How your information will be used
The Company needs to keep and process information about you for our normal business
As a business entity regulated by the Malta Financial Services Authority under part B III of the
Investment Service Rules for Investment Service Providers, we may on occasion need to
process your data to comply with the regulatory requirements or fulfil the obligations of a
contract we have entered with you.
Much of the information we hold will have been provided by you, but from time to time, some
may come from other sources. If we obtain data about you from other sources, we will only
collect relevant documents required to carry out any necessary function and this may consist
of various due diligence documents to prove your name, residential address, contact details
(email, phone number) and any personal data you have made public.
The type of information we hold includes your contact details, correspondence details with or
about you and other personal details as required by regulatory requirements such as a valid
passport or driver’s licence. We do not process special category data as defined under the
Law. We use automated decision making (including profiling) in circumstances.
Recipients of Your data
Your data will be received by the employees of Scotstone Fund Managers Limited.
Retaining Your Data
Your status with us as a client will determine how long your data will be stored with us. Your
personal data will be stored both in hard copy files and electronically either for the duration
of your client relationship or for a period of five years after your relationship with us has
ended, to fulfil our regulatory requirements. For individuals who do not establish a business
relationship with us, we will destroy your data as soon as practicable.
We take the security of your data seriously. We have internal policies and controls in place
to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not
accessed except by our employees in the proper performance of their duties.
In limited and necessary circumstances, your information may be transferred outside of the
European Union, or countries not appearing on the Adequacy list, or to an international
organisation, to comply with our legal or contractual requirements. We have in place
safeguards to ensure the security of your data, which consist of locked and secure storage
facilities for any data in hard copies and password protected security procedures for any soft
Changes to this Privacy Notice
In the future, if we intend to process your personal data for a purpose other than that which it
was collected, we will provide you with information on that purpose and any other relevant
Under GDPR you have certain rights with regards to your personal data. You have the right
to request from us access to and rectification of your personal data. If you would like access
to the data we hold, we must receive a request in writing in order to fulfil the request. This
request should be sent to us by email at (Subject line: Subject Access Request,
email@example.com) or by regular post (Scotstone Fund Managers Limited re: Subject
Access Request, 68, Penthouse 10, Northfields, Independence Avenue, Mosta, MST 9026,
In certain circumstances, you have the right to request erasure of your personal data, the
right to restrict processing, object to processing, and the right to data portability.
If you have provided consent for the processing of your data, you have the right to withdraw
that consent at any time which will not affect the lawfulness of the processing before your
consent was withdrawn.
You have the right to file a complaint with the Data Commissioner’s Office in Malta if you
believe that we have not complied with the requirements of GDPR with regard to your
Identity and contact details of controller and Responsible Officer
Scotstone Fund Managers Limited is the controller and processor of data for the purposes of
If you have any concerns as to how your data is processed, you may contact
Responsible Officer at firstname.lastname@example.org
Mr. Julian Borg Gauci, Managing Director at email@example.com
Or you can write to these individuals using the address of 68, Penthouse 10, Northfields,
Independence Avenue, Mosta, MST 9026, Malta