[Nemesis Capital Management] and its affiliated companies and subsidiaries (collectively referred to as “Nemesis”) are dedicated to collecting, using, and disclosing personal information in accordance with relevant laws and in a manner that would be deemed appropriate by a reasonable individual under the given circumstances.

Scope of policy
As a service provider working on behalf of its clients and operating under their guidance, Nemesis may collect, use, and disclose personal information concerning Claims, Claimants, or other individuals who provide information through this website (referred to as “Data”). This data is handled as directed by Nemesis’s clients and in accordance with applicable laws, in order to deliver Case Management Services on behalf of those clients. Nemesis strictly adheres to all relevant privacy and data protection laws, including but not limited to, the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, as a data processor. This Privacy Policy is constructed based on the principles and regulations outlined in the applicable privacy legislation.

Nemesis has appointed a Privacy Director who bears the responsibility of ensuring compliance with this Policy. The Privacy Director can be contacted using the details provided below:

Nemesis Capital Management
Attention: Privacy Director
Craigmuir Chambers Road Town, VG1110,
British Virgin Islands

Claims Data collected

Nemesis, acting on behalf of its clients who have control over the Data, has the authority to gather information from claimants, clients themselves, and third parties. The collected data may encompass the following:

  • Details pertaining to identity, such as name, address, email address, and additional contact information of claimants and other relevant individuals.
  • Information related to banking and financial accounts.
  • Publicly accessible information about you, relevant individuals, and other associated details concerning your claim(s).
  • The IP address utilized to access our website.
  • Any other information that you may disclose or share with us online, via phone, or in any other manner in connection with your claim(s).

Uses and disclosures

Nemesis will clearly state the purposes for which it collects personal information from individuals before or at the time of collection. These purposes can be communicated verbally or in writing, with written notification being the preferred method whenever feasible.

On behalf of its clients, Nemesis may gather, utilize, and reveal data for the following reasons:

  1. Initiating, processing, reviewing, investigating, assessing, validating, settling, finalizing, and overall administering claims as per the approved terms and conditions of Class Action Settlement Agreements by the Courts.
  2. Reporting, auditing, and performing analytics to provide reports on claims and audit claims on behalf of clients.
  3. Communication regarding your claim(s).
  4. Verifying your identity.
  5. Detecting and verifying fraud for the protection of Nemesis, its clients, and others, and to prevent fraud, errors, and harm.
  6. Enhancing services and operations used for claims management and related services, including training relevant personnel.
  7. Complying with the law, judicial proceedings, court orders, or other legal processes, such as responding to a court order or subpoena.
  8. Utilizing de-identified and aggregated information related to claims for research, analytics, and similar purposes.

While carrying out the aforementioned activities and purposes on behalf of its clients, Nemesis may process data, including involving other affiliated entities, which provide services or support related to Claims Management Services. Data may also be disclosed to third parties in the following circumstances:

  • Adjusters, assessors, valuators, and service providers contracted by Nemesis for services or functions related to Claims Management Services.
  • Authorized representatives and other service providers acting on behalf of Nemesis.
  • Other third parties when required to comply with the law, judicial proceedings, court orders, or other legal processes, such as responding to a court order or subpoena.
  • Nemesis may also disclose data to its clients, who have control over the data. Importantly, Nemesis will not sell the data to any party.

Limiting use, disclosure, and retention

Personal information will only be used or shared for the specific purposes for which it was collected, unless consent from the individual is obtained or when mandated by law. Nemesis strictly prohibits the sale of data to any third party.

As per our clients’ instructions, we will promptly destroy, erase, or anonymize documents and records that contain personal information when it is reasonable to believe that retaining the information no longer serves its original purpose and is no longer necessary for legal or business requirements. We will exercise caution during the destruction process to prevent unauthorized access to the information and ensure its security.


Nemesis will ensure that the personal information it collects is accurate, complete, and up-to-date to fulfill its intended purposes. It is our commitment to continuously take reasonable measures to maintain the accuracy and completeness of the personal information within our custody and control. We expect individuals to provide their personal information to Nemesis in an accurate and complete manner. Our objective is to minimize the risk of using inaccurate information when making decisions concerning individuals whose personal information is processed by Nemesis.


Nemesis has implemented various safeguards to ensure the security of personal information, preventing accidental loss and unauthorized access, use, alteration, or disclosure. All personal information is securely stored on our protected servers, shielded by firewalls.

Our security measures at Nemesis encompass:

  • Education and training provided to relevant staff members to ensure their awareness of privacy obligations while handling personal data.
  • Administrative and technical controls to limit access to personal data on a need-to-know basis.
  • Technological security measures such as firewalls, multi-factor authentication, encryption, and anti-virus software.
  • Physical security measures, including staff security passes required for premises access.
  • Reasonable precautions taken for the disposal or destruction of personal information, such as secure shredding of physical documents and secure deletion of electronically stored information to prevent easy recovery.
  • In the event of a security breach where there is a genuine risk of significant harm to you, we will notify you unless prohibited by applicable laws or regulations.

In the event of a security breach where there is a genuine risk of significant harm to you, we will notify you unless prohibited by applicable laws or regulations.

Access and correction

If you wish to access or correct the personal information that Nemesis has collected and processed as part of the Claim Services, learn about how the information is being used, and obtain details about individuals and organizations to whom the information has been disclosed, you can make a written request to our Privacy Director. Please note that you may need to verify your identity for such requests.

Since we act on behalf of our clients, we will forward your request to them and collaborate with them to address your request appropriately. However, there may be circumstances where we or our clients are unable to grant access to specific personal information. This can occur if the disclosure would reveal personal information about another individual, the information is protected by solicitor/client privilege, the information was collected for investigative purposes, or if the disclosure would unveil confidential commercial information. Additionally, legal restrictions may prevent us from providing access to certain personal information. In the event that an access request is denied, we will inform you in writing, explain the reasons for the refusal, and provide information about any available recourse options.

Cross-border transfers

To fulfill the aforementioned purposes, Nemesis, along with its subsidiaries or affiliated companies, may transfer your personal information across national borders.


Nemesis may utilize cookies and other methods to gather personal information about individuals who visit or engage with us online. Cookies serve as unique identifiers that tailor your website experience. While most web browsers automatically accept cookies, you can typically modify your browser settings to block or receive notifications when a cookie is sent. This allows you to decide whether to accept or decline the cookie. The information obtained through cookies assists us in enhancing our website, improving our services, and detecting and verifying instances of fraud. Please note that declining a cookie may result in limitations on certain site functions that you can access.


We employ automated devices and third-party applications, such as Google Analytics (http://www.google.com/intl/en/policies/privacy/), to analyze the usage of our website and services. This evaluation aims to enhance the performance and user experience of our website and services. These third parties may utilize cookies and other tracking technologies as part of their services. While we do not disclose your personal information to these third parties, they may collect your IP address for their own purposes.

Contact Information

We will, on request, provide information regarding our complaint procedure. Any inquiries, complaints, or questions regarding this Policy should be directed in writing to our Privacy Director as follows:

Nemesis Capital Management
Attention: Privacy Director
Craigmuir Chambers Road Town, VG1110,
British Virgin Islands

Important changes to our privacy policies and practices will be reflected in this Privacy Policy in a timely manner. We may add, modify, or remove portions of this Policy when we feel it is appropriate to do so.