Privacy Policy

Arabesque Group – Privacy Policy

In accordance with its obligations under the General Data Protection Regulation (“GDPR“), the Data Protection Act 2018 (the “DPA”), and other applicable data protection laws and regulations, (collectively hereinafter the “Data Laws”) the Arabesque group of companies (hereinafter the “Arabesque Group”, “we”, “us” or “our”)  set forth herein its Privacy Policy (the “Policy“) to describe how we hold your data and/or information and what your data and information is used for in connection with the services and products that we offer and provide.  This Policy applies to data and information that we collect when you use www.arabesque.com and any other websites operated by Arabesque, mobile applications, and/or services (“Website”) that refer to this Policy.  

The Arabesque Group is committed to protecting and respecting your private data and information.   Accordingly, this Policy sets out the basis upon which any personal data and information that the Arabesque Group collects from you, or that you provide to the Arabesque Group, will be processed by us. Reference to the Arabesque Group herein refers to the following  entities: Arabesque Asset Management Limited & Arabesque AI Limited (Jamestown Wharf, 32 Jamestown Road, London, NW1 7BY, United Kingdom); Arabesque Deutschland GmbH (Lindleystr. 8A, Frankfurt am Main, Germany); and Arabesque Asset Management Singapore Pte. Limited (18A Gemmill Lane, Singapore, 069255) and branches of the foregoing (“Arabesque” or “Arabesque Group”).

1. Who are we and what do we do?

The Arabesque Group consists of two core operational divisions: asset management and artificial intelligence.  In conducting its activities, the Arabesque Group collects personal data and information from the following types of people in order to enable the Arabesque Group to offer and provide our services:

2. Information you give to us or we collect about you

This includes any data and information about yourself that you give to the Arabesque Group in connection with the provision of our services and/or by corresponding with us by telephone, email, in writing or otherwise.

It can include data and information that you provide to us when you enquire about, or invest in, a collective investment scheme for which we act as investment manager, subscribe to our mailing lists and/or attend events or meetings organised by us in connection with our asset management activities.  It includes information that you provide to us when you appoint us as the investment manager of your managed account, and/or attend events or meetings organised by us in connection with our financial services business. It includes information that you provide to us in connection with our artificial intelligence business. 

The information that you provide to the Arabesque Group, or that we collect from you, may include your name, address, date of birth, private and/or corporate email address, private and/or corporate telephone number, specific and general financial information, sensitive documentation and other data and information which relates to, amongst other things, your background, circumstances, investment experience, and information pertaining to your employment including obtaining information from public registers with governmental and/or quasi-governmental organisations (e.g. the Financial Conduct Authority), copies of identification documents such as a passport or driving licence, photographs, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, other forms of social media and/or a corporate website.

The Arabesque Group also uses ‘Cookies’ to automatically collect certain information about visits to the Website which helps us to make improvements relating to Website content and navigation. It may include your IP address, the date, times, and frequency with which you access the Website, and the way you use and interact with its contents.  Please refer to our Cookies Policy set out on our website.

3. Purposes of the processing and legal basis for the processing

The Arabesque Group uses the data and information that we hold in relation to you, in the following ways:

The key legal basis for the processing of your personal data and information is our legitimate business interest, described in more detail below.  Furthermore we may also, in certain circumstances, rely on a contractual or legal obligation and/or consent for specific uses of data and information.   Where we retain your data and information in fulfilment of a legal and/or regulatory obligation, in doing so, we will rely on legal obligation to hold such data and information.

4. Our legitimate business interests

The asset management division of the Arabesque Group provides a range of investment management services to a number of collective investment schemes and a number of managed accounts. In this capacity, the exchange of personal data and information between: us; you; the collective investment schemes and/or managed accounts (for which we act as investment manager); certain third parties (appointed to provide ancillary services directly related to the provision of our discretionary investment management activities); and global governmental and quasi-governmental agencies, is a fundamental and essential part of our business.  In order to support those collective investment schemes and managed accounts for which we act as investment manager, we maintain databases of personal data and information of investors or prospective investors in such collective investment schemes and managed accounts which contain both current and historical information of the kind described within section 2 above.  In order to maintain, expand and develop our business we must record the personal data and information of investors and prospective investors in the collective investment schemes that we manage.

The artificial intelligence division of the Arabesque Group offers and provides artificial intelligence products and services to a range of corporate clients.  In this capacity, the exchange of personal data and information between us, you, third party vendors, and other third parties (appointed to provide ancillary services directly relate to the provision of our artificial intelligence services) is a fundamental and essential part of our business.  In order to support our artificial intelligence business activities, we maintain databases of personal data and information relating to clients and prospective clients which contain both current and historical information of the kind described within section 2 above.  In order to maintain, expand and develop our business we must record the personal data and information of clients and prospective clients of the artificial intelligence products and services that we provide.

5. Disclosure of your information inside and outside of the EEA

The Arabesque Group may disclose information about you to our affiliates, and/or third parties. 

For the purposes of the Arabesque Group’s business activities this may include, but is not limited to: the administrator, the prime brokers and the custodians of the collective investment schemes and/or managed accounts that are managed by the Arabesque Group, third parties which facilitate the provision of our artificial intelligence products and services.  Moreover, your data and information will be used for our everyday business purposes, such as the provision of asset management activities; the maintenance of your account(s) or responding to court orders and legal investigations.  It may also be necessary, under anti-money laundering and other regulations and laws, to disclose information about you to regulatory authorities and other relevant governmental and quasi-governmental organisations.  We will also release information about you if you direct us to do so.

We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates.  You may prevent this type of sharing by contacting us as described in this privacy policy. We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes. If you are a new investor or client, we may share your information with affiliates in accordance with this privacy policy.  When you are no longer an investor or client, we may continue to share your information as described in this privacy policy.

We do not share your information with non-affiliates for them to market to you.

In addition to the above, we may also disclose your personal information to third parties in the following circumstances:

The lawful basis for the third-party processing will include:

6. Where we store and process your personal data and information

The data and information that the Arabesque Group collects from you may be transferred to, and/or stored at, a destination outside of the European Economic Area (“EEA”).  It may be transferred to third parties outside of the EEA to enable us to provide our discretionary investment management services and/or artificial intelligence products and services.  Your data and information may also be processed by staff operating outside of the EEA who work for the Arabesque Group  or for one of our suppliers.  This includes staff engaged in, amongst other things, the provision of discretionary investment management services, the provision of and/or artificial intelligence products and services.  By submitting your personal data and information, you agree to this transfer, storing and/or processing.  The Arabesque Group will take all reasonable steps to ensure that your data and information is treated securely and in accordance with this Policy.

7. Retention of your data and information

The Arabesque Group understands that is has a legal duty to retain accurate data and information and to only retain personal data and information for as long as it is required for the legitimate business interests, as outlined herein, and only where you are happy for us to do so. Accordingly, we maintain a data retention policy to ensure that we only retain data and information in accordance with this Policy.

8. Your rights

The GDPR provides you with the following rights:

9. Access to information

The Data Laws give you the right to access your data and information held by the Arabesque Group. Your right of access can be exercised in accordance with the Data Laws, as described herein. Subject access request should be submitted to [email protected].

10. Changes to our privacy policy

Any changes we make to our privacy policy will be posted on our website and, where appropriate, notified to you by email.  We recommend that you periodically review the Policy to ensure that you continue to be aware of your rights.

11. Contact details

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].

For the purposes of data protection legislation in force from time to time the data controller is Arabesque Holding Ltd and its affiliates within the Arabesque Group.