Disclaimer

The distribution of the information contained within the Website in certain countries may be restricted by law and persons who access the Website have to comply with any such restrictions. The information is not intended to be published or made available to any person in any jurisdiction where doing so would contravene any applicable laws or regulations.

By accessing the Website you confirm that you are aware of the laws in your own jurisdiction relating to the provision and sale of funds, related financial services products and you warrant and represent that you will not pass on or utilise the information contained in the Website in a manner that could constitute a breach of such laws by Creechurch Capital Limited or any other person. The Website does not constitute an offer or solicitation in any jurisdiction in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such an offer or solicitation.

The Website is provided for information purposes only and does not constitute investment, legal, tax or other advice or any recommendation to buy or sell any of the Funds or stocks mentioned. Prospective investors should take appropriate professional advice before making any investment decision. Investments in the Funds are to be made on the terms of the relevant prospectus and no reliance should be placed on the information contained in the Website. Accepting this disclaimer will store a cookie in order to remember that you have already accepted the terms and conditions.

Creechurch Capital – Privacy Statement

At Creechurch Capital Limited, we’re committed to protecting and respecting your privacy.

This Statement explains what personal when and why we collect personal information about people, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

Any questions regarding this Statement and our privacy practices should be sent by email to info@creechurchcapital.com or by writing to the Data Protection Officer, Creechurch Capital Limited, Knox House, 16-18 Finch Road, Douglas, Isle of Man, IM1 2PT.

Who are we?

Creechurch Capital Limited is a Discretionary Fund Manager. We are licensed by the Isle of Man Financial Services Authority and registered in the Isle of Man, Company No. 5267V. VAT registration No. 003 2910 30. Registered Address: Knox House, 16-18 Finch Road, Douglas, Isle of Man, IM1 2PT.

How do we collect information from you?

We obtain information about you at the time of on-boarding the relationship with you by completing the “Gathering Information” document and providing us with the relevant due diligence documentation.

We may periodically update our records which may require us contacting you to obtain further information.

What type of information is collected from you?

The personal information we collect will include your name, former names, date of birth, national insurance number, tax reference number, place of birth, nationality, country of residence, domicile, address, email address, telephone numbers (home/work/mobile).

As part of the application we will also collect the value of assets to be managed, details of the existing custodian / policy provider, portfolio reference number and product name.

We will also ask for details of your exiting assets, source of wealth and investment priorities and objectives.

To complete your risk profile which is necessary for us to assess the product suitable for you we will ask you for, timeframe for investment, investment objectives and further questions to ascertain your attitude to risk.

How is your information used?

We may use your information to:

– To meet our regulatory requirements, to ensure that we have identified you.

– To ensure that we have ascertained your time horizon and attitude to risk to ensure that we provide you with a suitable product.

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.

Who has access to your information?

We will not sell or rent your information to third parties.

We will not share your information with third parties for marketing purposes.

Third Party Service Providers:

We utilise a client relationship management product, Satuit CRM, to hold the data we have obtained.

Satuit Technologies, Inc. the company behind Satuit CRM is a Company registered in the U.S.A. We have obtained confirmation that Satuit, Inc. is a subscriber to the U.S. Privacy Shield and complies with the framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union to the United States.

We have received confirmation from Satuit Technologies, Inc that the information stored within Satuit CRM is hosted on servers located in Canada which are owned by CenturyLink, a Canadian IT services company.

With the above in mind we are therefore satisfied that it is appropriate to use Satuit CRM to store and manage the information we receive from our clients.

As part of our legal requirements with regards to identifying our clients and intermediaries we utilise a software solution (RDC GRID TM), provided Regulatory DataCorp, Inc. (RDC). RDC GRID TM is a database of global risk intelligence. We screen potential clients, existing clients and intermediaries details against RDC GRID TM. The details we screen against include full names and dates of birth.

RDC store the information that we share with them for their own regulatory requirements. RDC’s full privacy policy can be viewed at the following link:

https://rdc.com/company/privacy-policy/

We are satisfied that it is appropriate to use RDC for the purpose of screening our client and intermediary data against.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of business or to protect the rights, property or safety of our customers. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

Your rights

If you wish to access the data we hold about you then please contact us by email at info@creechurchcapital.com or by writing to the Data Protection Officer, Creechurch Capital Limited, Knox House, 16-18 Finch Road, Douglas, Isle of Man, IM1 2PT.

In addition to the right to access your personal detail you also have the following rights under the legislation:

– the right to access personal data held about them;
– the right to object to processing (for example, direct marketing);
– the right to data portability;
– the right to complain about processing carried out by the data controller;
– the right to object to automated decision making;
– the right for the personal data being updated; and
– the right to be forgotten.

Please contact us as per the above details should you wish to exercise any of these rights.

Review of this Statement

We keep this Statement under regular review. This Statement was last updated in May 2018.


Associated Offices
Douglas
Knox House, 16-18 Finch Road,
Douglas IM1 2PT
London
7 Old Park Lane, London,
W1K 1QR
Manchester
Blackfriars House, Parsonage,
Manchester M3 2JA

Clients are advised that the value of investments can go down as well as up. Creechurch Capital Limited is licensed by the Isle of Man Financial Services Authority and registered in the Isle of Man, number 5267V.
VAT Registration No. 003 2910 30. Registered Address: Knox House, 16-18 Finch Road, Douglas, Isle of Man IM1 2PT. For your security communications may be recorded. Full product details including Terms & Conditions and Fee Schedule are available upon request.