ONEWORLD PLUS MANAGEMENT LIMITED, (“
Oneworld Plus Management”, “we”, “us”, “our”) is a company duly incorporated under the laws of the Republic of Cyprus and operates as a “Super ManCo” offering both AIFM and UCITS ManCo services authorised and regulated by the Cyprus Securities and Exchange Commission (CySEC).
This Privacy Policy contains the personal data collection and use procedures adopted by Oneworld Plus Management in connection with this website (the “
Site”). References to “
you” and “
your” are references to a user of our website.
This Privacy Policy (“
Privacy Policy”) (together with our
Terms and Conditions) explains what personal data we collect from you or you provide to us, how we use it and with whom we share them. The Privacy Policy also sets out your rights and who you can contact for more information.
Please read the following carefully in order to understand our views and practices regarding your personal data and how we will treat it. We are committed to protecting and respecting your privacy and handling your personal data in an open and transparent manner.
We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as “
processing”.
In this Privacy Policy the term “
Data Protection Legislation” means the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection of the Republic of Cyprus and the EU.
For the purposes of Data Protection Legislation the data controller is Oneworld Plus Management.
Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and are generally collected so that we can deliver requested materials, information or services.
We may collect, record and use data about you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Legislation and as set out in this Privacy Statement.
A. Information we may collect and process:
- Your Internet Protocol (IP) address: The IP address indicates the location of your computer on the Internet and is used to connect your computer to the Internet. This information may be aggregated to provide statistical information about the users of our Site. No individual user will be identifiable from such information, which is used to ensure the Site reflects the needs of users. Whilst IP addresses may be categorised as personal information, we do not use this data to track your session.
- Your browser type and language: We may need these data for functional purposes, specifically, to monitor the good function of our Site.
- Your use of our Site: Information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page. We may collect these data in order to maintain a user-friendly Site.
- Your opinion: We may also, from time to time while you are accessing the Site, request you to complete a survey form which may relate either to your use of the Site and/or information posted on the Site. This is voluntary and helps us improve our Site and provision of services.
- Data necessary for certain services: Your personal data is necessary to enable Oneworld Plus Management to deal with your enquiry, but additional information may be requested to help us provide the most appropriate response. If such additional information is requested, it is highlighted and its provision is voluntary. Such data may be your name, contact details, educational background, financial status etc.
- Data for newsletter registration: When you register with us, use our services, book to attend an event or submit a subscription request (e.g. to receive a newsletter or for marketing information), make an enquiry (either by submitting an online enquiry form or by corresponding with us by phone, e-mail or otherwise), you may be asked to provide some personal information such as your name and contact details (including telephone number, home address, date of birth and email address) and website registration credentials (username and password). Oneworld Plus Management does not require registration for access to the Site in general but you may be asked to register in order to access certain areas.
- Data for employment: If you apply to work and send us your CV, you may be asked to provide us with certain additional sensitive personal data. Please see Paragraph B below for more details.
B. Sensitive Personal Data
When you apply for one of our jobs, you might need to register with us and submit an application. Data Protection Legislation gives special protection to certain types of sensitive information (which includes 'sensitive' or 'special categories' of personal data as defined by Data Protection Legislation). Special categories of personal data can include data about your race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record. You should only provide this information if it is required in response to a mandatory question on our registration form, or if you are otherwise content for us to process this information in accordance with the terms of this Privacy Policy. Where you do provide sensitive personal data these will be accepted as explicit consent to Oneworld Plus Management to use them in connection with the purpose for which they have been provided.
Your data is processed with a de minimis principle in mind, which means that we limit such processing only for necessary legitimate reasons. We may also use the information that you have provided to ensure that the content on our Site is presented in the most effective manner for you and your electronic device.
We use your information for the following specific purposes:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to notify you about changes to our service;
- to ensure that content from our Site is presented in the most effective manner for you and for your electronic device;
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- as part of our efforts to keep our Site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to consider your application where you have applied for a position with us;
- to send you our newsletter or updates, or to make suggestions and recommendations of our Site about services that may interest you; and provide you with targeted marketing in relation to our services (unless you indicate at any time that you do not wish us to do so); and
- to offer you the opportunity to further request other information that may be of interest when applying for material or asking someone to contact you.
- to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping; and
- Improving our products and services.
We will only keep the information we collect about you, through your use of the Site or otherwise, for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
We take your online security seriously and have implemented generally accepted standards of technology and operational security to protect your personal data from loss, misuse, alteration or destruction. Once we have received your personal data we ensure that the collection and use of it is in accordance with Data Protection Legislation and this Privacy Policy. All personnel of Oneworld Plus Management authorised to access and process personal data are required to keep such data confidential at all times, unless otherwise required by the public authorities (e.g. police, court authorities, etc.) and our legal obligations.
Please note that we take all steps to keep secure the data provided to us via our Site, however, we cannot guarantee that the transmission of such data via the Internet is completely secure.
Data that you submit via our website is sent to and stored on secure servers in Microsoft Azure.
Your personal data may be transferred, stored and processed by staff who work for us, or for one of our service providers, related companies, agents or contractors and is operating at a country outside the European Economic Area (“EEA”). Such transfers may be made in order to improve our Site or to assist in our security or fraud protection activities. We try to take all necessary steps so that the staff who work for us, or for one of our service providers, related companies, agents or contractors who are operating outside the EEA comply with the GDPR and all applicable data protection legislation.
When we, or our permitted third parties, transfer your information outside the EEA, we or they will impose contractual obligations on the recipients of that data to protect them to the standard required in the EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing.
We are committed to ensuring that your data is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the data we collect online. Our employees will never ask you for your username and/or password so please treat them as extremely confidential and refrain from sharing them over email or phone.
Data is only provided to a third party if it is required in handle your enquiry, but there may be other circumstances where it is necessary for Oneworld Plus Management to provide data as a result of legal or regulatory process.
The following categories of recipients may receive your personal data and process it for the purposes outlined in this Privacy Statement:
- third party companies, agents, contractors, service providers or related companies (including payment processors) if this is necessary to provide you with our products and services, respond to your enquiries or for any other related purposes;
- analytics and search engine providers that may assist us in the improvement and optimisation of our Site;
- third parties who support our information technology or handle mailings or events on our behalf;
- law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site, our technology assets or the rights, property or personal safety of any person);
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity; and
- any successor in interest, in the event of a liquidation or administration of Oneworld Plus Management.
We do not undertake marketing activities for third parties, nor do we provide information to third parties for their own marketing purposes.
We will not sell, distribute or lease your personal data to third parties unless we are required by law to do so. We will never use your personal data to send you promotional information about third parties unless you tell us that you wish this to happen.
The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever you process personal data:
- you have given clear consent for us to process your personal data for a specific purpose.
- the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
- Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
- Vital interests: the processing is necessary to protect someone’s life.
- Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
- Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.
At any time, you have the right:
- to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from whom it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
- to request access to or a copy of any personal data which we hold about you;
- to rectification of your personal data, if you consider that it is inaccurate;
- to ask us to delete your personal data, if you consider that we do not have the right to hold it;
- to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- to ask us to stop or start sending you marketing messages (e.g. our newsletter) at any time by using the below contact details;
- to restrict processing of your personal data;
- to data portability (moving some of your personal data elsewhere) in certain circumstances;
- to object to your personal data being processed in certain circumstances; and
- not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
We will correct any incorrect or incomplete data and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that data.
We aim to ensure that the data we hold about you is accurate at all times. To assist us in ensuring that your data is up to date, do let us know if any of your personal details change.
If you believe that any data we are holding on you is incorrect or incomplete or you need further details on how you can invoke any of your rights, please email us as soon as possible at
info@oneworldaifm.com. We will promptly correct any information found to be incorrect.
You have the option of “unsubscribing” from our mailing list for newsletters, alerts and updates at any time, thereby disabling any further such e-mail communication from being sent to you. To unsubscribe you can send us an email at
info@oneworldaifm.com. In addition, each electronic mailing we send you will contain details of how you can unsubscribe by clicking on the “unsubscribe” link in the email.
Please note that it may take up to one month to action your request.
If you have any concerns or questions about the security of our Site, this Privacy Policy or any personal data we collect from you, please do not hesitate to contact us at
info@oneworldaifm.com.
Additionally, if you have any concerns about our use of your information, you also have the right to make a complaint to the Data Protection Commissioner's Office, which regulates and supervises the use of personal data in Cyprus:
http://www.dataprotection.gov.cy
1 Iasonos str, 1082 Nicosia
P.O.Box 23378, 1682 Nicosia
Tel: +357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy
Our Site may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our Site, you should note that we do not have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Any changes to our Privacy Statement will be posted on this page of the Site. We encourage you to check the Privacy Policy each time you use the Site. If our Privacy Policy changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
This Privacy Policy is effective from 01/05/2020.