Privacy Policy

Apex Group Ltd. is comprised of various entities across multiple jurisdictions (collectively, the “Apex Group” or “Apex”). Emerging Asset Management Ltd. is a part of the Apex Group. This Privacy Policy applies to the use of Apex Group website’s (as listed in the website section below) and to the Apex Group’s use of data / information gathered. If you would like to request an organisational chart for the Apex Group please contact enquiries@apex.bm.

The Apex Group’s fundamental goal is to provide asset managers around the world with comprehensive fund administration and middle office solutions. Our products and services deliver cross-jurisdictional reporting capabilities, fund administration services, middle office solutions and more to enable your fund to focus on what matters, performance. As we build on the Apex suite of services, we are committed to the principles of respecting your privacy, keeping your data safe and keeping the decision as to how your information is used and shared in your hands.

Our privacy pledge:

  • Apex will only collect data that is of legitimate interest, useful and necessary for improving its products, services and your experience.
  • Apex will maintain fairness and transparency at all times with regards to how we collect and process data at all times.
  • Apex will never sell your data and will only share your personal data when given your explicit consent to do so for a specific reason.
  • Apex will never make decisions based solely on automated processing or profiling of dat
  • Apex will always take the security of your data seriously.

To learn more about the data collected by Apex, please read our full Privacy Policy below.

Subject to the relevant local laws, Apex may process certain information about you if this information is of Legitimate Interest. This data may include what is known as Personally Identifiable Information (PII). PII includes data that could personally identify you as a natural person such as your name, email, postal address or data that could reasonably be linked back to you.

Apex processes your personal information in line with its Privacy Policy and T&C’s to provide you with the information that is of most interest to you, and deliver the services you have requested.

Apex does not carry out automated profiling and will not make any decisions based on the automated processing of data.

Apex does not seek to collect special categories of personal data (“sensitive data”), including but not limited to data revealing racial, or ethnic origin, political opinions, gender, religious or philosophical beliefs, health, genetic and biometric data, or trade union memberships, through this site. Please note that, by freely providing Apex with an unsolicited sensitive data, subject to the relevant laws, you are consenting Apex to use the said data in conformity with this Privacy Policy.
Apex understands the importance of protecting children’s privacy. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.

The Apex Group maintains three websites; our main Site (www.apexfundservices.com), a portal for clients using the Apex247 product (https://www.apexfunds247.com ), and a website for our emerging manager solutions business (www.eam.bm), (referred to as “Site(s)”).

We collect some relevant data from anyone who visits our Site(s). When you enter an Apex Site(s) we collect industry standard log data that records information about your visit, such as your browser type, the URL of the page that referred you, the different pages you visited and time spent on those pages. Apex uses Google Analytics to gather this data and we use this type of information to ensure our Site is working properly and make improvements; for example, we may expand upon the information on the most frequently visited pages. This data may be shared across jurisdictions with multiple entities within the Apex Group in accordance with local laws. We also collect data for cookies. For more details on what cookies are and how they are used, please ready our full Cookie Policy below:

This Cookie Policy is part of our Privacy Policy. Apex uses cookies on its websites to ensure that you receive the best user experience possible when browsing our sites.

What are Cookies?

Cookies are text files that are sent by servers to web browsers and stored on your computer. The cookies tell us which parts of the Apex Site(s) you have visited so that we can ensure we provide you with information that you are interested in and make any future visits to our website simple and easy for you. The information and data collected by Apex cookies will be held for two years.

Social Buttons:

Social media tools, like widgets and plug-ins, are sometimes used so that you can share information from Apex on other sites such as Twitter (found on our Blog pages). These interactive mini-programs collect your IP address, record the pages you visit on our site, and set cookies that will enable the widget to function properly. Your interactions with these widgets are governed by the privacy policy of the company providing them, not by Apex’s Privacy Policy. We may also use Twitter, Facebook and LinkedIn pixel tags to help us understand how effective our marketing is on those sites.

Browser control:

You can decline the use of cookies at any time by modifying your browser settings. By deleting or declining cookies, you may not be able to use some interactive features or access certain areas of the site that depend on cookies. If you do wish to decline the use of cookies please refer to the instructions for your file management software.

Most browsers allow you to see what cookies you have and delete them on either an individual basis, or block them. You can block cookies for specific websites or for all websites, depending on your preferences. To make it easier for you we have provided some examples of how to change your cookie settings here: Internet Explorer 5 | Google Chrome | Cookie Central FAQ

Managing Analytics Cookies:

As aforementioned, Apex uses Google Analytics. You can opt-out of having your anonymised browsing activity within websites tracked by Google Analytics cookies by clicking on the following link: Google Analytics Privacy

If you are subscribed to one of Apex’s marketing lists we may occasionally send you relevant updates. When you receive marketing emails Apex, we may use web beacons, customised links, or similar technologies to determine whether the e-mail has been opened and on which links you click, to provide you more focused e-mail communications or other information in the future.

You can stop the delivery of marketing emails from Apex at any time by Unsubscribing/Opting Out. We include a link at the bottom of every marketing email which you can utilise to update your preferences by selecting and deselecting lists based on your personal interests, or you can unsubscribe from ALL marketing communications if you so wish. Alternatively you can make a direct request to unsubscribe by emailing the following address: enquiries@apex.bm

Please note, that by unsubscribing from ALL marketing emails Apex will proceed to remove your contact details from all mailing lists and place you on a “no mail” list. Alternatively you can update your subscription preferences to unsubscribe from certain mailing lists and remain on others that you feel are more relevant. If you wish to amend or update your subscription preferences at any time please use the link at the bottom of any Apex marketing email or contact enquiries@apex.bm

Apex Privacy Policy does not apply to third parties websites which Apex website link to or which advertise on Apex website. These third party websites will have their own cookies and operate their own Privacy Policy which we encourage you to read before disclosing any of your personal data.

Apex may share your personal data with:

  • Apex Group, which includes any Apex subsidiaries and affiliates part of the Apex network of companies;
  • Apex services providers (third parties) who process information on Apex behalf, including providers of information technology, identity management, website hosting and management, data analysis, data back-up, security and storage services; or,
  • Other third parties where you have given your consent to the disclosure (either to Apex or the third party).

Apex Group operates in compliance with the relevant data protection laws and regulations. Apex services providers are legally obliged to follow Apex express instructions in respect of the use of your personal information and they must comply with appropriate security measures to protect your personal information.

In case Apex transfers your personal information to countries that may not have the same level of data protection provided in your home country, Apex will put a contract or other legal instruments available in place to ensure that your personal information is protected in accordance with the relevant laws and regulations.

Apex is committed to protecting the security of your personal information. Apex has implemented generally accepted standards of technology and operational security in order to protect personal data and information from loss, misuse, alteration or destruction. Apex ensures that all appropriate confidentiality obligations and technical and organisational security measure are in place to prevent any unauthorised or unlawful disclosure or processing of such information and data and the accidental loss or destruction of or damage to such information and data.

Only authorised Apex employees and services providers are allowed to access the data and they are legally obliged to ensure confidentiality of this information.

The data you submit to Apex will only be retained for as long as is required for the purposes for which it was collected or as required by the relevant laws.

Please note that subject to the relevant laws, when the data is no longer necessary to the purpose for which it was collected; Apex will proceed to erase all your personal data held in its systems without undue delay.

Should you wish to unsubscribe from mailing lists or any other registrations, Apex will provide instructions on the appropriate webpage or in communications sent to you, or you may contact Apex by email to enquires@apex.bm Please note that subject to the relevant laws, by unsubscribing Apex will proceed remove your contact details from all mailing lists as request and place you on a “no mail” list. You will receive no further marketing communications from Apex if you unsubscribe.

Subject to the relevant laws, you have the right to know what personal information we hold about you. If you would like a copy of the information you are entitled, you may contact Apex by email to enquiries@apex.bm . Please note that for the execution of this request, you must provide with a clear identification of yourself and the information you require.

Also, you have the right to request rectification of inaccurate personal data concerning to you. If you would like to exercise this right, you may provide Apex with a supplementary statement by email to enquiries@apex.bm . Please note Apex does not assume responsibility for verifying the ongoing accuracy of the personal information provided.

If at any point you wish to withdraw your consent for Apex holding your data you can contact us and request this via the following email address: enquiries@apex.bm

Please note, if you wish to exercise your “right to be forgotten” we recommend that you authorise Apex to retain your information on its “no mail” list. If you are totally removed from the system you could be legitimately and legally added back into the system at some point in the future and therefore could receive future communications from Apex. If your data is kept on the “no mail” list you will never receive marketing communications from Apex again, unless you change your preferences and explicitly request it.

Apex may disclose your personal information to law enforcement, regulatory, or other government agencies or to other third parties are required by, and in accordance with, applicable laws or regulations.

Apex may update the terms of this Privacy Policy, within reason, in line with new regulation or directives at any time and without notice. When we make changes to this Statement, we will amend the revision date at the top of this page, and such modified or amended Privacy Statement shall be effective as to you and your information as of that revision date. We encourage you to periodically review this Privacy Statement to be informed about how we are protecting your information.

If you have any questions about this Privacy Policy, you may contact us via enquiries@apex.bm or via regular mail to:

Emerging Asset Management Ltd.
58 Par-la-Ville Road
4th Floor, Vallis Building
Hamilton, HM11

Last updated: 17 September 2019