Privacy Notice

This Privacy Notice (the “Notice”) sets out the basis on which Africa Global Trade Finance Ltd and associated companies; Africa Global Trade Finance Mauritius and Africa Global Trade Finance SA (Pty) (collectively, “AGTF”) use your personal information. For the purposes of the United Kingdom GDPR Data Protection Act 2018 & the South Africa Protection of Personal Information Act, No. 4 of 2013 (POPIA) (the “Act”), the data controller is Africa Global Trade Finance Ltd, of 85 Gresham St, London, EC2V 7NQ, United Kingdom.

AGTF is committed to protecting your personal information and respecting your privacy. AGTF will use your personal information fairly and lawfully.

If you are viewing this Notice on www.agtf.group & www.agtf.co.uk (the “Site”), you accept that your use of the Site indicates your consent to the practices described in this Notice.

We are registered with the Information Commissioner’s Office (ICO) under registration number: 00018828364.

Personal Information

Whose personal information is collected?

AGTF collects and uses information about the following groups of individuals:

Clients, investors and beneficiaries (current, prospective and former) and any of their directors, officers, employees, partners, shareholders or agents;
Suppliers and service providers;
Professional advisers and consultants;
Individuals who contact AGTF by email, phone or otherwise;
Employees, contractors and other members of staff (current, prospective and former); and
Directors, officers and senior management of listed and private companies in which AGTF may invest.

What types of personal information is collected?

AGTF may collect and use personal information that is:

Directly provided by you;
Related to services provided to you by AGTF;
Received from your representatives or advisers;
Received from third parties, including administrators of products and services advised by AGTF;
Sourced from public sources.

The Site uses cookies to distinguish you from other Site users and help ensure that the Site is operating smoothly.

Purpose for collecting the personal information

AGTF may use the information held about you to:

Provide you with information about AGTF’s products, services, research or events;
Assess your suitability for products or services;
Process your investment in AGTF sponsored funds or investment vehicles;
Fulfil any contract between you and AGTF;
Fulfil any legal, regulatory or self-regulatory requirement that applies to AGTF and/or any member of the AGTF group of companies;
Process your job application and assess your suitability for a vacancy with AGTF;
Ensure that the Site is effectively presented for you and for your computer or device;
Administer the Site;
Respond to any enquiry or complaint raised by you; and
With respect to information about directors, officers and senior management of listed or private companies in which AGTF may invest, finance or advise, for research and investment purposes.

AGTF may also combine any information that you provide with the information received from other sources. The combined information may be used for the purposes set out above.

How We Protect Your Personal Data

AGTF implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure.

AGTF maintains technical and organisational security measures to protect personal data. The company has achieved Cyber Essentials certification, demonstrating its commitment to recognised cybersecurity standards.

While no method of transmission over the internet or electronic storage is completely secure, we continually review and enhance our security controls to safeguard the information entrusted to us.

Lawful basis for processing

AGTF processes your personal data on the following legal bases:

Contractual necessity (Article 6(1)(b)) - where processing is necessary to perform a contract with you or to take steps at your request prior to entering into a contract.
Legal obligation (Article 6(1)(c)) - where processing is necessary to comply with our legal and regulatory obligations, including anti-money laundering and KYC requirements under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017.
Legitimate interests (Article 6(1)(f)) - where processing is necessary for our legitimate business interests, including managing our business relationships, assessing risk, and facilitating trade finance transactions.
Consent (Article 6(1)(a)) - where you have provided explicit consent, including via your signed KYC form. You may withdraw consent at any time by contacting compliance@agtf.group, though this will not affect any processing carried out before withdrawal.

How long we keep your information

AGTF retains personal data for as long as necessary to fulfil the purposes for which it was collected. As a minimum, client KYC and due diligence records are retained for five years following the end of the business relationship, in accordance with our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. In certain circumstances, data may be retained for longer where required by law or for the establishment, exercise or defence of legal claims.

Third Parties

AGTF may share your personal information with any member of AGTF for the purposes set out above.

AGTF may share your personal information with the selected third parties including:

Business partners, suppliers and sub-contractors for the performance of any contract AGTF enters into with them or you;
Your current, prospective and former employers;
Marketing providers that assist with the delivery of information to you;
Analytics providers that assist in the improvement of the business or Site; and
Administrators and directors of AGTF sponsored funds, businesses or investment vehicles in connection with your subscription or investment in such funds, businesses or investment vehicles.
Funding partners, risk participation counterparties, banks and other regulated financial institutions where necessary to facilitate and administer trade finance facilities

AGTF may also share your personal information with third parties in the following circumstances:

If AGTF sells or buys any business or assets, it may be necessary to share your personal information with the prospective seller or buyer;
If AGTF is acquired by a third party, the personal information held by AGTF will be one of the transferred assets; or
If there is a duty to share your personal information in order to fulfil any legal, regulatory or self-regulatory requirement that applies to AGTF and/or any member of the AGTF group of companies.

Security of your information

AGTF is committed to protecting information that you provide. Physical, electronic and procedural safeguards are used to protect your information against unauthorised access, disclosure or loss. Authorised access to personal information is limited to only those employees, contractors and agents with a need to know, and is subject to strict confidentiality obligations.

Storage of your information

The information that AGTF collects from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). It may also be processed by AGTF or AGTF’s suppliers operating outside of the EEA for the purposes set out above. By submitting your personal information to AGTF, you agree to this transfer, storing or processing. AGTF will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with the Notice.

Your rights

The Act gives you the right to access information held about you and to request that such information is not used for any particular purpose (for example to provide you with information about AGTF’s products, services, research or events). You can exercise these rights by writing to:

by mail:

Africa Global Trade Finance Ltd
85 Gresham Street
London
EC2V 7NQ
United Kingdom

or emailing: compliance@agtf.group

Where we rely on your consent as the lawful basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out prior to withdrawal. To withdraw consent please contact us at compliance@agtf.group.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your personal data has not been handled in accordance with applicable data protection law. The ICO can be contacted at www.ico.org.uk or by calling 0303 123 1113.

Changes to this notice

Any changes AGTF may make to this Notice will be posted on the Site. Please check back frequently to see any updates or changes to this Notice.