Privacy Policy

Data Controller

Your privacy is very important to us. With this Privacy Notice, Optimum Complexity Ltd (“Optimum”) explains your privacy rights and how we gather, use and share information about you. This Privacy Notice sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data that we hold on individuals, in relation to services we provide. As a delegated portfolio manager, Optimum is a controller of personal data. This Privacy Notice is being provided in accordance with the requirements of data privacy laws, including GDPR, the U.S. Gramm-Leach-Bliley Act of 1999, as amended, and any other law relating to privacy or the processing of personal data and any statutory instrument, order, rule or regulation implemented thereunder, each as applicable to Optimum (collectively, “Data Protection Law”). References to “you” in this Privacy Notice mean any individual with whom we have entered into terms of business, any Director of a Fund we manage or any Investor in a Fund we manage, who is a legal person (each such individual, a “data subject”).

The categories of personal information that we may collect and use

The categories of personal data we may hold include names, residential addresses or other contact details, signature, nationality, place of birth, tax identification number, date of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds details or other sensitive information, such as certain special categories of data contained in the relevant materials or documents.

How we collect personal data

We may collect personal data about you from third parties to whom you have provided this information. We may also obtain information from publicly accessible databases or registers, or other publicly accessible sources, such as the Internet or from recording and monitoring of telephone conversations and electronic communications with you, as detailed below.

The lawful basis on which we process this information

We may process your personal data for the purposes of administering the relationship between you and us, that is, in fulfilling our contractual duties as delegated portfolio manager with respect to communications and reporting, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities with competent jurisdiction over our business). Your personal data will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so.

Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in your subscription in the applicable product we manage being rejected or compulsorily redeemed or withdrawn, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

Who we share this information with and why

We may disclose information about you to our affiliates or third parties, including the executing brokers and trading counterparties for our everyday business purposes, such as to facilitate transactions or respond to court orders and legal investigations. It may also be necessary, under anti-money laundering and similar laws, to disclose information. We will also release information about you if you direct us to do so. We do not share your information with non-affiliates for them to market to you.

Monitoring of communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.

Retention periods and security measures

We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Law. Personal data will be retained for the duration of any contractual relationship, direct or indirect, where applicable, and for a minimum period of five to seven years after the termination of such relationship. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

To protect your personal information from unauthorized access and use, we apply organisational and technical security measures in accordance with Data Protection Law. These measures include computer safeguards and secured files and buildings. We will notify you of any material personal data breaches affecting you in accordance with the requirements of Data Protection Law.

International transfers

Because of the international nature of a portfolio management business, personal data may be transferred to countries outside the EEA (“Third Countries”), such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the Data Protection Law in the EEA. In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of the Data Protection Law, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries.

Your rights under Data Protection Law

Under data protection legislation, you have the right to request access to information about you that we hold. To make a request for your personal information or if you have any questions about this Privacy Notice, contact Daniele Cosulich at If you remain dissatisfied, you have the right to make a complaint to The Information Commissioners Office in the UK (

Our website

When you visit our website, we may use traffic log cookies to identify which pages on our website are being used. This helps us analyse data about web page traffic and improve our website by tailoring it to the needs of users. We only use this information for statistical analysis purposes. A cookie is a small file which asks permission to be placed on your computer. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular website. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Overall, cookies help us provide a better website by enabling us to monitor which pages users find useful and which they don’t. A cookie does not give us access to a user’s computer or any information about them, other than the data they choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, this may prevent you from taking full advantage of the Website. For further details on cookies and how to manage them, we recommend that you visit the All About Cookies website.

Who to contact about this Privacy Notice

For any questions about this Privacy Notice or requests with regards to personal data we hold, you can contact us by emailing or by writing to us at One Mayfair Place, London, W1J 8AJ.