Internet Privacy Policy


Cherry Bay Capital MFO S.A.M. (CBC) takes your privacy and the protection of your personal information very seriously. This Privacy Policy (“Policy”) is issued on behalf of CBC so any reference to "we", "us" or "our" in this Policy is a direct reference to the relevant member of CBC responsible for processing your data.

This Policy explains what information we gather about you, how we use that information, what we use that information for and who we may share that information with. It also sets out your rights in relation to any information that we may hold about you.

It is important that you read this Policy, together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are processing your data. This Policy supplements other notices and privacy policies and is not intended to override them.

1.     Who we are

CBC is the controller and responsible for

2.     Third party links

The CBC may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Any third party links referred to on CBC’s site is not managed by CBC and, when you follow links to third party sites, this Policy no longer applies and you should ensure that you review and understand the privacy policy of that site before use.

3.     The Information we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We use different methods to collect data from and about you including through direct interactions. For example, you may provide us with your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.

You can browse CBC’s site without entering any personal information. However, if you choose to request information about CBC or any of the products or services we offer, you will be asked to provide us with personal information through a request form. Information we collect may include: your name, email address, telephone number and, in the case of determining your eligibility to receive promotional information, confirmation of your status as an authorised or exempt person under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005.

We endeavour to only collect the minimum amount of information necessary to fulfil your request. However, some of the information that we ask you to provide is mandatory and if you do not provide it, we may not be able to grant you access to certain areas of CBC’s site or provide you with certain materials.

4.     Cookies and other information-gathering technologies

CBC’s site uses cookies. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. These cookies allow us to distinguish you from other users of CBC’s site which helps us to provide you with an enhanced user experience when you browse CBC’s site and allows us to continuously improve CBC’s site. You can set your browser to refuse all or some browser cookies, or to alert you when CBC’s site sets or accesses cookies. If you disable or refuse cookies, please note that some parts of CBC’s site may become inaccessible or not function properly.

5.     How we will use the information about you

When you provide personal information to us, we may use it for any of the purposes described in this Policy or as stated at the point of collection, including, but not limited to:

·       where it is necessary for our/your legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

·       to administer and manage CBC’s site, including to confirm and authenticate your identity and prevent unauthorised access to some areas of CBC’s site;

·       to continue to improve the user experience on CBC’s site;

·       to conduct benchmarking and data analytics, for example, determining the usage of CBC’s site and sorting and analysing your data for this purpose;

·       to conduct quality and risk management assessments including the use of data analytics;

·       to monitor compliance with CBC’s site’ terms of use policy;

·       where we need to comply with a legal/regulatory obligation; and/or

·       any other purposes for which you have provided your personal information to CBC (we will notify you if this is the case at the time).

·       We only collect personal information in accordance with applicable law and this Policy and we do not, collect your personal information for sale to third parties or for consumer marketing purposes.

6.     Security of your personal information

We adhere to highly stringent security measures to protect your personal information from misuse, loss or alteration. Only persons who have agreed to protect and keep confidential your personal information in line with this Policy and our practices relating to data protection and confidentiality have access to your personal information you provide to us.

We take all appropriate measures to protect personal information; however, as any transfer of data over the internet is not completely secure we cannot guarantee absolutely the security of data transmitted to us over the internet. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7.     Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, governance or reporting requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, having regard to the applicable legal, regulatory, tax, accounting, governance or other requirements.

In some circumstances you can ask us to delete your data (see section 12 (Your legal rights) below).

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8.     Access to your information and updating and correcting your information

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to If your request is clearly unfounded, repetitive or excessive we could refuse to comply with your request.

We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address or name, please let us know the correct details by sending us an email or writing a letter to us at the addresses provided above. You may ask us, or we may ask you, to correct information you or we think is inaccurate or incomplete and you may also ask us to remove information which is inaccurate.

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond 

We aim to respond to all legitimate requests within three months. If your request is particularly complex or you have made a number of requests it may take us longer to respond. In this case, we will notify you and keep you updated.

9.     Transfer of personal information

International transfer

When necessary, your personal information may be transferred to and stored outside of the Principality of Monaco. This includes countries outside of the European Economic Area (“EEA”) which may not have local laws which specifically provide protection for personal information. Where your personal information is collected within the EEA and transferred out of the EEA, it will only be transferred where: the recipient is located in a country which provides an adequate level of protection; and/or, an agreement is in place which includes contractual clauses that are of a standard approved by the European Commission for the purposes of transferring personal information outside of the EEA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Third party affiliates

In accordance with this Policy, where it is necessary to do so for the purposes set out in this Policy, we may transfer or disclose the personal data we collect to members of CBC, their subsidiaries and affiliates, subcontractors and to their third party contractors and their subsidiaries and affiliates. This may be necessary for administrative, security, storage and management purposes and to process the information for the reason it has been submitted.

10.     Applicable law

The terms of this Policy, its subject matter and its formation are governed by Monegasque law and where not applicable by European law.

11.     Changes to this Policy

We keep this Policy under regular review. Every time you wish to use CBC’s site, please check these terms to ensure you understand the terms that apply at that time.

12.     Your legal rights 

You may find your rights at the following European Commission’s page:

13.     Contact us

We welcome your views about CBC’s site and this Policy. If you would like to contact us with any queries or comments please send an email to