Policies and disclosures.
We appreciate your interest in our website and our company. We make every effort to protect your personal data when it is collected, processed and used during your visit of our website. Your data is protected in accordance with statutory requirements, including the General Data Protection Regulation (EU) 2016/679, whose implementation is described in the personal data protection policy below.
Personal data is collected and processed on our website as far as you have actively provided such data by registering yourself. Walnut may collect different categories of personal data such as, in particular: last Name, first Name, email, profession, company, phone number, job title, country.
Walnut is also likely to collect IP addresses, cookies, and information about your browser in order to perform security or statistical analysis-related processing on an anonymous basis.
The purpose of the personal data use is to enable the carrying out of statistical analysis operations in order to improve the services offered and to enhance the security of the website. This information also allows the provision, if any, of data relating to collective investment vehicles managed by Walnut.
Personal data is disclosed to service providers in order for them to carry out the services specifically dedicated to Walnut’s scope of activity.
Walnut outsources some of its processing and might in this instance transfer data outside of the European Union. In such a case, Walnut is committed to have the service providers contractually agree to adequate data protection.
Walnut is committed to storing your personal data no longer than necessary for the purpose for which it was processed. Furthermore, Walnut stores your personal data in accordance with the retention period imposed by current regulations.
2. Best selection and execution policy
Walnut has an obligation to act in the best interests of its clients and of the funds it manages or sub-manages. To this end, the company is subject to an obligation of best selection and best execution and applies a dedicated procedure.
Best Selection: under the supervision of Walnut’s investment committee, financial intermediaries & brokers are selected based on the following criteria:
- Intermediation / brokerage costs
- Quality and reliability of execution
- Capacity to deal with large orders
- Quality of confirmation flows and back office processes
The fund managers are required to monitor that actual execution flows are in line with the above. Quality is assessed globally and not deal by deal. Failure to execute, confirm and settle orders within Walnut’s quality standards is reported to Walnut’s management and investment committee.
Best execution: when selecting a new broker, Walnut requires that such broker provides its own best execution policy.