Privacy policy.

1. Who we are

BCM Management Ltd ("BCM", "we", "us") is a company incorporated in the British Virgin Islands (Company No. 2214422) with its registered office at Trinity Chambers, Ora et Labora Building, Wickhams Cay II, PO Box 4301, Road Town, Tortola, British Virgin Islands VG1110. BCM is approved by the BVI Financial Services Commission as an Approved Investment Manager. For the purposes of the Data Protection Act, 2021 of the Virgin Islands and, where it applies, the EU and UK General Data Protection Regulation, BCM is the controller of the personal data described in this policy.

2. The data we collect

Correspondence. When you write to us, we receive the details you provide, such as your name, email address, telephone number and the content of your message.

Clients and prospective clients. Before and during a managed-account relationship we collect the information our regulatory obligations require, including identity and address verification documents, tax residence, source of funds and source of wealth information, details of your custodian account, your investment objectives, financial circumstances and risk tolerance, and records of our communications and of transactions in your account.

Website use. This website does not set cookies and does not use analytics or advertising tools. Our hosting provider keeps standard server logs (IP address, browser type, pages requested, time of request) for security and operational purposes. Fonts are loaded from Google Fonts, which means Google receives your IP address when a page is displayed. If you tick "Remember my selection" on the entry notice, your selection is stored in your browser's local storage on your own device; it is not sent to us.

3. How we use it

We use personal data to respond to correspondence; to assess and onboard clients; to enter into and perform a Discretionary Investment Management Agreement; to manage, trade and report on your account; to meet our legal and regulatory obligations, including anti-money-laundering, counter-terrorist-financing and sanctions screening requirements, record-keeping and reporting to regulators; to keep our systems secure; and to establish, exercise or defend legal claims.

Where the GDPR applies, our lawful bases are the performance of a contract with you (or steps taken at your request before entering into one), compliance with legal obligations, and our legitimate interests in operating and protecting our business and in communicating with people who contact us. We do not rely on consent except where the law requires it, and we do not use personal data for automated decision-making that produces legal effects on you.

4. Who we share it with

We share personal data only where necessary and with appropriate safeguards: with the custodian or broker that holds your account, to the extent needed to operate it; with our professional service providers, including our registered agent, legal advisers, auditors, compliance consultants and IT and hosting providers, who act on our instructions and under duties of confidentiality; with the BVI Financial Services Commission, the BVI Financial Investigation Agency, courts and other public authorities where the law requires or permits it; and with a successor in the event of a reorganisation or sale of our business. We do not sell personal data and we do not share it for third-party marketing.

5. International transfers

BCM operates from the British Virgin Islands and works with clients, custodians and service providers in other countries. Personal data may therefore be transferred to and stored in jurisdictions other than your own. Where the GDPR applies to a transfer, we rely on adequacy decisions, standard contractual clauses or another lawful transfer mechanism.

6. How long we keep it

We keep personal data for as long as needed for the purposes above. Records relating to client identification, transactions and account management are retained for at least five years after the end of the relationship or the completion of the transaction, as BVI anti-money-laundering legislation requires, and longer where a legal claim, investigation or regulatory requirement makes it necessary. Correspondence from people who do not become clients is deleted within twelve months of our last contact.

7. Security

Personal data is held on access-controlled systems, and access is limited to the firm's officers and the service providers who need it. Client documents are transmitted and stored using encrypted channels and storage. No transmission over the internet is completely secure, and we ask you not to send account credentials or card details by email.

8. Your rights

Subject to the exceptions in applicable law, you have the right to ask for access to the personal data we hold about you, to have inaccurate data corrected, to have data deleted where we no longer have a lawful reason to keep it, to object to or ask us to restrict certain processing, and to receive data you provided to us in a portable form. Some records must be retained under anti-money-laundering law even if you ask for their deletion; we will tell you when that is the case. You may also complain to the Information Commissioner of the Virgin Islands or, where the GDPR applies, to the data protection authority in your country.

9. Contact

Requests and questions about this policy can be sent to BCMTrading@bcmmanagementltd.com or in writing to BCM Management Ltd at the registered office above, marked for the attention of the Compliance Officer.

10. Changes

We may update this policy from time to time. The date at the top shows when it was last changed, and the current version is always the one published on this website.