MONUMENT GROUP – PRIVACY NOTICE FOR EU INDIVIDUALS
This Notice sets forth the privacy practices of Monument Group, Inc. and its associated entities (collectively, “Monument Group”, “we”, “us” or “our”) with respect to the personal information (i.e. information which directly or indirectly identifies an individual) of parties who provide personal information to Monument Group in connection with doing business with Monument Group, or otherwise interact with Monument Group. For the purposes of EU data protection laws, Monument Group is the data controller (i.e. the company responsible for, and which controls the processing of your personal information).
Collection and Use of Personal Information
We may collect and process your personal information when you: (i) provide us with your personal information when you are a prospective, former or current client and/or investor in one or more of our client’s funds (ii) contact us via the Site; and/or (iii) act as a referee in providing certain information to us about our clients.
If you provide personal information, we may use that personal information to:
- respond to your requests and enquiries, including any contact via our website www.monumentgroup.com(the “Site”);
- provide you with services, if you are a prospective, former or current client of Monument Group;
- provide you with information concerning funds we may be marketing if you are an investor or prospective investor and/or deal with any requests or inquiries you may have concerning such funds;
- provide referencing reports about our clients to prospective investors;
- conduct our recruiting and selection process; and
- comply with any applicable laws or regulations in any country
Purposes of the Processing
Monument Group will process personal information where necessary for the performance of a contractual relationship with an individual, where in our legitimate interests, or to enable Monument Group to comply with its legal and regulatory obligations.
Please note that you have the right to object to the processing of your personal information where that processing is carried out in Monument Group’s legitimate interest or for direct marketing. Although you have a right to object to our processing of your personal data for the business reasons detailed herein, such legitimate business interests may nonetheless require our continued processing of your data.
Disclosure to Certain Third Parties
We may disclose certain personal information: (i) to our affiliates and service providers; with whom we have put in place European Commission-approved data transfer agreements and/or other appropriate contractual data safeguarding terms (ii) to fraud prevention agencies and law enforcement agencies; (iii) to courts, governmental and non-governmental regulators, tax authorities and ombudsmen; (iv) to any third parties that acquires, or is interested in acquiring, all or part of Monument Group’s assets or shares, or that succeeds Monument Group in carrying on all or a part of its business, whether by merger, acquisition, reorganization or otherwise; or (v) as required or permitted by law, including to comply with a subpoena or similar legal process or request by a governmental, self-regulatory, or regulatory organization, or when Monument Group believes in good faith that disclosure is legally required or Monument Group has a legitimate interest in making disclosure, such as where necessary to protect Monument Group’s rights and property.
Consequences of Not Providing Personal Information
If you do not provide your personal information, we may not be able to provide you with the requested services or continue our relationship with you. If you are an investor or a prospective investor, where Monument Group requires personal information to comply with anti-money laundering or other requirements, failure to provide this information means Monument Group or the fund in which you wish to invest may not be able to accept you as an investor and may result in Monument Group terminating its relationship with you.
Transfer of Personal Information Outside the EEA
Where you are located in the European Economic Area (“EEA”), personal information collected from you for the above purposes may be transferred to recipients in countries located outside of the EEA, including to Monument Group in the US, Hong Kong, Japan and certain service providers, which do not provide a similar or adequate level of protection to that provided by countries in the EEA. By submitting your personal information to Monument Group, you consent to the transfer of your personal information to recipients, as described in this Notice, which are located outside the EEA. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Monument Group has put in place EU Commission approved Model Clauses for transfers of personal information between Europe, the US, Hong Kong and Japan. Where Monument Group transfers personal data to other recipients outside of the EEA, Monument Group will enter into a Model Contract with the recipient or seek assurances from the recipient that they are EU-U.S. Privacy Shield certified or have Binding Corporate Rules in place. You can request copies of the Model Clauses by contacting GDPR@monumentgroup.com.
Rights for Individuals in Europe
Individuals in the EEA have certain data subject rights which may be subject to limitations and/or restrictions. These rights may include the right to: (i) request access to and rectification or erasure of their personal information; (ii) obtain restriction of processing or to object to processing of their personal information; and (iii) ask for a copy of their personal information to be provided to them, or a third party, in a digital form. If you wish to exercise one of the above-mentioned rights, please send your request to GDPR@monumentgroup.com. Individuals in the EEA may also have the right to lodge a complaint about the processing of their personal information with their local data protection authority.
Security and Retention
Monument Group will take reasonable steps to protect personal information against loss or theft, as well as from unauthorized access, disclosure, copying, use, or modification, regardless of the format in which it is held. Monument Group will retain personal information for as long as is necessary or relevant for the purposes described in this Notice or for as long as required for us to perform the services or comply with applicable legal or regulatory obligations.
If you have any questions about this Notice, or if you are located in the EEA and wish to exercise your data subject rights, please contact us at GDPR@monumentgroup.com.
Effective Date of Notice: May 25, 2018
 Monument Group Europe LLP; Monument Group, LP; and Monument Group (HK) Limited