Privacy Policy / Notice of New Ocean Capital Management, Limited

Privacy and Cookies

New Ocean Capital Management (NOCM or we or us) are committed to compliance with data protection laws. This policy (Privacy Policy) sets out NOCM's personal information collection and sharing practices in relation to the personal information that we collect. This Policy also covers any personal information collected through a users' use of NOCM website (the Site).

This website may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability of their policies or processing of your personal information.

This Privacy Policy is intended to explain our privacy practices and covers the following areas:

  1. Personal information about you we may hold or collect
  2. How we may use your personal information
  3. Who we may disclose your personal information to
  4. How we protect your personal information
  5. Contacting us & your rights to access and update your personal information
  6. Our Cookies Policy
  7. Changes to this Privacy Policy and the Cookies Policy

1     Information we may collect about you

1.1    We may collect and process the following personal information about you:

  1. Information that you provide by filling in forms or upload to us, including Social Security number, investment experience, Income, Account transactions, and Assets
  2. Information including your name, address, contact details, details relating to a proposal or a claim (which depending on the nature of the claim may include medical reports and reports of criminal convictions or crime) that you, your employer or organization whom we insure or reinsure or a third party claimant provide to us in relation to the administration of an insurance policy that we insure or re-insure.
  3. Information relating to any criminal or fraudulent activities provided to us by you or third parties (such as law enforcement, anti-fraud agencies or other insurers).
  4. If you contact us, we may keep a record of that correspondence or details of any conversation we may have with you.
  5. Details of your visits to our website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

2     Uses made of your personal information

2.1    We may use your personal information in the following ways:

  1. to decide whether to enter into any proposed transaction with you or your employer or organization, including in certain circumstances, disclosing such information to third party anti-fraud and money laundering agencies for the purposes of detecting and preventing fraud and crime (as further set out in paragraph 3 below);
  2. to identify you and to carry out any identity checks as may be required by applicable law and regulation and best practice at any given time;
  3. to analyze it in order to understand the service we provide and in order to improve our business;
  4. to monitor calls and transactions to ensure service quality, compliance with procedures and to combat fraud.

2.2    We may also use your information for marketing our own and selected third parties' products and services to you by post, email, SMS, phone and fax and, where required by law, we will ask you for your consent at the time we collect your data to conduct any of these types of marketing.

3     Disclosures to third parties

3.1    All financial companies need to share customers’ personal information to run their everyday business. Below, we list the reasons New Ocean chooses to share their customers’ personal information, and whether you can limit this sharing.

3.2    We may also permit selected third parties and agents to access your personal information, for the purposes set out in paragraph 2 above. Specific examples are set out in paragraphs 3.3 to 3.6 below. All such exchanges will be made in accordance with applicable laws.

3.3    If false or inaccurate information is provided and/or fraud is identified or suspected, details may be passed to fraud prevention and anti-money laundering agencies, law enforcement agencies or other insurers and may be recorded by us or by them.

3.4    We, and other organizations that may access and use information recorded by fraud prevention agencies, may do so from other countries including outside the EEA.

3.5    We can provide the names and addresses of the agencies we may use to counter fraud or money laundering upon request.

3.6    We may disclose your personal information to third parties, such as to process and service your transactions, report on transactions, maintain your account(s), respond to court orders, regulatory and legal investigations, or report to credit bureaus, in connection with enquiries, proceedings or investigations by such parties anywhere in the world or in order to enable NOCM to comply with its regulatory requirements or dialogue with its regulators as applicable.

3.7    In the event that NOCM is (i) subject to negotiations for the sale of its business or (ii) is sold to a third party or undergoes a re-organization, you agree that any of your personal information which it holds may be disclosed to such party (or its advisors) as part of any due diligence process or transferred to that re-organized entity or third party and used for the same purposes or for the purpose of analyzing any proposed sale or re-organization.

4     Transmission, storage and security of your personal information

4.1    No data transmission over the Internet or website can be guaranteed to be secure from intrusion. To protect your personal information from unauthorized access and use, we use security measures that include computer safeguards and secured files and facilities, as well as commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with applicable data protection legislative requirements.

We train our employees in the proper handling of personal information. We require companies that help provide our services to you to protect the confidentiality of personal information they receive.

4.2    All information within our control is stored on our secure servers (or secure hard copies) and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site or any other portal we operate, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

5     Your rights & contacting us

5.1    Applicable data protection laws may give you the right to access certain personal information held about you. We will comply with our obligations to provide you with access to your personal information and to rectify any inaccuracies we are informed of in accordance with applicable data protection laws. Where permitted to do so, complying with your request may be subject to a fee to meet our associated costs.

5.2    We will use reasonable endeavors to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by updating your details by contacting us at the address below.

5.3    We can be contacted in relation to your rights or any questions you may have in respect of this Privacy Policy or our processing of your personal information by the following means:

Post: Peter Gracey
New Ocean Capital Management
3 Bermudiana Road
Hamilton, HM08

Tel: +1 441 294-7530
Fax: +1 441 294-5731

6     Our Cookies Policy

6.1    When you visit this website, we may collect usage information to help us understand how our website is navigated and used. This data does not include any personal information about you and is used only to measure and improve the effectiveness of our website.

6.2    This website uses "cookies" to enhance your viewing experience. A cookie is a tiny element of data that is sent to your browser to be stored on your hard drive so that we can recognize you when you return. You may set your browser to notify you when you receive a cookie or refuse cookies from all websites, if you wish. Please note, however, that if you reject cookies it is possible that some web pages may not properly load or load at all, and your access to certain information might be denied or you might have to enter information about you more than once.

6.3    We use session cookies, persistent cookies and Google Analytics.

6.4    Session cookies: Session cookies allow this website to link the various actions of a user during a browser session, including which pages the user visited before visiting this one. Session cookies expire when the browser session ends.

6.5    Persistent cookies: Persistent cookies are stored on a user's device in between browser sessions, storing information about the preferences or actions of the user across a site.

6.6    Google Analytics: Google Analytics is a popular web analytics service that uses cookies to count the number of people that visit and help analyze how they use it (e.g., we can determine which pages on our site are visited most frequently). The information generated by the cookies (including your IP address) is transmitted to and stored by Google on its servers. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Google uses this information to evaluate the way visitors use our website, compiling reports to us on website activity and providing other services relating to website activity and internet usage. The information also helps us improve this website. Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google's behalf. Google undertakes not to associate your IP address with any other data held by Google.

6.7    In addition to the above cookies used by our website, cookies and other similar technologies may be deployed on websites hosted by third parties which this website provides links e.g. for published webcasts or written material. We cannot be held responsible for the use by those sites of cookies or similar technology.

6.8    We do not add your name to mailing lists unless you specifically request that we do so. We do not share, sell, lease or rent our mailing or customer lists to third parties. We may, however, use third parties to help us administer email alerts. If personally identifiable information (e.g., name, address, email address or telephone number) is provided to any of these third parties, we will require that such information be maintained by them in strictest confidence. We also continually assess new technology for protecting customer information.

6.9    We take the security of your personal information seriously and use secure servers and various other technological means to protect it.

6.10    NOCM respects your right to verify, amend and challenge the veracity of your personal data. If you have any concerns about this privacy statement or wish to review your personal data, please contact us.

7     Changes to our Privacy Policy and/or Cookies Policy

7.1    We may change the content of our website or services without notice, and consequently our Privacy Policy and/or Cookies Policy may change at any time in the future. We therefore encourage you to review it from time-to-time to stay informed of how we are using personal information.

8     Additional Information

8.1    Information for Vermont and California Customers

In response to a Vermont regulation, if we disclose personal information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transactions or experiences with you.

In response to a California law, we automatically treat accounts with California billing addresses as if you do not want to disclose personal information about you to nonaffiliated third parties except as permitted by the applicable California law. We will also limit the sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.

New Ocean reserves the right to amend the terms of this privacy notice from time to time. We will provide to Clients a copy of our Privacy Policy when revised and annually in writing, provided the Client maintains an ongoing relationship with us.

You do not need to do anything in response to this notice. This notice is merely to inform you about our privacy policies and practices.