device you use to access our websites
• Records of your use of our services
• Any other personal information you voluntarily share with us

As a client:

• Your name, date of birth, nationality, passport number
• Your address, email address, and contact phone numbers
• Your payment details
• Information on your financial affairs, including details of your income and assets

How does Omba use your information?

We use your information as follows:

To fulfil a contract with you or take steps at your request before this:

• Providing discretionary investment management services or financial advice and investment/technical support if you ask for this
• Contacting you with information about changes to our services
• Handling your payments to us
• Storing and analysing your information in order to review and progress your job application if you apply to work with us

As required by Omba to conduct our business and pursue our legitimate interests, in particular:

• Giving you access to our products or services
• Letting you know about Omba’s products and services by post, email, and phone in accordance with your marketing preferences and laws relating to direct marketing
• Providing targeted advertising for other Omba products and services that we think may be of interest to you, based on how you use Omba websites, products and services
• Analysing how you use Omba products and services so we can improve our levels of service and develop future products and services, including through the use of surveys
• Ensuring the security of Omba’s websites and information technology systems and protecting Omba’s rights

Where you give us consent:

• If we need your consent in order to send marketing for Omba products and services to you

For purposes which are required by law:

• Sharing your personal information in order to comply with legal obligations to which Omba is subject.

How will Omba share your information?

We share your personal details:

• Within Omba in order to carry out the processing described above
• With third party service providers who process your information on Omba’s behalf for the purposes above – such as administrators, custodians, fund managers, brokers, financial institutions, payment processors, or our technology service providers

We will also share your personal information:

• If we think this is necessary to in order to protect the rights, property, or safety of Omba, our employees, our commercial partners, or our customers
• With third party agencies for the purposes of fraud protection and credit risk reduction
• With government authorities, financial regulators, and law enforcement officials if required by law.

Giving and withdrawing your consent, and updating your personal information

Where your consent is required for us to process your personal information, we will ask for your consent at the point at which you provide your data.  You have the right to withdraw that consent at any time. You can also update your personal information at any time. If you wish to do either, contact us at compliance@ombainvestments.com

Storing your personal information

Your personal information may be stored and processed outside of the country where it is collected, including outside of the United Kingdom (UK) or the European Economic Area (EEA). When transferring information to others, within the UK or the EEA or otherwise, we ensure that appropriate and suitable safeguards and technical measures are in place to protect your personal data. To do this, we make use of standard contractual clauses that have been approved by the European Commission with our suppliers, or we implement other similar measures required by laws around the world.

We will only keep records of your personal information for as long as is reasonably necessary for the purposes for which we have collected it, and in order to comply with any statutory or regulatory obligations in relation to retention of records. We respect requests to stop processing your personal data for marketing purposes. This includes keeping a record of your request indefinitely so that we can respect your request in future.

Cookies

We use cookies on our websites and similar technologies in our apps and other software.  Please see our Cookie Policy for details of how this may apply to you.

Your rights

You have the right to request access to and rectification or erasure of personal information, the right to restrict processing of your personal information, and the right to object to processing of your personal information. You have the right to object to your personal information being processed on the grounds of Omba’s legitimate interests. You have the right to object to us sending you direct marketing and profiling you for the purposes of direct marketing. You have the right to lodge a complaint regarding our processing of your personal information with a data protection supervisory authority in a country where you live, work, or where you believe a breach may have occurred. 

Contacting us

The data controller for our websites, products and services is OMBA Advisory & Investments Ltd, Cargo Works, 1-2 Hatfields, London, SE19PG.

You can contact us by email at compliance@ombainvestments.com in relation to any of the rights described in this privacy policy, or if you have any questions regarding this privacy policy.