Disclosures
Legal Terms of Use
This website is owned, controlled and operated by GuardCap Asset Management Limited and its affiliates, partners and associated businesses (together, “GuardCap“, “we“, “us” or “our“). GuardCap is a private limited company registered in England and Wales (registered number 04667528) having its registered office at 11 Charles II Street, St James’, London, United Kingdom, SW1Y 4NS. GuardCap is authorised and regulated by the Financial Conduct Authority.
These terms and conditions (the “Terms“) explain how you may use this website and any of its content (the “Site“). These Terms apply between GuardCap and you, the person accessing or using the Site (“you” or “your“).
Your access to and continued use of this Site constitutes your understanding and acceptance of, and is conditional upon your continued acceptance of and compliance with these Terms and applicable laws and regulations. Please read these Terms carefully before proceeding to use this Site and if you do not agree with any of these Terms, do not use this Site.
Please note that these Terms may be amended or replaced from time to time without notice to you. Each time you use this Site you should check these Terms to ensure that you understand the terms that apply at that time and by continuing to access or use this Site, you are deemed to agree to any changes. It is your responsibility to check for any such changes. This version was last updated in June 2024.
Other important terms
All products and services of GuardCap are subject to the terms and conditions of any applicable agreements governing their use.
These Terms incorporate the terms of GuardCap’s Privacy and Cookies Policy (available here), which also apply to your use of the Site and set out the way in which GuardCap processes personal data about you, including that which GuardCap collects from you, that which you provide GuardCap or that which GuardCap generates, and also sets out details of the cookies used on the Site.
Site availability
The information, material and content provided in the pages of this Site (the “Information“) may be updated, amended, removed or replaced at any time without notice. We do not guarantee that this Site, or any Information on it, will always be available or be uninterrupted. We reserve the right to suspend or withdraw or restrict the availability of all or any part of this Site (including without limitation the Information) for business and operational or other reasons, without prior notice.
GuardCap tries to make the Site as accessible as possible. If you have any difficulties using the Site, or any other questions about the Site, please contact GuardCap by:
(a) sending an email to guardcapinfo@guardiancapital.com; or
(b) calling GuardCap on +442079072400.
Intellectual property rights
GuardCap either owns or is licensed to use the intellectual property rights, including without limitation copyright and related rights, trade marks, domain names, database rights, and any and all other intellectual property rights of any kind whether registered or unregistered anywhere in the world, on this Site and in all Information, including, but not limited to, text, images, illustrations, audio clips and video clips on the Site. GuardCap and its licensors reserve all intellectual property rights. This means that GuardCap or its licensors (as applicable) remain the owner of them and are free to use them as they see fit. You may view, display and print the Information on this Site for your own personal non-commercial use only, provided the Information is not modified. Any other use of the Information is prohibited. Unless otherwise specified, none of the Information may be otherwise downloaded, copied, reproduced, republished, modified, stored in any medium, uploaded, posted, re-transmitted or re-disseminated in any manner or form without the prior written consent of GuardCap. You may not use or export or re-export the Information in violation of applicable laws. Nothing in these Terms, or on this Site, grants you any rights in the Site or the Information other than as necessary for you to access this Site in accordance with these Terms.
You agree not to remove any copyright or other proprietary notices contained on the Site at any time.
Certain words, phrases, names, designs, icons, graphics or logos used on the Site may constitute trade marks, service marks or trade names of GuardCap or other entities. The display of any trade marks on the Site does not imply that a licence has been granted for any further use by you. Any unauthorised downloading, re-transmission or other copying or modification of trade marks that occurs without our prior written consent is strictly prohibited and may be a violation of statutory or common law and/or trade mark law and could be subject to legal action.
Your use of this Site
Your access to and use of this Site is at your own initiative and risk, and you are solely responsible for your use of this Site, the use to which you put Information contained on it and any decisions you make regarding any investments.
The Information on this Site is provided for informational purposes only. No part of the Site should be taken to constitute an offer or solicitation to buy or sell securities and/or other products or services, unless otherwise stated, and nothing on the Site is intended to constitute an invitation or inducement to engage in investment activity in any jurisdiction.
No information on the Site constitutes investment, tax, legal or any other advice. You should seek professional advice in respect of any investments you are considering making and before relying on any information contained on the Site. For the avoidance of doubt, any investment decisions relating to funds or opportunities involving GuardCap should be made on the basis of the final terms of such investment/opportunity and not on the basis of any information provided on this Site.
Should you undertake any investment activity based on information contained in this Site, you do so entirely at your own risk and GuardCap shall have no liability whatsoever for any loss, damage, costs or expenses incurred or suffered by you as a result.
Past performance is not an indicator of future performance. Market and currency movements may cause the value of investments and the income and other returns from them to go down as well as up and you may get back less than you invested.
Local Laws
It is important to note that not all of the products, services and Information are available in jurisdictions outside the United Kingdom. This Site is not directed at any person resident in any jurisdiction where, under local law or regulation, the publication or availability of this Site is prohibited, and the Information on this Site does not constitute an offer or solicitation to buy or sell any product, service or information to anyone in any jurisdiction in which an offer or solicitation is not authorised or cannot legally be made or to any person to whom it is unlawful to make an offer or solicitation.
The terms and conditions applicable to any product, service or information will be those determined at the time of provision of the product, service or information. Please be aware of the laws of your country or that otherwise apply to you in relation to any of the matters described in these pages.
GuardCap makes no promise that the Site is appropriate or available for use in locations outside of the United Kingdom. If you choose to access the Site from outside of the United Kingdom, you do so on your own initiative and are responsible for compliance with applicable local, national or international laws. You may not use or export or re-export the Information of any copy or adaptation in violation of applicable laws or regulations, including export laws and regulations of the United Kingdom in force from time to time.
Links to Other Web Sites
This Site may, from time to time, contain links to other websites and resources (including third party websites and resources). These links are provided for your information only as references to help you identify and locate other internet resources that may be of interest. These other websites were independently developed by third parties and are outside of GuardCap’s control. GuardCap does not review, endorse, approve or control and is not responsible for the accuracy or appropriateness of the information contained, or endorse products, services or viewpoints expressed, at such websites. In providing links to other websites, GuardCap is in no way acting as a publisher of the material contained on those other websites and does not, and does not seek to, control the content of, or maintain any editorial control over such websites.
Following a link from our Site to any other website is at your sole risk and GuardCap will not be responsible or liable for any damages in connection with such linking. Please note that your use of a third party website may be governed by the terms and conditions of that third party website.
Links to downloadable software websites may be made available to you for convenience only and GuardCap is not responsible or liable for any difficulties of consequences associated with downloading the software. Use of any downloaded software is governed by the terms of the licence agreement, if any, which accompanies or is provided with the software. You should read any such licence agreement carefully. It may contain provisions that set out your legal rights and your legal responsibilities when using the software, the software provider’s legal responsibilities and any limitations on the software provider’s legal responsibilities to you. Using software in an unlawful way (such as reproducing or redistributing it in a way that breaches any terms and conditions that apply to it) may result in civil and criminal penalties.
A link to another website should not be construed to imply that GuardCap is affiliated or associated with the third party operating that website, or is legally authorised to use any trade mark, trade name, logo or copyrighted symbol that may be reflected in the link or the description of the link to such other websites.
No Endorsement
The mention of another party or its product or service on the Site should not be construed as an endorsement of that party or its product or service.
Submitting information to the Site and/or GuardCap
While GuardCap tries to make sure that the Site is secure, GuardCap does not actively monitor or check whether information supplied to us through the Site is confidential, commercially sensitive or valuable.
Any unencrypted or otherwise unprotected e-mail communication over the internet is, as with communication via any other medium, not confidential, subject to possible interception or loss, and is also subject to possible alteration. GuardCap is not responsible for and will not be liable to you or anyone else for any damages in connection with an e-mail sent by you to GuardCap or an e-mail sent by GuardCap to you at your request.
Other than any personal information which will be dealt with in accordance with our Privacy and Cookies Policy (available here), GuardCap does not guarantee that information supplied to us through the Site will be kept confidential and GuardCap may use it on an unrestricted and free-of-charge basis as GuardCap reasonably sees fit.
Conformance with Law
You agree that your use of the Site shall not violate any applicable local, national or international law, including but not limited to any regulations having the force of law. Some jurisdictions may have restrictions on the use of the internet by their residents.
Your conduct
As a condition of your use of the Site, you agree not to:
(a) misuse or attack our Site by knowingly introducing viruses, trojans, worms, logic bombs or any other material which is malicious or technologically harmful (such as by way of a denial-of-service attack), or
(b) attempt to gain unauthorised access to our Site, the server on which our Site is stored or any server, computer or database connected to our Site.
GuardCap may prevent or suspend your access to the Site if you do not comply with these Terms or any applicable law.
No Warranties
While GuardCap attempts to ensure that this Site remains secure, we do not guarantee that this Site will be secure or free from bugs or viruses. You are responsible for configuring your information technology and computer programmes in order to access the Site.
GuardCap makes no warranty that the content of the Site will be appropriate for the purposes for which you use it. Information provided on the Site is believed to be reliable when posted. However, GuardCap makes no warranties, representations or guarantees regarding the quality, accuracy, completeness or timeliness of the Information provided. GuardCap assumes no obligation to update the Information on further developments concerning topics mentioned. Information contained on the Site may contain typographical errors. Information provided may be updated, amended, removed or replaced without notice. Access to this Site is provided on an “as is, where is” basis. GuardCap and its officers, directors, employees and agents disclaim all express and implied warranties, representations, endorsements and conditions regarding use of the Site and the Information provided, including without limitation, all warranties as to merchantability, operation, fitness for a particular purpose, non-infringement, usefulness, completeness, accuracy, currency and reliability, whether arising from a course of dealing, usage or trade practice. Further, there are no representations and warranties that the Site will be available and meet your requirements, that access will be uninterrupted, that there will be no delays, failures, errors or omissions or loss of transmitted information, that no viruses or other contaminating or destructive properties will be transmitted or that no damage will occur to your computer system.
Liability
Nothing in these Terms exclude or limit in any way GuardCap’s liability for:
- death or personal injury caused by GuardCap’s negligence, or that of its directors, agents, officers or representatives;
- fraud or fraudulent misrepresentation; or
- any other liability which cannot be limited or restricted by law.
Nothing in these Terms shall limit GuardCap’s liability under the regulatory system.
If you are a business
Except in relation to the types of losses set out above, GuardCap and its officers, directors, employees and agents are not responsible for any direct, indirect, special, incidental, consequential, exemplary, punitive or any other losses, damages, costs or expenses whatsoever and howsoever caused, arising out of or in connection with your use of the Site or reliance on the Information available on the Site or you transmitting or receiving information to or from GuardCap over the internet (including without limitation any loss or damage which may arise from or in connection with your use of or inability to use, interruption to, delay or the unavailability, operation or transmission of, this Site, or from a computer virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of this Site or to your downloading of any content from it), including any loss of use, lost data, lost business profits, loss of business or business interruption, loss of goodwill or reputation, loss of revenue, loss of anticipated savings, wasted expenditure, personal injury, or any other pecuniary loss, whether in an action of contract, negligence or other tortious action, or breach of statutory duty even if GuardCap has been informed of the possibility these damages.
GuardCap is not liable to you if it fails to comply with these Terms because of circumstances beyond our reasonable control, including failure of electronic or mechanical equipment of any kind, failure of communication systems (including telephone, cable or internet), unauthorised access, theft, operator error or any similar event.
No one other than us or you has any right to enforce any of these Terms.
If you are a consumer
Please note that we only provide our Site to you for domestic and private use. You agree not to use our Site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
Choice of Law
This Site is administered by GuardCap from its offices in the United Kingdom. The Site will be governed by the laws of England and Wales, notwithstanding any conflict of laws provisions or your domicile, residence or physical location. All disputes, controversies or claims arising out of or in connection with the Site shall be submitted to and be subject to the jurisdiction of the courts of England. You hereby submit and attorn to the exclusive jurisdiction of the courts of England to finally adjudicate or determine any suit, action or proceeding arising out of or in connection with this Site.
If you do not agree to be bound by the above Terms then please close the window on your web browser and exit this Site.
© 2024 GuardCap Asset Management Limited. All rights reserved.
UK Reporting Fund Status
Privacy and Cookies Policy
GUARDCAP ASSET MANAGEMENT LIMITED
GuardCap Asset Management Limited (the “Firm“, “we“, “us” or “our“) is committed to protecting the privacy of individuals whose data it processes (“you” or “your“).
1. IMPORTANT INFORMATION AND WHO WE ARE
This privacy policy aims to give you information on how the Firm collects and processes your personal data as a controller.
In addition, it outlines your data protection rights under applicable data protection laws in the UK, including the retained UK law version of the General Data Protection Regulation ((EU) 2016/679) (“UK GDPR“) and the UK Data Protection Act 2018.
This website is not intended for children and we do not knowingly collect data relating to children.
Due to the nature of its business, the Firm has determined that it does not require a statutory Data Protection Officer given the limited amount of personal data that it processes. However, the Firm’s Compliance Team shall be responsible for overseeing the implementation of this policy and for monitoring compliance with this policy and with data protection law.
2. CATEGORIES OF DATA SUBJECTS
(A) CLIENTS AND INVESTORS
The following section of this policy sets out how the Firm, as controller of personal data supplied by, and collected in relation to, clients as well as shareholders and potential investors in the funds we manage (“Funds“) and other persons whose information is provided to us by or on behalf of the clients or Funds, will process such personal data.
Types of information we may hold
We may hold personal data about clients (and those working for clients) as well as investors in the Funds which is provided to us by you directly as a result of your being a client and/or holding an investment in a Fund. Information may be obtained by (i) correspondence in respect of the services we provide; and/or (ii) completing and submitting application forms for the Fund(s), and/or through our website, recorded and monitored telephone calls, collation of due diligence as a result of holding your investment and/or you corresponding with us. It also may be collated or provided to us by third parties for credit and money laundering checks and compliance purposes, such as screening. We may also process personal data about individuals that are connected with our clients and the Funds and/or you as an investor (for example directors, trustees, employees, representatives, beneficiaries, shareholders, investors, clients, beneficial owners or agents).
We may collect, store, and use some or all of the following categories of personal information about you: contact details (including name, title, address, telephone number, personal email address), your date of birth, copies of passport, driving licences and utility bills, bank account details and details relating to your investment activity and personal identifiers such as your social security number, national insurance number, tax file number and IP address.
In limited cases, we also collect what is known as “special categories” of information. Our money laundering, sanctions, financial crime and fraud prevention checks sometimes result in us obtaining information about political opinion, actual or alleged criminal convictions and offences.
You are not obliged to provide us with your information where it is requested but we may be unable to provide certain products and services or proceed with our business relationship with you if you do not do so. Where this is the case, we will make you aware.
How we will use information about you
Your personal data may be processed by the Firm or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:
- to administer your investment in accordance with your instructions and/or in order to perform a contract we have entered into;
- to allow us to administer and manage investments (including fee calculations and the payment of dividends and other corporate actions) which are necessary for the Firm to comply with applicable laws and/or are in its legitimate interest to allow us to provide our services to the clients and Funds we manage;
- to update and maintain records for the Firm, including maintaining statutory registers, which is necessary to comply with the Firm’s legal obligations;
- to carry out anti-money laundering checks and other actions in an attempt to detect, prevent, investigate and prosecute fraud and crime and verify your identity, in order to comply with the Firm’s legal obligations, for the performance of a task being carried out in the public interest and/or to pursue the Firm’s legitimate interests (including for the prevention of fraud, money laundering, sanctions, terrorist financing, bribery, corruption and tax evasion);
- to scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems to pursue our legitimate interests including for document retention purposes; and
- such other actions as are necessary to manage the activities and/or to comply with the legal obligations of the Firm, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and enforcing or defending the rights and/or interests of the Firm, in order to comply with the Firm’s legal obligations and/or to pursue the Firm’s legitimate interests such as use in connection with the Firm’s internal management and reporting, to administer, operate, facilitate and manage your account(s) with us and your use of our services and products, to facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements and to pursue the legitimate interests of the Firm in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions.
To the extent that such personal data contains special category data (such as data relating to racial or ethnic origin, political opinion, or religious or philosophical belief), the processing of such data shall solely be for the purpose of complying with any duty imposed on us and/or the Funds by law (such as anti-money laundering and combatting the financing of terrorism). In limited circumstances, we may ask for your explicit written consent to process special category personal data and we shall inform you of our intended purpose(s) of processing such data at the relevant time.
We may only use information relating to criminal convictions where the law allows us to do so. We may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Some of the above grounds of processing will overlap and these may be several grounds which justify how we use your personal data.
The Firm does not anticipate being required to obtain your consent for the processing of your personal data as listed above. If the Firm wishes to use your personal data for other purposes which do require your consent, the Firm will contact you to request this.
(B) VISITORS TO OUR WEBSITE
The following section of this policy sets out how the Firm may process personal data (as a controller) about visitors to its website and/or individuals who contact the Firm using the contact information provided on the website.
Types of information we may hold
We may collect, use, store and transfer different kinds of personal data about you which you provide to us though our website, such as your name, address, email address, telephone numbers, technical data (including internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
We do not collect any special categories of personal data about you through our website.
How we collect your data
We use different methods to collect data from and about you including through direct interactions when you contact us using our contact details provided on the website, and through cookies, server logs, pixel tags and other similar technologies (which we may use to collect technical data about your equipment, browsing actions and patterns).
How we will use information about you
Your personal data may be processed by the Firm or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:
- to provide you with any information that you have requested, in order to perform a contract with you;
- to send you updates on the performance of the Firm, newsletters, invitations to events and other marketing communications which we will do only with your consent;
- to use data analytics to improve our website, marketing and user experiences on the basis of our legitimate interests;
- to comply with legal or regulatory requirements;
- to scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems to pursue our legitimate interests including for document retention purposes; and
- such other actions as are necessary to manage the activities of the Firm, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and enforcing or defending the rights and/or interests of the Firm, in order to comply with its legal obligations and/or to pursue its legitimate interests.
If we consider it necessary to obtain your consent in relation to the use of your personal data (such as for sending emails to individuals that have not invested in the Firm), we will contact you to request this consent. Details of how to withdraw your consent are set out below.
Processing on the basis of legitimate interests
Where such processing is being carried out on the basis that it is necessary to pursue the Firm’s legitimate interests, such legitimate interests should not override your interests, fundamental rights and freedoms.
Links to websites
Where the website provides links to other websites, the Firm is not responsible for the data protection/privacy/cookie usage policies of such other websites, and you should check these policies on such other websites if you have any concerns about them. You should always exercise caution and review the privacy policy applicable to the website in question.
Cookies
A cookie is a small file that a website sends to your computer and is stored by your web browser, which it then sends back to the website. Cookies allow us to save your login state, stated country, username, preferences, and other navigational details, and also allow us to measure how you use the website so that it can be improved based on your needs and the aggregate browsing behaviour of our website users. Cookies are encrypted, and only Firm web servers can read them.
The browsers of most computers, smartphones and other web–enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the “Help” menu of your browser to learn about how to change your cookie preferences. However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it may affect how our website works and you may not be able to access all or parts of our website.
Further information about cookies (including how to turn them off) can be found at www.allaboutcookies.org.
3. DISCLOSURES OF YOUR PERSONAL DATA
We may disclose personal data we hold about you:
- to other entities within our group;
- to providers of investment products or services, including fund administrators, registrars, printers and similar service providers;
- to our IT and other service providers;
- to our professional advisers;
- in the event that we sell or transfer any business or assets, in which case we may disclose personal data we hold about you to the prospective and actual buyer of such business or assets; and/or
- if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party (including without limitation to any of our regulators).
4. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
5. INTERNATIONAL TRANSFERS
Some of the third parties to whom we transfer personal data may be based outside the UK and/or the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the UK and/or EEA.
Whenever your personal data is transferred outside the UK and/or EEA by us, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or UK Secretary of State; or
- where we use certain service providers, we may use specific contracts approved by the European Commission or UK Secretary of State which give personal data the same protection it has in Europe and/or the UK.
Please contact us if you want further information on the specific mechanism used when transferring your personal data outside the UK and/or EEA.
6. DATA SECURITY
The Firm has put in place measures to ensure the security of the personal data it collects and stores about you. It will use its reasonable endeavours to protect your personal data from unauthorised disclosure and/or access, including through the use of network and database security measures, but it cannot guarantee the security of any data it collects and stores.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required or consider it appropriate to do so.
7. YOUR LEGAL RIGHTS
In certain circumstances, by law you have the right to:
- request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
- request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
- object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
- request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
- request the transfer of your personal information to another party; and
- withdraw your consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw such consent at any time. Withdrawing your consent will not affect the lawfulness of processes based on consent before its withdrawal. To withdraw your consent or to opt out of receiving marketing communication, please contact us at UKComplianceTeam@guardiancapital.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you wish to exercise any of the rights set out above, please contact the Compliance Team at UKComplianceTeam@guardiancapital.com.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
8. CHANGES TO THIS PRIVACY NOTICE
We may update this privacy notice from time to time, and will communicate such updates through our website. We may also notify you from time to time about the processing of your data.
9. QUERIES AND COMPLAINTS
If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please first contact your GuardCap relationship manager. If you would like to escalate any matter, you can also contact our Compliance Team at UKComplianceTeam@guardiancapital.com or write to us at 11 Charles II Street, St James’, London, SW1Y 4NS, marking your letter for the attention of the Compliance Team.
You also have the right to make a complaint at any time to your local data protection authority (in the UK, the Information Commissioner’s Office (ICO) (www.ico.org.uk)) if you consider that the processing of your personal data carried out by us or the administrator of any other service provider to us, has breached data protection laws. We would, however, appreciate the opportunity to deal with your concerns before you approach any of the supervisory authorities so please contact us in the first instance by emailing UKComplianceTeam@guardiancapital.com.
