A&P Privacy and Personal Data Protection Policy states the ways in which A&P Investment Fund Management Company processes, manages and uses personal data of Customers and eventual business associates and the rights they may exercise in this regard. 

A&P adopts the necessary measures to protect the privacy of the data of its clients, employees and business partners, having prepared this Privacy and Personal Data Protection Policy (“Privacy Policy”) with the purpose of demonstrating its commitment and respect for the rules of protection of personal data, thus complying with the principles of lawfulness, loyalty, transparency, purpose limitation, conservation, accuracy, and integrity confidentiality.

The Privacy Policy was prepared to inform the practical rules of protection of the personal data made available, seeking to clearly explain the requested personal identification information (“Personal Data”), as well as its use, management and disclosure.

We also provide information about the Data subject’s rights exercise such as of the rights of access, rectification, and opposition to the treatment of your personal data, in accordance with Law 8/2005.

The personal data provided to A&P Investment Fund Management Company are protected namely by the personal data protection legislation (Law No. 8/2005). This Law establishes the principles for processing personal data, which should be done in a transparent manner and in strict compliance with individuals’ privacy and with other fundamental rights set out in the Basic Law of Macau, other instruments of international law as well as the current legislation in force in Macau.

The relationship between A&P and the Customer is guided by the observance of a strict confidentiality and by the compliance with the duties binding the Company, especially not to disclose or use (share, sell or transmit) information about facts or details of the Customer such as personal information or business activities and transactions, unless when, and on the conditions, required by law or when expressly authorized by the Customer.

A&P is a company that respects the law and regulations including in these areas of privacy protection and respects and abide namely by the personal data protection legislation (Law No. 8/2005).

A&P emphasizes its commitment to data protection and privacy including a full and permanent compliance with applicable data protection laws and regulations. 

If you are using A&P website, check here (link) our full Website Terms and Conditions of Access Policy and Regulations for more detailed information.

Personal data: the information related to a single natural person, identified or identifiable (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiologic, genetic, mental, economic, cultural or social identity of that natural person;

Data subject: Natural person to whom the processed data refers to.

Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Consent: shall mean any freely given specific and informed indication of the data subject will, by which you express your acceptance to personal data relating to yourself being processed.

When performing its activity, A&P processes data within explicit and specific purposes. This processing is based on compliance with legal obligations and relevant regulations from competent Macau authorities, such as AMCM, in the performance of contracts in which the data subjects are part, in the pursuance of A&P’s legitimate interests, and within the consent of the data subjects.

Personal data or financial information you make available to or may be requested by the Company will be used to enable us to provide services to you, meet eventual disclosure or other requirements imposed by law or ordered by a lawful authority, comply with finance activities supervision and auditing requirements, or designing financial products or services.

The Company may from time to time request your personal data, in order to provide services you have applied for or to ensure that the company’s records are correct and up to date. If you choose not to provide requested data or if information provided by you is incomplete or incorrect, this may prevent the company from providing services to you.

In case, for legal reasons, it is necessary to retain the data for a certain period of time, the information should be kept and stored according to the purpose for which the information is processed.

The period of retention of personal data is indicated in an independent formal statement signed by the holder, that is the data subject, and according to the purpose of the processing.

A&P maintains appropriate measures to ensure that all personal data is securely stored as long as it is necessary for us to provide services to you or to comply with retention obligations imposed by law, after which it will be destroyed.

All our staff and third parties with permitted access to your information are specifically required to observe the Company’s confidentiality obligations.

We strive to ensure that your personal data is protected against accidental or unauthorized access, processing or deletion.

All our staff that deals or may deal with personal data is aware of the legal obligations and procedures regarding personal data protection established in the relevant legislation, namely Law 8/2005.

A&P managers, collaborators and employees have an obligation to ensure the confidentiality of personal data as an integral part of their professional duties and ensure compliance with the guidelines set out in the Privacy and Personal Data Protection Policy.

A&P has a special designated Privacy Officer as seen further ahead.

By requesting services from us, you acknowledge, accept and expressly authorize the Company to transfer your personal data and/or information related to transactions you undertake with the Company to other parties, insofar as such collection or transmission is necessary for the Company to provide services to you as you may request, to enable the Company to comply with reporting obligations, and for the Company’s internal or external auditing purposes. 

As stated, in certain cases, there is a need to assign personal data to third parties for them to provide services on our behalf. We will only share the information strictly necessary for the service provided with these entities, and they are prohibited from using it for any other purpose. 

This information is covered through an agreement signed between A&P and these third parties or simply through a statement of responsibility.

Any such transmission shall be undertaken in strict compliance with applicable customary and legal commercial secrecy and personal data privacy legislation.

The Company may be lawfully ordered to provide users’ personal data or other information such as of financial nature to government departments responsible for finance supervision or to Macau SAR courts, but we will only do so under proper authority and within the legal obligations applicable to the case.

In each individual case, A&P will inform the affected holders of the mandatory nature of the provision of the personal data in question.

Under no circumstances will the data collected be used for any purpose other than that for which the express consent of the holders was given.

After receiving a written request, A&P shall ensure the exercise of the following rights, in accordance with what is established, namely, in Law 8/2005, in its articles 10 and forward:

Right of access: you shall have the right to obtain from the Company confirmation as to whether or not personal data concerning yourself is being processed, and, where that is the case, access to the personal data;

Right to rectification: you shall have the right to obtain from A&P without undue delay the rectification of inaccurate personal data concerning yourself. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement;

Right to object: you shall have the right to object, at any time, to processing of personal data concerning yourself, namely when processing is performed for other purposes than the ones for which it was collected and for which you have given your consent. Where personal data is processed for direct marketing purposes, you shall have the right to object at any time to processing of your personal data for such marketing;

Right to erasure (‘usually known as the ‘right to be forgotten’): you shall have the right to obtain from the Company the erasure of personal data concerning yourself without undue delay, as long as you meet the requirements for that erasure, namely, the relationship with A&P has been ceased and all legally established record retention periods or other legal or contractual guarantees have already expired;

Right to restriction of processing: you shall have the right to obtain from the Company the restriction of processing of your personal data where one of the following applies:

The accuracy of the personal data is contested by you, for a period enabling A&P  to verify the accuracy of the personal data;

The processing is unlawful and you oppose to the erasure of the personal data and request the restriction of its use instead;

A&P no longer needs the personal data for the purposes of the processing, but it is required by yourself for the establishment, exercise or defense of legal claims;

You have objected to processing, pending the verification whether the legitimate grounds of A&P override those of the data subject.

You also have the right to lodge a complaint with the Company’s supervisory authority, AMCM, or with the Macau Data Protection Office.

The Company is entitled to charge a reasonable fee for processing data access requests. 

However, pursuant to article 12, 2, of Law 8/2005, the above-mentioned right to object is free of charge.

A&P has a special designated Privacy Officer responsible for addressing privacy-related concerns and inquiries from users. 

Cookies are small pieces of data transmitted from a web server to a web browser and stored on the user’s local hard drive. They can be read only by the web site that provides them and cannot be used to obtain data from a user’s hard drive and do not harm the user’s system. This is useful for allowing a website to maintain information about a particular user, therefore, cookies are very commonly used on websites.

To provide better service and a more effective website, we use cookies as part of our interaction with your browser to determine your service preference. These cookies do not collect personally identifiable information, and we do not combine information collected through cookies with other personal information to determine your identify or your email address.

We will only use cookies as a session identifier and will not store user’s sensitive information in them. Once a session is established, all the communications will use the cookie to identify a user. The cookie will expire once the session is closed. If users try to disable cookies from their web browsers, they will not be able to access this website.

Cookie Consent: By using your website, users consent to the use of cookies as described above-mentioned. 

Users can manage their cookie preferences, such as through browser settings or cookie consent banners.

Users have the option to accept or reject certain types of cookies.

Updates to the Cookies Policy: The Cookies Policy may be updated from time to time, hence it is the users responsibility to review the Cookies Policy periodically for any changes.

For further information regarding these policies and practices adopted, please address your correspondence to:

Email: enquiry@apfund.mo