In December, the VN-Index continued its robust recovery...
This is the Privacy Policy Statement of Asia Frontier Capital Ltd., on behalf of itself, its affiliates and subsidiaries (AFC). The purpose of this Privacy Policy Statement is to set out the policies and practices of AFC’s commitment to protecting personal data privacy in accordance with the provisions of the Hong Kong Personal Data (Privacy) Ordinance as well as the European General Data Protection Regulation (GDPR).
For the purposes of the GDPR, we are a data controller in respect of your personal data. AFC is responsible for ensuring that it uses any personal data provided by you in compliance with the GDPR.
This privacy policy applies if you are an existing client or a prospective client. This privacy notice sets out the basis on which any personal data that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us.
We may collect and process the following personal data about you:
Uses of your personal data
Your personal data may be stored and processed by AFC in the following ways and for the following purposes:
We are entitled to use your personal data in these ways:
Disclosure of your information to third parties
We will take steps to ensure that personal data is accessed only by staff that have a need to do so for the purposes described in this notice.
We may also share your personal data outside of AFC and our affiliates:
Retention of personal data
How long we hold your personal data for will vary. The retention period will be determined by various criteria including:
Your rights
You have a number of legal rights in relation to the personal data that we hold about you. These rights include:
Accessing your personal data
You have the right to access and update your information and contact us. If you have any question about our Privacy Policy Statement, please contact us at:
Data Protection Officer
Asia Frontier Capital Ltd. / Asia Frontier Investments Limited
905 Loon Kee Building
267-275 Des Voeux Road Central
Hong Kong
Fax: 852 3904 1017
This email address is being protected from spambots. You need JavaScript enabled to view it.
May 2018
Cayman Privacy Notice of AFC Umbrella Fund
This privacy notice (Cayman Privacy Notice) explains the manner in which AFC Umbrella Fund (Fund) collects, processes and maintains personal data about you pursuant to the Data Protection Law, 2017 of the Cayman Islands, as amended from time to time and any regulations, codes of practice or orders promulgated pursuant thereto (DPL).
The Fund is committed to processing personal data in accordance with the DPL. In its use of personal data, the Fund will be characterised under the DPL as a 'data controller', whilst certain of the Fund's service providers, affiliates and delegates may act as 'data processors' under the DPL.
Interpretation: For the purpose of this Cayman Privacy Notice you or your shall mean, you, the holder of participating shares (Shareholder) in a sub-fund (Sub-Fund) of the Fund and shall also include any individual connected to you which could include: any person owning or controlling the Shareholder, having a beneficial interest in the Shareholder, any person for whom the Shareholder is acting as agent or nominee, any trustee, settlor or protector of a trust, and the directors, managers, members, officers and employees of all such persons. We, us or our means the Fund in its capacity as data controller of the personal data.
Personal data: By virtue of making an investment in the Fund, the investment manager of the Sub-Fund (Investment Manager), the investment adviser of the Sub-Fund (if applicable), Trident Fund Services (HK) Limited, the administrator of the relevant sub-fund, and their respective affiliates and delegates (Authorised Entities) may collect, record, store, transfer and otherwise process personal data[1] by which individuals may be directly or indirectly identified.
Much of the personal data will be provided through completion of subscription forms, investor questionnaires and other information provided by you in writing (including any anti-money laundering, identification, and verification documentation), in person, by telephone (which may be recorded), fax, electronically or by any other means.
We may combine personal data that you provide to us with personal data that we collect from, or about you. This may include personal data collected in an online or offline context including from credit
reference agencies and other available public databases or data sources, such as news outlets, websites and other media sources and international sanctions lists.
If you are a nominee investor or a corporate entity, this Cayman Privacy Notice will be relevant for those individuals connected to you and you should transmit this document to such individuals for their awareness and consideration.
Why is your personal data processed: Your personal data will be processed fairly and for lawful purposes, including:
As a data controller, we will only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will contact you.
Automated decision-making: We do not envisage that any decisions will be taken about you using fully automated means, however we will notify you in writing if this position changes.
Disclosure of personal data: We anticipate that we will share your personal data with the Authorised Entities for the purposes set out in this Cayman Privacy Notice as well as advisers (e.g. auditors, legal counsel and tax advisers) to the Fund and/or the Investment Manager relating to or in connection with subscriptions to the Fund. We may also share relevant personal data where it is lawful to do so and necessary to comply with our contractual obligations or your instructions or where it is necessary or desirable to do so in connection with any regulatory reporting obligations. In exceptional circumstances, we will share your personal data with regulatory, prosecuting and other governmental agencies or departments, and parties to litigation (whether pending or threatened), in any country or territory including to any other person where we have a public or legal duty to do so (e.g. to assist with detecting and preventing fraud, tax evasion and financial crime or compliance with a court order). At times, it may also be necessary to share relevant personal data with (i) a prospective service provider of the Fund including one which is replacing an existing service provider or (ii) to people or companies where required in connection with a potential or actual corporate restructuring, merger, acquisition or takeover of the Fund and/or the Investment Manager.
We will not sell your personal data. Any transfer of personal data outside of the Cayman Islands shall be in accordance with the requirements of the DPL. Where necessary, we will ensure that separate
and appropriate legal agreements are put in place with the recipient of that data. For example, where data is to be transferred to a person in a country which does not provide an adequate level of data protection, the Fund will ensure it puts in place appropriate safeguards, such as contracts which seek to ensure that any data processor is contractually bound to provide an adequate level of protection in respect of the personal data transferred to it and that any such transfer complies with the requirements of the DPL.
Your rights: You have certain rights under the DPL, including:
Please note that if you do not wish to provide us with requested personal data or subsequently withdraw your consent, you may not be able to invest in the Fund or remain invested in the Fund as it will affect our ability to provide our services to you and manage your investment.
Retention of Personal Data: The personal data shall not be held by the Fund for longer than necessary with regard to the purposes of the data processing.
Changes to Cayman Privacy Notice: We encourage you to regularly review this and any updated Cayman Privacy Notice to ensure that you are always aware of how personal data is collected, used, stored and disclosed.
Contact us: Please contact the Fund if you have any questions about this Cayman Privacy Notice, the personal data we hold about you or to discuss your data protection rights.
24th October 2019: Thomas Eugen Hugger, Chairman, This email address is being protected from spambots. You need JavaScript enabled to view it.
[1] Examples of personal data include: name, title, date of birth, age, gender, nationality, picture, national identification number, usernames, email address, residential address, postal address, telephone / mobile / fax number, family structure, siblings, offspring, source of wealth, personal assets, bank account numbers and income details, tax identification number, financial and investment qualification, shareholder reference number, payment details and other details of products and services purchased by the client, power of attorney information, job titles, employment history, employer details, personal data contained in emails, data regard the client's preferences in connection with marketing communications, personal data obtained pursuant to standard criminal record checks, data obtained further to the Fund's standard anti-money laundering and client due diligence checks. It may also include data which, when aggregated with other data, enables an individual to be identified, such as an IP address and geolocation data.
Cayman Privacy Notice of AFC Umbrella Fund (Non-US)
This privacy notice (Cayman Privacy Notice) explains the manner in which AFC Umbrella Fund (Non-US) (Fund) collects, processes and maintains personal data about you pursuant to the Data Protection Law, 2017 of the Cayman Islands, as amended from time to time and any regulations, codes of practice or orders promulgated pursuant thereto (DPL).
The Fund is committed to processing personal data in accordance with the DPL. In its use of personal data, the Fund will be characterised under the DPL as a 'data controller', whilst certain of the Fund's service providers, affiliates and delegates may act as 'data processors' under the DPL.
Interpretation: For the purpose of this Cayman Privacy Notice you or your shall mean, you, the holder of participating shares (Shareholder) in a sub-fund (Sub-Fund) of the Fund and shall also include any individual connected to you which could include: any person owning or controlling the Shareholder, having a beneficial interest in the Shareholder, any person for whom the Shareholder is acting as agent or nominee, any trustee, settlor or protector of a trust, and the directors, managers, members, officers and employees of all such persons. We, us or our means the Fund in its capacity as data controller of the personal data.
Personal data: By virtue of making an investment in the Fund, the investment manager of the Sub-Fund (Investment Manager), the investment adviser of the Sub-Fund (if applicable), Trident Fund Services (HK) Limited, the administrator of the relevant sub-fund, and their respective affiliates and delegates (Authorised Entities) may collect, record, store, transfer and otherwise process personal data[1] by which individuals may be directly or indirectly identified.
Much of the personal data will be provided through completion of subscription forms, investor questionnaires and other information provided by you in writing (including any anti-money laundering, identification, and verification documentation), in person, by telephone (which may be recorded), fax, electronically or by any other means.
We may combine personal data that you provide to us with personal data that we collect from, or about you. This may include personal data collected in an online or offline context including from credit
reference agencies and other available public databases or data sources, such as news outlets, websites and other media sources and international sanctions lists.
If you are a nominee investor or a corporate entity, this Cayman Privacy Notice will be relevant for those individuals connected to you and you should transmit this document to such individuals for their awareness and consideration.
Why is your personal data processed: Your personal data will be processed fairly and for lawful purposes, including:
As a data controller, we will only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will contact you.
Automated decision-making: We do not envisage that any decisions will be taken about you using fully automated means, however we will notify you in writing if this position changes.
Disclosure of personal data: We anticipate that we will share your personal data with the Authorised Entities for the purposes set out in this Cayman Privacy Notice as well as advisers (e.g. auditors, legal counsel and tax advisers) to the Fund and/or the Investment Manager relating to or in connection with subscriptions to the Fund. We may also share relevant personal data where it is lawful to do so and necessary to comply with our contractual obligations or your instructions or where it is necessary or desirable to do so in connection with any regulatory reporting obligations. In exceptional circumstances, we will share your personal data with regulatory, prosecuting and other governmental agencies or departments, and parties to litigation (whether pending or threatened), in any country or territory including to any other person where we have a public or legal duty to do so (e.g. to assist with detecting and preventing fraud, tax evasion and financial crime or compliance with a court order). At times, it may also be necessary to share relevant personal data with (i) a prospective service provider of the Fund including one which is replacing an existing service provider or (ii) to people or companies where required in connection with a potential or actual corporate restructuring, merger, acquisition or takeover of the Fund and/or the Investment Manager.
We will not sell your personal data. Any transfer of personal data outside of the Cayman Islands shall be in accordance with the requirements of the DPL. Where necessary, we will ensure that separate
and appropriate legal agreements are put in place with the recipient of that data. For example, where data is to be transferred to a person in a country which does not provide an adequate level of data protection, the Fund will ensure it puts in place appropriate safeguards, such as contracts which seek to ensure that any data processor is contractually bound to provide an adequate level of protection in respect of the personal data transferred to it and that any such transfer complies with the requirements of the DPL.
Your rights: You have certain rights under the DPL, including:
Please note that if you do not wish to provide us with requested personal data or subsequently withdraw your consent, you may not be able to invest in the Fund or remain invested in the Fund as it will affect our ability to provide our services to you and manage your investment.
Retention of Personal Data: The personal data shall not be held by the Fund for longer than necessary with regard to the purposes of the data processing.
Changes to Cayman Privacy Notice: We encourage you to regularly review this and any updated Cayman Privacy Notice to ensure that you are always aware of how personal data is collected, used, stored and disclosed.
Contact us: Please contact the Fund if you have any questions about this Cayman Privacy Notice, the personal data we hold about you or to discuss your data protection rights.
24th October 2019: Thomas Eugen Hugger, Chairman, This email address is being protected from spambots. You need JavaScript enabled to view it.
[1] Examples of personal data include: name, title, date of birth, age, gender, nationality, picture, national identification number, usernames, email address, residential address, postal address, telephone / mobile / fax number, family structure, siblings, offspring, source of wealth, personal assets, bank account numbers and income details, tax identification number, financial and investment qualification, shareholder reference number, payment details and other details of products and services purchased by the client, power of attorney information, job titles, employment history, employer details, personal data contained in emails, data regard the client's preferences in connection with marketing communications, personal data obtained pursuant to standard criminal record checks, data obtained further to the Fund's standard anti-money laundering and client due diligence checks. It may also include data which, when aggregated with other data, enables an individual to be identified, such as an IP address and geolocation data.
Thomas Hugger wins #1 Spot in Citywire/Lipper's
|
Thomas Hugger wins #1 Spot in Citywire/Lipper's Frontier Markets Equity Managers Review
Asia Frontier Capital Limited is very pleased to announce that Thomas Hugger, CEO and Fund Manager, has just been rated the Top-Performing Frontier Markets Equity Manager by Citywire/Lipper on 26th November 2015 for managing the AFC Asia Frontier Fund. The three year total net return for the fund is +42.59%, which is 9.11% more than the second place finisher and 27.32% higher than the average of all the frontier markets funds that were rated. Citywire/Lipper writes: Even more important than the fund’s stellar performance is its low risk level. This risk level, measured in terms of maximum drawdown or lowest standard deviation, is the lowest of all the frontier funds rated on Citywire/Lipper. The fund has a maximum drawdown of -5.7% and an average non-annualised standard deviation of just 2.6% in the last 3 years. Thomas and his team achieved these results as a culmination of more than three years of dedication to stock selection in the Asian frontier universe combined with careful risk management and a well-founded macro strategy. Thomas and our research analysts have spared no effort in analysing individual companies, including visits to numerous facilities of companies in frontier countries. Some of these trips to remote areas are recounted in our monthly newsletters. With his 27 years’ experience in equity investment, Thomas has built up a wealth of expertise on company and macro-economic analysis, as well as extensive emerging and frontier market knowledge. This is now paying off, as he has reached star status as Citywire’s #1 Frontier Markets Equity Manager. For the full article, please go to Citywire’s website by clicking here (the runners-up are listed first). You can read more about Thomas Hugger and the AFC Asia Frontier Fund on www.asiafrontiercapital.com or download the latest fund factsheet here:
If you would like further information or have a query about Asia Frontier Capital or our funds, please do not hesitate to contact me at This email address is being protected from spambots. You need JavaScript enabled to view it.. With best regards, Peter de Vries http://www.asiafrontiercapital.com/ Asia Frontier Capital Limited
Disclaimer:This document does not constitute an offer to sell, or a solicitation of an offer to invest in AFC Asia Frontier Fund, AFC Asia Frontier Fund (non-US), AFC Iraq Fund, AFC Iraq Fund (non-US), AFC Vietnam Fund or any other funds sponsored by Asia Frontier Capital Ltd. or its affiliates. We will not make such offer or solicitation prior to the delivery of a definitive offering memorandum and other materials relating to the matters herein. Before making an investment decision with respect to our Funds, we advise potential investors to read carefully the respective offering memorandum, the limited partnership agreement or operating agreement, and the related subscription documents, and to consult with their tax, legal, and financial advisors. We have compiled this information from sources we believe to be reliable, but we cannot guarantee its correctness. We present our opinions without warranty. Past performance is no guarantee of future results. © Asia Frontier Capital Ltd. All rights reserved. The representative of the funds in Switzerland is Hugo Fund Services SA, 6 Cours de Rive, 1204 Geneva. The distribution of Shares in Switzerland must exclusively be made to qualified investors. The place of performance and jurisdiction for Shares in the Fund distributed in Switzerland are at the registered office of the Representative. By accessing information contained herein, users are deemed to be representing and warranting that they are either a Hong Kong Professional Investor or are observing the applicable laws and regulations of their relevant jurisdictions.
|