In this notice, “we”, “SPX” and “SPX Entities” refer collectively to SPX Gestão de Recursos Ltda., SPX Equities Gestão de Recursos Ltda. and SPX International Asset Management Ltd.
SPX is committed to protecting your privacy.
This privacy notice describes what personal information we collect about you, how we may collect, use and share your personal information, our legal bases for using your personal information, how long we keep your personal information, how we protect your personal information, the countries to which we may transfer your personal information, and your rights regarding your personal information.
Types of personal information we collect about you
The types of personal information we collect about you depends on your relationship with us. They include:
Your personal contact details such as name, title, postal addresses, email addresses and telephone numbers.
The company you work for and your position.
Identification and background information we may collect about you as part of our business acceptance procedures and recruitment procedures.
Financial information, such as your bank account details.
Technical information, such as information from your visits to our website or relating to the event invitations, updates, marketing materials and other communications we send to you electronically.
Your communication preferences regarding marketing materials.
Any other personal information you provide to us during your relationship with us, such as dietary requirements, any physical disability and your views and comments.
How we collect your personal information
The ways in which we collect personal information about you may include the following:
In the course of our business acceptance procedures and in providing information about investment services and products to investors and prospective investors.
Through your general use of our website. In particular, we collect personal information about you if you complete forms on our website or send emails to SPX personnel from our website.
Through your responses to our emails asking that you confirm and update information we maintain about you, or that you provide your consent for us to communicate with you.
Through information you may provide to representatives of SPX via post, telephone or electronic communications, or face-to-face at business meetings, conferences or similar events.
Through your application for a job at SPX.
How we use your personal information
We may use your personal information for the following purposes:
To manage, administer and improve our provision of information about investment services and products to investors and prospective investors.
To provide information requested by you.
To provide, administer, monitor the use of, and improve our website.
To promote our investment services and products, including by sending to you personalised event invitations, updates and other marketing materials.
To follow up with you on a job application.
Our legal bases for using your personal information
We use your personal information on the following bases:
For our legitimate interests, as summarised above under the heading ‘How we use your personal information’.
To comply with a legal obligation.
To perform a contract with you, such as engaging with you as a prospective or former employee.
How we share your personal information
We may share your personal information with others in the following circumstances:
SPX Entities in order to provide information about investment services and products to investors and prospective investors and in accordance with our business administrative practices.
Our third party service providers in order to provide us with services, including our professional advisers such as our auditors, our external counsel, our information technology service providers, and third parties to whom we outsource support services such as translation and photocopying.
Fund administrators or registrars/transfer agents, in connection with your investment or proposed investment in a relevant investment product.
Government or regulatory authorities, courts, tribunals or other third parties if we consider it necessary or appropriate under applicable laws.
Any new SPX affiliate or other third party if we decide to re-organize or transfer all or any part of our business.
We do not sell or otherwise disclose to third parties your personal information without your consent.
How long we keep your personal information
We retain your personal information in accordance with our global retention guidelines. Our retention periods are based on the requirements of applicable data protection laws, other legal and regulatory requirements to retain information for a minimum period and limitation periods for taking legal action.
How we protect your personal information
We have in place technical and organisational measures to protect the personal information we collect about you from unauthorised, improper or unlawful access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
Countries to which we transfer your personal information
We may need to transfer your personal information to locations outside the jurisdiction in which you provide it, or from where you are viewing our website, in order to use it on the bases set out above. If you are an EU citizen or reside in the EU we will transfer your personal information outside the EU in accordance with EU data protection laws to ensure that it remains protected and secure.
Your rights regarding your personal information
If you reside in the EU you may have the following rights under EU data protection laws:
To request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
To correct any incomplete or inaccurate personal information that we hold about you.
To request us to delete or remove from our systems your personal information where there is no legal basis for us continuing to process it.
To request us to suspend processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it.
To request the transfer of your personal information to a third party.
To withdraw any consent that you have provided to us for processing your personal information.
To make a complaint to a local supervisory authority about how we are processing your personal information.
If you reside in a jurisdiction outside the EU, you may also have rights under applicable laws in connection with your personal information that we collect, hold and process.
It is important that the personal information we hold about you is accurate and up to date. Please advise us of any changes to your personal information by contacting us at email@example.com.
SPX operates through a number of different legal entities. For the purposes of applicable EU data protection laws, the data controller of your personal information is SPX International Asset Management Ltd.
Updates to this notice
We may change this privacy notice from time to time by updating this page. Please check this notice regularly to ensure that you are familiar with its content.
If you have any questions about this privacy notice or you would like to exercise any of your rights relating to your personal information, please contact us at firstname.lastname@example.org.
In this notice, “SPX” and “SPX Entities” refer collectively to SPX Gestão de Recursos Ltda., SPX Equities Gestão de Recursos Ltda. and SPX International Asset Management Ltd.
Last updated 25 June 2018