Legal

Privacy Policy

Last updated 22 September 2026. Pending legal review.

1. Information we collect

We collect information you provide directly: name, contact details, entity name, investor type, and jurisdiction submitted through our enquiry form; and the identity, financial, and verification documentation required to establish investor eligibility and to meet anti-money-laundering and know-your-customer obligations.

We also record the attestations made when accessing restricted areas of this site, together with the date, time, and technical information associated with them, because we are required to evidence them.

2. How we use it

To respond to enquiries; to verify investor eligibility; to administer subscriptions, redemptions, and investor reporting; to meet legal, regulatory, tax, and recordkeeping obligations; and to secure and improve our services.

3. Legal basis

Where the EU or UK General Data Protection Regulation applies, we process personal data on the basis of contract performance, compliance with legal obligations, and our legitimate interests in operating and securing the business.

4. Disclosure

We share personal data with our fund administrator, auditors, legal advisers, custodians, banking partners, and identity verification providers, in each case as required to deliver the service or to comply with law. We do not sell personal data.

5. Retention

We retain personal data for as long as necessary to fulfill the purposes above and to satisfy applicable recordkeeping requirements, which for investor records is generally a minimum of five years following the end of the relationship.

6. Security

We maintain administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including encryption at rest and in transit, access controls, and logging. No system is perfectly secure.

7. Your rights

Depending on your jurisdiction you may have rights to access, correct, delete, restrict, or port your personal data, and to object to certain processing. Requests may be submitted through the contact form on this website. Some rights are limited where we are legally required to retain records.

8. Cookies and analytics

We use strictly necessary cookies to operate the investor portal and to record attestations. We use privacy-preserving analytics that do not set advertising cookies, do not track individuals across sites, and do not sell or share data with advertising networks.

9. International transfers

Personal data may be processed in jurisdictions other than your own, including the United States and the Cayman Islands. Where required, we put appropriate transfer safeguards in place.

10. Contact

Questions regarding this policy may be submitted through the contact form on this website.