Privacy notice

This Privacy Notice is intended to inform and assure you about how we collect, use, store, disclose, update, safeguard, destroy, or otherwise process your personal data, in accordance with Law No. 22/11 of 17 June – the Personal Data Protection Law (“PDPL”).

Where the prospective investor, client, or similar contact is not a natural person, we ask that this Privacy Notice be provided to the relevant individuals (such as directors, officers, employees and/or beneficial owners whose personal data we may process).

“Personal data” refers to any information relating to you that enables your identification. It does not include anonymised or aggregated data which does not allow for the identification of a specific individual.

We act as the data controller in relation to your personal data. The data controller is the entity that determines how and why your personal data is processed. Processing may be carried out directly by us or by third parties acting on our behalf as data processors.

We may also provide you with additional privacy notices on specific occasions when we are collecting or processing your personal data to ensure full transparency as to how and why your information is being used. These supplemental notices should be read in conjunction with this Privacy Notice.

If you have any questions regarding this Privacy Notice, you may contact our Compliance team at:
📧 compliance@kassaicapital.ao

What information do we collect about you and how do we use it?

The personal data we hold about you, or which is processed on our behalf, may include (but is not necessarily limited to):

your name, age, gender, sex, and identification numbers;
residential address;
place of work;
email address;
other contact details;
professional contact information;
signature;
employment and professional history;
regulatory status;
records of correspondence;
information relating to your investment activity or preferences;
financial information, including behavioural data, objectives and needs;
information about how you use our website; and
other technical data (such as your IP address, browser type and version, time zone settings, and location).

The purposes for which we may collect, retain and use your personal data, along with the legal basis for doing so, are summarised below:

Purpose	Legal Basis for Processing
To undertake pre-investment steps, including determining your eligibility to invest, conducting required due diligence, and assessing your investment preferences.	To take steps prior to entering into a contract with you or the fund in which you may invest, in compliance with applicable legal obligations and in pursuit of our legitimate interests in identifying suitable investment strategies.
To correspond with you.	Our legitimate interests in responding to your enquiry, contacting you in connection with the services you provide, or otherwise communicating in the context of our business operations.
To conduct business development and promotional activities, including making suggestions and recommendations about products or services that may be of interest to you. These may include direct electronic marketing.	We will only send direct electronic marketing where you have consented or where permitted by law. You may opt out at any time via the unsubscribe mechanisms in the message or by contacting compliance@kassaicapital.ao.
To disclose information to third parties, such as service providers, legal counsel, auditors, technology suppliers and regulators, in order to comply with legal obligations or pursue our legitimate business interests.	As required by law or to pursue our legitimate business interests.
To maintain our records.	Our legitimate interests in the proper conduct of our business activities.
To analyse how our services are used, maintain a relevant website, and inform our marketing strategy.	Our legitimate interests in improving and developing our business and marketing approach.

In addition to the purposes listed above, we may also process your personal data where required by law or where we reasonably believe it is necessary to protect our rights and/or to comply with legal or regulatory proceedings, court orders or other legal processes.

Special categories of personal data

Article 13 of the PDPL establishes specific requirements for the processing of sensitive personal data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning sexual life or orientation.

We do not actively seek to collect such special categories of data. However, we may incidentally hold such data, for example:

When you voluntarily provide it to us or to our processors (e.g., via email);
When documents collected for regulatory or legal purposes (e.g., due diligence from public sources) contain such data.

What if you do not provide the requested data?

Unless and until you decide to invest with us or engage in a commercial transaction (at which point you will receive a copy of the relevant privacy policy), you are under no obligation to provide us with personal data. Please note, however, that certain technical data may be automatically collected through your use of our website.

Change of purpose

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for a different purpose that is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will notify you and explain the legal basis for doing so, in accordance with Article 9 of the PDPL.

How do we collect this information?

We typically collect your data when you, or someone acting on your behalf, communicates or transacts with us—whether in writing, electronically, by telephone or otherwise. For example, when you request product documentation, marketing materials or information.

We may also automatically collect technical data when you interact with our website, using cookies, server logs and similar technologies.

Additionally, we may receive personal data about you from third parties, including:

Public sources or information providers;
Presenters, distributors or intermediaries promoting or providing services to you.

With whom do we share your information?

We may share your personal data with third parties where required by law, where necessary to perform our contract with you, or where we have a legitimate interest to do so. This may include:

Other entities within our group for performance monitoring, restructuring, or support in marketing and business development;
Intermediaries promoting or delivering services to you;
Professional advisers (lawyers, banks, auditors, insurers) where relevant to their services;
Regulatory authorities;
Tax authorities;
Cloud service providers;
Other service providers where relevant to their contractual duties.

We may also share your personal data in the context of a potential sale or restructuring of the business, or if required by law or legal process, or where we believe it necessary to protect our rights.

Your data may be transferred to countries that do not provide the same level of data protection as your home jurisdiction. Where this occurs, we will only do so where appropriate safeguards are in place and in compliance with all applicable legal and regulatory requirements.

How long will we retain your data?

We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting or reporting obligations, and our legitimate business interests. This typically includes the period during which we are engaging or anticipate engaging with you, plus a retention period deemed reasonable for internal archiving purposes.

In determining the appropriate retention period, we consider the nature and sensitivity of the data, the risk of unauthorised use or disclosure, the purposes of processing, and whether these purposes can be achieved by other means, as well as applicable legal requirements.

As a general rule, we retain relevant records for seven years from the date of last activity, or longer if required by law or regulation.

In certain cases, we may anonymise your data so that it no longer identifies you. In such cases, the data ceases to be considered personal.

When personal data is no longer required, we will securely destroy it in accordance with applicable laws and regulations.

Accuracy of your information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your information changes during your relationship with us.

Your rights in relation to your personal data

As a data subject, you have the following rights under applicable law:

To request access to your personal data (commonly known as a "data subject access request") and information about its use;
To request rectification of inaccurate or incomplete data;
To request erasure of your data;
To request restriction of processing;
To object to the processing of your data;
To request transfer of your data to another party.

If you wish to exercise any of these rights, please contact us at: compliance@kassaicapital.ao.

You also have the right to lodge a complaint with a supervisory authority at any time.

Fees

You will not normally have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with such a request in those circumstances.

What we may need from you

We may need to request specific information from you to verify your identity and ensure your right to access your data (or exercise any of your rights). This is a security measure to ensure that your data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In limited circumstances where you have provided your consent for the processing of your data for a specific purpose, you have the right to withdraw your consent at any time. To do so, please contact: compliance@kassaicapital.ao.

Upon receipt of your withdrawal notice, we will cease processing your data for that purpose unless we have a legal basis to continue.

Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. We will make an updated version available to you and notify you of any material changes. We may also notify you by other means in relation to how we process your data.

Further information

This Privacy Policy is intended to be clear and concise but does not constitute an exhaustive description of all aspects of our data collection and use. If you require additional information, please do not hesitate to contact us at: compliance@kassaicapital.ao