Sanditon Site Masthead

Terms &
Privacy Policy

 

Introduction

The content of this website has been prepared by Sanditon Asset Management Limited (“SAM”) on the basis of information and sources believed to be reliable. Under no circumstances should any part of this website be construed as an offering or solicitation of an offer, and any investment in the products of this site should only be made on the basis of an Offering Memorandum or Prospectus. SAM is authorised and regulated by the Financial Conduct Authority (“FCA”) (register number 609326). You can gain access to the FCA's rules and guidance notes from the following link: http://www.fca.org.uk

Sanditon Asset Management Limited is a company registered in England (number 08639467) with its registered office at 4th Floor Reading Bridge House, George Street, Reading, Berkshire, England RG1 8LS.

Sanditon Asset Management Limited is approved by the Central Bank of Ireland to act as investment manager to Irish authorised investment funds.

 

Terms

1. Terms and conditions of use – Important Legal Notice

The following terms and conditions of use ("Terms”) apply to your access to and use of SAM’s website (“website” or “site”). Every time you access or use the website you agree to comply with and be bound by the Terms and acknowledge that we may rely upon your agreement. Please read the following Terms carefully and if you do not accept any terms or conditions, please do not access or use this website.

2. Not for US persons

The provision of the information in this website does not constitute an offer of securities to any person in the United States or to any US Person as such term is defined under the Securities Act of 1933, as amended. The information contained in this site about SAM and/or any of its affiliates is not directed to any person in the United States. Funds referred to herein are neither registered under the Securities Act 1933 of the USA, nor are they registered under the Investment Company Act of 1940. Consequently, they cannot be offered for sale or be sold in the USA, its territories, possessions or protectorates under its jurisdiction, nor to nationals, citizens or residents in any of those areas. No investments or services mentioned on this website are directed at US Persons who are not Professional Clients or Eligible Counterparties as defined by the UK Financial Conduct Authority (FCA) Handbook or Qualified Purchasers as defined under the Investment Company Act of 1940. The information contained herein does not constitute a distribution, an offer to sell or the solicitation of an offer to buy any securities in any jurisdiction in which such distribution or offer is not authorised.

3. Information on SAM website

Except where stated otherwise, the information, content and services on this website (“Information”) are provided by SAM (referred to as "we" and "us") as at the date indicated on the relevant material. The Information is provided for personal use and information purposes only. The Information does not take account of the investment objectives, financial situation and particular needs of any particular person and is not general advice to any class of persons. Therefore, you should not rely on the Information and should obtain relevant and specific professional advice in making any investment decision. Furthermore, nothing on this website constitutes or should be construed to constitute:

(a) an offer, advice, invitation or solicitation from us or our affiliates to buy or sell any investments or securities, futures, options or other financial instruments;

(b) an invitation or inducement to engage in investment activity or a financial promotion of any kind; or

(c) investment recommendation or advice.

References in this site to specific securities should not be taken as a recommendation to buy or sell those securities, but are included for the purposes of illustration and/or information only.

4. Website - permitted users

The laws and regulations of the country from which you access this website may include restrictions on the distribution of the Information. This site is not directed at or intended for distribution to or use by any person or entity in any jurisdiction where (by reason of that jurisdiction’s applicable securities laws, person’s nationality, residence or otherwise) such distribution, publication, availability or use of this site or any part of its contents would be contrary to applicable law or regulation or would subject SAM or any SAM Funds or its investment manager or affiliates to any registration or licensing requirement within such jurisdiction. If you are such a person or entity, you are not authorised to enter the site. It is your responsibility to ensure that your use of this website complies with any restrictions or any applicable local laws regarding use of the Information on this website. Persons or entities in respect of whom such restrictions apply must not access the relevant pages on this site. The Information displayed on this website contains material that may be interpreted by the relevant authorities in the country where you are viewing this site as a financial promotion or an offer to purchase securities. Accordingly, if you reside in any such country or fall within the scope of any law that seeks to regulate financial promotions in the country of your residence or in the country in which you are viewing this site, please cease accessing or using this website immediately. If you are uncertain about your position under the laws of the country in which you are viewing this website, then you should seek clarification by obtaining legal advice from a lawyer practicing in your country’s law or in the country in which you are viewing this website before accessing this site. You may not use any part of the material or Information on this site to establish, maintain or provide or assist in establishing, maintaining or providing a stock market for trading in securities. This site is not directed at you if we are prohibited by any law of any jurisdiction from making the information on this site available to you. You should satisfy yourself before accessing the site that we would be allowed to advertise investments and investment services to you under the laws and regulations of your jurisdiction. For the avoidance of doubt, this document is NOT intended for distribution to or use by citizens or residents of the USA. No investment may be offered or sold to citizens or residents of the USA nor in any other country, state or jurisdiction where it would be unlawful to offer, solicit an offer or sell such investments. This restriction also applies to residents of the USA who may view or access this site whilst travelling or living outside of their normal jurisdiction.

In order to access certain sections of this website, you must first confirm that you are a professional client or an eligible counterparty for the purposes of the FCA Rules.

SAM reserves the right to terminate or suspend your access to all or any part of the site, without notice, if SAM, in its sole discretion, believes that your continued use of the site or any of its content is in violation of any applicable law or is harmful to the interests of SAM or any of its affiliates, subsidiaries or other representatives.

5. Accuracy of information and investment performance

Whilst the information contained on the site has been given in good faith and every effort has been made to ensure its accuracy, the Information may not be complete or accurate for your purposes. This site and the Information is provided on an "as is" basis and we may not, and have no obligation to, update the Information or correct any inaccuracy which subsequently becomes apparent. The Information and/or opinions and estimates comprised in the Information may be changed or withdrawn without notice and may become outdated. You should verify any information or other material obtained from this site before you use it. The site contains material about the past performance of SAM Funds. The value of an investment in a Fund may go up as well down so that an investor's investment in a Fund, when redeemed, may be more or less than the original investment amount. By its nature, investment in a Fund managed by SAM is only suitable for sophisticated investors who do not require immediate liquidity for their investment, for whom an investment in a Fund does not constitute a complete investment programme and who fully understand and are willing to assume any high risk that may be involved in the investment programme of a Fund. THE PAST PERFORMANCE OF ANY INVESTMENT, INVESTMENT STRATEGY OR INVESTMENT STYLE IS NOT INDICATIVE OF FUTURE PERFORMANCE. SAM, ITS RELATED BODIES CORPORATE, THE DIRECTORS OR OFFICERS OF THOSE ENTITIES, OR THEIR AGENTS DISCLAIM ALL REPRESENTATIONS AND WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING BY WAY OF EXAMPLE BUT NOT LIMITATION AS TO RELIABILITY, COMPLETENESS, FITNESS FOR PURPOSE OR ACCURACY OF THE INFORMATION ON THIS WEBSITE OR ON ANY THIRD PARTY WEBSITE LINKED TO THIS WEBSITE. IN ADDITION, WE DO NOT REPRESENT OR WARRANT THAT THIS WEBSITE OR THE SERVERS THAT MAKE THE SAM SITE AVAILABLE WILL BE ERROR FREE, UNINTERUPTED OR FREE FROM INFECTION, VIRUSES, WORMS OR ANY OTHER HARMFUL CODE WHICH MAY HAVE CONTAMINATING OR DESTRUCTIVE PROPERTIES. YOU ARE FULLY RESPONSIBLE FOR ENSURING PROTECTIVE STEPS ARE TAKEN SUCH AS VIRUS CHECKING. The Information is assembled from material prepared by SAM or its agents but may not include Information made known to SAM officers (or agents) subsequent to the date of publication of the Information indicated on the site. If you use the Information, you do so at your own risk. Please recognise that the previous performance of securities or other instruments does not guarantee or predict future performance.

6. Exclusion of liability

TO THE FULLEST EXTENT PERMITTED BY LAW, SANDITON ASSET MANAGEMENT LIMITED, ITS AFFILIATES, OFFICERS OR AGENTS ACCEPT NO LIABILITY TO YOU OR ANY THIRD PARTY FOR ANY LOSSES OR DAMAGES, INCLUDING, WITHOUT LIMITATION, DIRECT OR INDIRECT DAMAGES, CONSEQUENTIAL OR SPECIAL DAMAGES, LOSS OF USE, DATA OR PROFITS, COSTS OR EXPENSES INCURRED OR SUFFERED BY YOU OR THIRD PARTY, WHETHER IN CONTRACT OR DUE TO NEGLIGENCE OR OTHER TORTIOUS ACTION, ARISING OUT OF OR IN CONNECTION WITH THE ACCESS TO, USE OF, RELIANCE ON, OR PERFORMANCE OF THIS WEBSITE OR ANY INFORMATION CONTAINED ON THIS WEBSITE, WHETHER DUE TO INACCURACY, ERROR, OMISSION OR ANY OTHER CAUSE AND WHETHER ON THE PART OF US, OUR SERVANTS, AGENTS OR ANY OTHER PERSON. NOTHING IN THE TERMS OF USE EXCLUDES, RESTRICTS OR MODIFIES ANY CONDITION, WARRANTY OR LIABILITY WHICH MAY AT ANY TIME BE IMPLIED BY STATUTE OR ANY OTHER APPLICABLE LAW WHERE TO DO SO IS ILLEGAL OR WOULD RENDER ANY PROVISION OF AN AGREEMENT VOID. No liability is accepted for any loss, either direct or indirect, incidental or consequential, arising out of the information on this site not being true and accurate, except to the extent caused by the wilful default or gross negligence of SAM or to the extent that such liability arises under the Financial Services and Markets Act 2000. Please note that SAM may update or alter the information on the site at any time without giving notice of the alterations.

7. Third party websites

We may provide, on our website, links to websites operated by third parties as a convenience to you. If you use these other sites, you will leave this site. If you decide to visit any linked site, you do so at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive elements. SAM makes no representations, warranties or guarantees of any kind about any of the content of any other website which you may access by hypertext link through this site. When you access any other website by means of a link from this site, you should understand that your access to that other website is independent of SAM and we have no control over the content of the website, nor do we in any way endorse or approve the content of that website. In no event will we in any way be liable to you or any other person(s) or organisation(s) for loss or damage (whether direct, indirect, consequential, special or other) for any use of any site linked to it by means of hypertext or otherwise.

8. Indemnity

You agree to indemnify SAM and its officers, agents and affiliates from and against any claim brought by third parties against SAM and its officers, agents and affiliates as a consequence of your breach of the Terms. Furthermore, if your use of this website results in the need for servicing, repair or correction of equipment, software or data, you assume all costs thereof.

9. Intellectual property rights and licence

Any information accessed via this site is confidential and is protected under copyright law. The copyright, trade mark or any other intellectual property rights in the website and the Information are owned by or licensed to SAM. You may download or print out a hard copy of individual pages and/or sections of this website provided you do not remove any copyright or other proprietary notices. Any downloading or other copying from this site will not transfer title to any software or material to you. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link to or use for any public or commercial purpose this site without the prior written permission of SAM. Any rights not expressly granted in the Terms are reserved.

10. Operation of the website

You should be aware that the internet, being an open network, is not secure. If you choose to send any electronic communications by means of this site, you do so at your own risk. We cannot guarantee that such communications will not be intercepted or changed or that they will reach the intended recipient safely.

11. Privacy

Any personal data relating to you will be collected, used and recorded by us in accordance with current data protection legislation, the Terms and our Privacy Policy below. You must read our Privacy Policy as it forms part of the Terms.

12. Governing law

This site is hosted in the UK and compiled in order to comply with the laws of England and Wales. All visits to and the contents of, this site are subject to and governed by the laws of England and Wales. If any dispute arises from your use of this site or any of the information on it, you agree to submit to the non-exclusive jurisdiction of the High Court of Justice in England and Wales. The Terms are governed by the laws of England and Wales.

13. Waiver

If you breach the Terms and we take no action, we will still be entitled to use our rights and remedies in any other situation where you breach the Terms.

14. Our details

This website is owned and operated by Sanditon Asset Management Limited, 33 Cannon Street, London EC4M 5SB. Telephone 02035952900.

27 June 2014, updated on 21 January 2016

 

Privacy Policy

1. Introduction

Sanditon Asset Management Limited (SAM) is committed to protecting your personal data and the privacy of all visitors to its website (website or site). Please read the following privacy policy to understand how we use and protect the information you provide.

By submitting your details to SAM or requesting to subscribe to SAM’s newsletters, facts sheets, events or other services, you are agreeing to the terms of our privacy policy and you consent to us using your data to send you the communications you have subscribed for in accordance with our privacy policy. You can unsubscribe at any time by emailing: info@sanditonam.com.

We endeavour to ensure that any personal data we collect about you will be held and processed strictly in accordance with the Data Protection Act 1998 (DPA) and, on and from 25 May 2018, the European General Data Protection Regulation (GDPR). The terms Personal Data, Data Controller and processing have the meanings given to them in the GDPR (which can be accessed in Article 4 of the GDPR), unless otherwise indicated.

2. Scope

This Privacy Policy demonstrates how SAM handle the Personal Data you provide to us, or which we collect about you in any way (Your Data), including:

  • a) by you submitting information to us through our website or for example, when you subscribe to a newsletter or ask to receive monthly fact sheets, conference call invitations or event invitations (Website User Data);
  • b) through your use of our other marketing resources, such as events or webinars which we run or sponsor (Marketing Data);
  • c) from what we learn about you from your visit to our websites (Website Background Data); and/or
  • d) by you otherwise interacting with us a prospective, current or former client or investor, (for example, where you provide your business card to us) other than in connection with ongoing services we are providing to you or your organisation (Prospect Data).

3. Identity and Contact Details of Data Controller

For the purposes of the DPA and the GDPR, SAM is the controller of Your Data. If you have any queries regarding this policy or complaints about our use of Your Data, please contact us at info@sanditonam.com or at the address below and we will do our best to deal with your complaint or query as soon as possible.

Sanditon Asset Management Limited
33 Cannon Street
London EC4M 5SB
+44 (0)20 3595 2900

4. What we use Your Data for

The table below sets out the purposes for which we may process Your Data and the legal basis for the processing:

Data Purpose Legal Basis
Website User Data
Marketing Data
Prospect Data
To keep you informed of any activities undertaken by us which we believe may be of interest to you and this use may include sending you email and postal marketing from time to time. This may include fact sheets and annual reports on our funds Consent - this will be requested either when you submit Your Data to us or, if we have received Your Data indirectly, by way of an email sent prior to us sending you any marketing communications.
Website User Data
Website Background Data
Website analytic purposes. For further details on the technology we use in order to analyse our website’s performance, please see our cookies policy below. Consent – this will be obtained when you click on the banner at the top of our website to accept certain cookies.
Legitimate interest of SAM (see our cookies policy for further information).
Website User Data
Marketing Data
Prospect Data
To provide you with the fact sheets or invitations or other information you have requested. Performance of a contract.
Website User Data
Marketing Data
Prospect Data
Website Background Data
Prospect Data
Survey Data
To respond to requests for information from regulated bodies or government agencies. Compliance with a legal obligation.
Website User Data
Prospect Data
To respond to an enquiry you have submitted. Legitimate interest of SAM – it may be necessary for us to process Your Data in order to reply or respond to your enquiry.

5. Who we share Your Data with

Please note that we may on occasion be required to share your information with third parties who provide services on our behalf. For example, we use third parties such as Digiterre to provide marketing automation services and Northern Trust to provide fund administration services. A list of all our third party service providers is available on request.

We have taken steps to ensure that all such entities keep Your Data confidential and secure and only use it for the purposes that we have specified and have informed you of. Our service providers are subject to data processing agreements which are, or are in the process of being updated to become, compliant with the requirements set out in the GDPR.

In relation to any other third parties, we will only disclose your information in the following circumstances:

  • • where you have given your consent;
  • • where we are required to do so by law or enforceable request by a regulatory body;
  • • where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights; and
  • • if we sell our company, go out of business, or merge with another company.

We will never sell your Data to any third party.

6. International Transfers

We use third party providers to host and manage our website and to provide us with marketing automation services. They are all based in the UK. However, in certain circumstances, we may transfer Your Data to countries outside the EEA, which may not adhere to the same levels of data protection to which countries within the EEA are subject. Any such transfers will, at all times, be made in accordance with the DPA and the GDPR.

7. Retention Period

Your Data will be stored for a maximum period of 7 years, after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained. If you consent to marketing, any information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information, unless we request your consent to store it for a longer period.

8. Your Rights in relation to Your Data

Under the GDPR, you will have the following rights in relation to how we process Your Data:

  • a) Right to request access – you may obtain confirmation from us as to whether or not Your Data is being processed and, where that is the case, access to Your Data.
  • b) Right to rectification and erasure – you have the right to obtain rectification of inaccurate personal data we hold concerning you and to obtain the erasure of Your Data without undue delay in certain circumstances.
  • c) Right to restriction of processing or to object to processing – you may require us to restrict the processing we carry out on Your Data in certain circumstances or to object to us processing Your Data.
  • d) Right to data portability – you have the right to receive Your Data in a structured, commonly used and machine-readable format.
  • e) Right to lodge a complaint – you may lodge a complaint with any supervisory authority in the EU. The supervisory authority for the United Kingdom is the Information Commissioner’s Office.

For further information on your rights, please see the Information Commissioner’s website: www.ico.org.uk.

9. Additional Information

  • I. There is no statutory or contractual requirement for you to provide Your Data to us and you are not obliged to do so. Please note, however, that we may not be able to provide you with the services you have requested, such as to receive our fact sheets, if you do not provide your contact details. As set out in our cookies policy, our website may not be able to function fully if you do not agree to certain cookies being set on your computer.
  • II. We do not undertake automated decision-making or profiling on Your Data.
  • III. We keep our privacy policy under constant review and may change it from time to time to reflect our practices or to remain compliant with relevant legislation. We will notify you of any material changes to our privacy policy via a notification on our website. Your continued use of this website or our other marketing services, following the posting of changes to these terms, will mean you accept these changes

10. Security of personal information

We recognise the need to ensure that personal information gathered via this website remains secure. Our site has security measures in place to protect against the loss, misuse and alteration of the personal information under our control. Our security measures include the use of a hardware firewall to prevent unauthorised access. You acknowledge that although we exercise adequate care and security there remains a risk that information transmitted over the Internet and stored by computer may be intercepted or accessed by an unauthorised third party.

11. Data obtained indirectly

In some circumstances, we may obtain Personal Data about you from other sources. This information may include your name, contact details and job title, which we obtain from publicly available sources such as your company’s website.

12. Links

Our website contains links to other websites belonging to third parties. We do not control the privacy practices of these other websites. You should therefore make sure when you leave our website that you have read that website’s privacy policy.

13. Cookies

SAM may use “cookies” to record and process information concerning your visit to and use of the site and identify you when you visit. Cookies are small pieces of information that your internet browser places on your computer’s hard drive. Cookies may be used for example for remembering user names and preferences. You have the option of setting your browser to block cookies. Please refer to the "help" function of your internet browser for instructions. In some cases blocking cookies may reduce the functionality of our site or prevent access. If you continue without changing your settings, we will assume that you are happy to receive all cookies. You can change your cookie settings at any time.

 

Sanditon Asset Management Limited, 33 Cannon Street, London EC4M 5SB. Telephone 02035952900.

27 June 2014, updated on 21 January 2016 and 4 May 2018