Your privacy is very important to us. This notice (“Privacy Notice”) is provided by Svelland Capital (UK) Ltd (“we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information.

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How we collect information about you

We may collect personal data about you through:

• information provided directly to us by you, or another person on your behalf, through our website, by email or post, or in person;

• information that we obtain in relation to any transactions between you and us; or

• recording and monitoring of telephone conversations and electronic communications with you as described below.

We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.

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Why we collect information about you

We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements.

We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we or a third party determine that is necessary for our legitimate interests to collect and use your personal information.

The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.

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What are the consequences of failing to provide your personal information?

As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below).

We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us.

A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

The types of personal data we may collect and use

The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose of which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials.

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Do we use automated decision-making processes?

No.

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Do we share your personal information with third parties?

We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:

• our affiliates or other entities that are part of our group or with our clients;

• any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;

• our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators;

• service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools;

• credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;

• any person, as directed by you; or

• any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

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Transfers of personal information to countries outside of the European Economic Area (EEA)

Due to the international nature of our business, your personal data may be transferred to countries outside of the EEA, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation or other data protection rules applicable to us (collectively, “ Data Protection Law”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.

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For how long do we keep your personal information?

We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

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What are your rights?

You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:

• to request access to your information;

• to request rectification of inaccurate or incomplete information;

• to request erasure of your information (a “right to be forgotten”);

• to restrict the processing of your information in certain circumstances;

• to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);

• where relevant, to request the portability of your information;

• where you have given consent to the processing of your data, to withdraw your consent; and

• to lodge a complaint with the competent supervisory authority.

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How to contact us

If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact us by email at chris@svelland.com or by writing to Svelland Capital (UK) Ltd, Zig Zag Building, 70 Victoria Street, London, SW1E 6SQ.

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Complaining to ICO

You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO’s website.

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Recording and monitoring of communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of:

• ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances;

• ensuring compliance with our regulatory obligations; or

• detecting and preventing the commission of financial crime.

Copies of recordings will be stored for a period of five years, or such other longer period as we may determine from time to time.

 

This website content is issued by Svelland Capital (UK) Ltd an appointed representative of Mirabella Advisers LLP, which is authorised and regulated by the Financial Conduct Authority. The distribution of this document is restricted by law. It has been made available only to a selected group of recipients. The information contained in this document is also confidential. You must not copy this document or pass it to anyone else. If you (or the legal person you represent) did not receive this document directly from Svelland Capital (UK) Ltd, please return it to Svelland Capital (UK) Ltd. The information contained herein is aimed at professional clients within the meaning of Article 4.1(10) of the Markets in Financial Services Directive 2014/65/EU (MiFID II) (“Professional Client”). This information does not constitute an offer or invitation to invest and no person resident in the United Kingdom or the European Union other than a Professional Client should act or rely on this information.

Risk Warning:

An investment into a fund may expose a person accepted as an investor in such fund to a significant risk of losing some or all of the amount invested. The information contained in this document should not be construed as either projections or predictions. Svelland Capital (UK) Ltd makes no representation or warranty, express or implied, except as required by law or in the case of fraud, regarding the accuracy, completeness or adequacy of the information. Past performance cannot be relied on as a guide to future performance. Un-audited performance numbers may be corrected from time to time.

Important Information:

Svelland Capital (UK) Ltd will not act for you (or any other investor) and will not be responsible to you for providing protections afforded to the clients of Svelland Capital (UK) Ltd’s investment services. Without prejudice to the generality of the foregoing, Svelland Capital (UK) Ltd does not provide any investment service to you (including, without limitation, the provision of investment advice, or the reception and transmission of orders). This document is not, and must not be treated as, investment advice, investment recommendations, or investment research. Recipients of this document must not take (or refrain from taking) any investment decision on the basis of the information set out in this document. Before making any investment decision, you should seek independent investment, legal, tax, accounting or other professional advice as appropriate, none of which is offered to you by Svelland Capital (UK) Ltd. Svelland Capital (UK) Ltd accepts no duty of care to you in relation to investments.

This document is for information purposes only. This document is not intended to constitute an offering or placement, or the solicitation of an offer to subscribe for, units or shares in any fund, in any jurisdiction. Any such offering or placement, if made, would be made only by way of a formal offering document and only in jurisdictions in which such an offering or placement would be lawful. Such offering document will contain important information concerning risk factors and other material information. [An investment into a fund may expose a person accepted as an investor in such fund to a significant risk of losing some or all of the amount invested. The information contained in this document should not be construed as either projections or predictions. Svelland Capital (UK) Ltd makes no representation or warranty, express or implied, except as required by law or in the case of fraud, regarding the accuracy, completeness or adequacy of the information. Past performance cannot be relied on as a guide to future performance.

Notice for persons in the European Economic Area:

In relation to each member state of the EEA (each a “Member State”) which has implemented Alternative Investment Fund Managers Directive (Directive (2011/61/EU)) (the “AIFMD”), this document may only be distributed to the extent that: (1) Svelland Capital (UK) Ltd is permitted to market funds to professional investors in the relevant Member State in accordance with AIFMD (as implemented into the local law/regulation of the relevant Member State); or (2) this document may otherwise be lawfully distributed in that Member State (including at the initiative of the investor). In addition, the following restrictions apply to the distribution of this document. Notice for persons in the United Kingdom: This website is a marketing communication may only be distributed to the extent that (1) Svelland Capital (UK) Ltd is permitted to market funds to professional investors in the UK in accordance with Alternative Investment Fund Managers Directive (Directive

(2011/61/EU)) (the “AIFMD”) (including the delegated and implementing acts adopted under it) as implemented, retained, amended, extended, re-enacted or otherwise given effect in the United Kingdom at the end of the transitional period agreed between the European Union and the United Kingdom pursuant to the European Union (Withdrawal) Act 2018 and as amended or supplemented in the United Kingdom thereafter; or (2) this document may otherwise be lawfully distributed in the UK (including at the initiative of the investor).

This website content may be issued in the United Kingdom by Svelland Capital (UK) Ltd to, and/or is directed at, only persons to or at whom it may lawfully be issued or directed under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 including persons who are authorised under the Financial Services and Markets Act 2000 (“FSMA”), certain persons having professional experience in matters relating to investments, high net worth companies, high net worth unincorporated associations or partnerships, or trustees of high value trusts or persons who qualify as certified sophisticated investors. This document may be distributed only to such persons in the United Kingdom and must not be relied or acted upon by any other persons in the United Kingdom. In order to qualify as a certified sophisticated investor a person must: (a) have

a certificate in writing or other legible form signed by an authorised person to the effect that he is sufficiently knowledgeable to understand the risks associated with a particular type of investment; and (b) have signed, within the last 12 months, a statement in a prescribed form declaring, amongst other things, that he qualifies as a sophisticated investor in relation to such investments. The content of our webiste is exempt from the general restriction in Section 21 of FSMA on the communication of invitations or inducements to engage in investment activity on the grounds that it is being issued to and/or directed at only the types of person referred to above. The content of this document has not been approved by an authorised person and such approval is, save where this document is directed at or issued to the types of person referred to above, required by Section 21 of FSMA. CISA Swiss disclosure: The representative in Switzerland is ARM Swiss Representatives SA, Route de Cité-Ouest 2, 1196 Gland, Switzerland. The paying agent in Switzerland is Banque Heritage S.A., 61, route de Chêne, Case Postale 6600, CH-1211 Geneve 6, Switzerland. The Prospectus, the Articles of Association and annual financial statements can be obtained free of charge from the representative in Switzerland. The place of performance and jurisdiction is the registered office of the representative in Switzerland with regards to the Shares distributed in and from Switzerland.

 

Notice for persons in other jurisdictions: The distribution of our website content may be further restricted by law. Accordingly, this document may not be used in any jurisdiction except under circumstances that will result in compliance with any applicable laws and regulations. Persons to whom this document is communicated should inform themselves about and observe any such restrictions. Any failure to comply with these restrictions may constitute a violation of applicable securities law