For the purposes of the Data Protection Act 1998 (the Act), the data controller is 1167 Capital LLP, c/o Haggards Crowther, Heathman’s House, 19 Heathman’s Road, London SW6 4TJ.
1 WHAT TYPE OF INFORMATION DO WE COLLECT FROM YOU?
1.1 We may collect and process the following information from you:
1.1.1 information that you provide by filling in forms on our website www.1167capital.com (our Website);
1.1.2 if you contact us, we may keep a record of that correspondence; and
1.1.3 details of your visits to our Website and the resources that you access.
2 HOW DO WE USE YOUR PERSONAL DATA?
2.1 We use information held about you in the following ways:
2.1.1 to carry out our obligations arising from any contracts entered into between you and us;
2.1.2 to provide you with information, products or services that you request
from us or which we feel may interest you, where you have consented to
be contacted for such purposes;
2.1.3 to ensure that content from our Website is presented in the most effective manner for you and for your computer; and
2.1.4 to notify you about changes to our service.
2.2 We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these.
2.3 If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data.
3 DISCLOSURE OF INFORMATION
3.1 We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the United Kingdom Companies Act 2006.
3.2 We may disclose your personal information to:
3.2.1 our affiliates or professional advisers;
3.2.2 persons or organisations who work on our behalf to provide a product or a service to you;
3.2.3 companies which perform marketing services on our behalf or with whom
we have joint marketing agreements;
3.2.4 other companies who we believe may have products and services of
interest to you.
3.3 We may also disclose your personal information to third parties if:
3.3.1 we sell or buy any business assets, in which case we may disclose your
personal data to the prospective seller or buyer of such business or assets;
3.3.2 1167 or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
4 HOW WE PROTECT YOUR DATA
5 IP ADDRESSES AND COOKIES
5.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration purposes.
5.2 Cookies contain information that is transferred to your computer’s hard drive. Cookies allow a web application to tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
5.3 This statistical data does not identify an individual. We only use this information:
5.3.1 to gather information on IP addresses and pages visited;
5.3.2 to analyse trends;
5.3.3 to administer the website;
5.3.4 to track users’ movements on the website; and
5.3.5 for purposes of statistical analysis.
6 LINKS TO OTHER WEBSITES
6.2 Our Website may from time to time contain links to and from other websites. If you follow a link to any of these websites please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You should always check these policies before you submit any personal data to these websites.
8 YOUR RIGHT TO ACCESS YOUR INFORMATION
8.1 The Act gives you the right to obtain a copy of the personal data we hold about you. The fee for obtaining a copy of your information is £10 which will go towards meeting our costs in providing you with details of the information we hold about you. We can provide you with that information further to a request in writing to 1167 Capital LLP, c/o Haggards Crowther, Heathman’s House, 19 Heathman’s Road, London SW6 4TJ providing us with sufficient information to identify you (we may need to request proof of identity in some instances). You have the right to request an amendment to any information that we hold and which you believe to be incorrect.
9.2 From time to time, 1167 or third parties who we think have products or services of interest to you may send you emails, email newsletters or news updates alerting you to new features, products, promotions, or services pertaining to our Website. If you no longer wish to receive materials from us and/or from such third parties, you may opt-out of receiving these communications by writing to us at 1167 Capital LLP, c/o Haggards Crowther, Heathman’s House, 19 Heathman’s Road, London SW6 4TJ or by emailing us your request to unsubscribe to email@example.com.
ANTI-BRIBERY AND CORRUPTION POLICY
1167 Capital LLP values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:
• Setting out a clear anti-bribery policy;
• Training all consultants and clients, so that they can recognise and avoid the use of bribery by themselves and others;
• Encouraging its consultants and clients to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;
• Notifying all third parties that 1167 Capital LLP engages with its policy and has zero tolerance of bribery and/or corruption;
• Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution;
• Taking firm and vigorous action against any individual(s) involved in bribery.
1167 Capital LLP prohibits:
the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or otherinducement:
to or from
any person or company, wherever they are situated and whether they are a public official or body or private person or company
any individual consultant, agent or other person or body acting on 1167 Capital LLP’s behalf
in order to
gain any commercial, contractual or regulatory advantage for 1167 Capital LLP in a way which is unethical or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
1167 Capital LLP recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Partnership or of the person or body employing or contracting with them or whom they represent.
This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:
• normal and appropriate hospitality;
• the giving of a gift for a corporate reason or at another special time, as long as it is reported in the proper manner within the firm on the gifts register;
Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the local senior manager with responsibility for this policy before proceeding. If necessary, guidance should also be sought from the Compliance Officer.
Consultants and Principles Responsibility within 1167 Capital LLP
The prevention, detection and reporting of bribery is the responsibility of all consultants throughout 1167 Capital LLP. Suitable channels of communication by which consultants or others can report confidentially any suspicion of bribery will be maintained via the Anti-Corruption Reporting procedures.
Useful resource: www.transparency.org.uk for the Transparency Index.
A fuller Policy and Procedures outlining all the Principles of the Act can be requested from the Chief Operating Officer of 1167 Capital LLP, by emailing firstname.lastname@example.org.
This page (together with the documents referred to on it) tells you the Terms and Conditions of Use
1 INFORMATION ABOUT US
1.1 1167 Capital LLP (we, us, our, and 1167) is a limited liability partnership incorporated
in England and Wales at under number OC411733. 1167 is authorised and regulated
by the UK Financial Conduct Authority with Firm Reference Number 784978. Our
registered office is at c/o Haggards Crowther, Heathman’s House, 19 Heathman’s
Road, London SW6 4TJ.
1.2 If you have any queries about the Website or any information contained on it, please
contact us at c/o Haggards Crowther, Heathman’s House, 19 Heathman’s Road,
London SW6 4TJ or by telephone on +44 (0) 203 405 5745; or by email at
2 ACCESSING OUR WEBSITE
2.1 Access to our Website is permitted on a temporary basis, and we reserve the right to
withdraw or amend the service we provide on our Website without notice. From
time to time, we may restrict access to some or all of our Website. We will not be
liable if for any reason our Website is unavailable at any time or for any period.
immediately and you must immediately destroy any downloaded or printed extracts
from the Website.
2.3 You are responsible for making all arrangements necessary for you to have access to
2.4 By accessing our Website any person using your computer agrees to be bound by
Website through your internet connection and on your computer are aware of these
of our Website by any person using your computer.
3.1 Nothing on this Website is intended, nor should it be taken, to create any legal or
contractual relationship. Any transmission, downloading or sending of any
information from the Website does not create any contractual relationship.
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3.2 The content of the Website is designed for information purposes only. Neither the
information nor any opinions stated in the Website constitutes a solicitation or offer
by 1167 to buy or sell any securities or other financial instruments or to provide any
3.3 The provision of investment services may be restricted in certain jurisdictions. It is
your responsibility to acquaint yourself with any local laws and restrictions on the
usage of this Website and the availability of any services described on it. The
information on this Website is not intended for distribution to or use by any
personal entity in any jurisdiction or country where such distribution would be
contrary to local law or regulation. The Services are available only to persons in the
United Kingdom and other European Economic Area countries. The Services are not
available to United States persons directly, unless introduced to 1167 by a FINRA
registered broker or their United States attorney.
3.4 Nothing in this Website may be published in the press or elsewhere without
permission of 1167.
3.5 1167 does not provide legal or tax advice. Clients of 1167 and viewers of this
Website are encouraged to consult their own legal and tax advisers before making
any investment decision. Private companies in all jurisdictions and potential
investors should take independent legal and taxation and investment advice before
proceeding with any type of fund raising activity.
3.6 While we endeavour at all times to ensure information on our Website is clear, fair
and not misleading at the date of publication, we do not hold the information as
impartial and it should not be viewed as wholly objective. Information on this
Website is based on sources that we believe to be reliable but we give no
undertaking that it is accurate or complete and 1167 cannot and does not guarantee
the accuracy, validity, timeliness or completeness of any information or data made
available to you for any particular purpose or at all.
3.7 The contents of this website are subject to change without notice and 1167 is under
no obligation to report updates or amendments or keep information accurate.
3.8 This Website is controlled and operated by 1167 in the United Kingdom. We make
no representations that materials in the Website are appropriate or available for use
in other locations. Those who choose to access the Website from other locations do
so at their own risk and are responsible for compliance with all applicable laws.
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4 INTELLECTUAL PROPERTY RIGHTS
4.1 This Website, its contents, any materials downloaded, and all intellectual property
pertaining to or contained on the Website (including but not limited to copyrights,
patents, database rights, graphics, designs, text, logos, trade dress, trademarks and
service marks) are owned by or licensed to us and/or from third parties and all
rights, title and interest in them shall remain the property of 1167 and/or such third
parties (collectively, the Content).
4.2 The Content is protected by copyright, patent and trademark laws, and various other
intellectual property rights and unfair competition laws.
4.3 You are permitted to print copies and download extracts of the content on the
Website for your own personal use for information purposes only, and may draw the
attention of others within your organisation to material posted on the Website,
subject to the following conditions:
4.3.1 our status (and that of any identified contributors) as the authors of
material on our Website must always be acknowledged;
4.3.2 you must not modify in any way the paper or digital copies of any materials
you have printed off or downloaded, and you must not use any
illustrations, photographs, video or audio sequences or graphics separately
from any accompanying text;
4.3.3 you must not duplicate, copy, publish, modify, create derivative works
from, participate in the transfer of, post on the internet, or in any way
distribute, redistribute or exploit the Website, or any portion of the
Website, for any public or commercial use without our express prior
4.3.4 you must not otherwise use any part of the Website in contravention of
4.4 If you print off, copy or download any part of the Website in breach of these Terms
of Use, your right to use the Website will cease immediately and you must, at our
option, return to us or destroy any copies of the materials you have made.
5 UNLAWFUL OR PROHIBITED USE
5.1 We will not be liable for any loss or damage caused by a distributed denial-of-service
attack, viruses, trojans, worms, logic bombs or other technologically harmful
material that may infect your computer equipment, computer programs, data or
other proprietary material due to your use of our Website or to your downloading of
any material posted on it, or on any website linked to it.
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5.2 You must not misuse our Website by knowingly or recklessly introducing viruses,
trojans, worms, logic bombs or any other material which is malicious or
technologically harmful. You must not attempt to gain unauthorised access to our
Website, the server on which our Website is stored or any server, computer or
database connected to our Website. You must not attack our Website via a denialof-service attack or a distributed denial-of service attack.
5.3 Any such unauthorised use of our Website may give rise to a claim for damages
and/or be a criminal offence under the Computer Misuse Act 1990. We will report
any such activity to the relevant law enforcement authorities and we will co-operate
with those authorities by disclosing your identity to them. In the event of such a
breach, your right to use our Website will cease immediately and without further
6.2 Additionally, by using our Website, you acknowledge and agree that internet
transmissions are never completely private or secure. You understand that any
message or information you send to our Website may be read or intercepted by
others, notwithstanding our efforts to protect such transmissions. We are not
responsible for any messages which are lost, altered by third parties or intercepted
and we will not be liable to you or anyone else for any damages or otherwise in
connection with any message sent by you to us or by us to you via the internet.
identify your computer. Cookies cannot identify which person is using the computer.
The cookies we use record which parts of our Site are being visited and for how long.
6.4 The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations
2011 requires that cookies can only be placed on a computer where the user has
given their express consent. You can choose to accept or decline cookies when you
first access our Site. We require you to indicate your choice via an automated “popup” box, which explains the cookies we use and what we use them for. Most web
browsers automatically accept cookies, but you can also usually modify your browser
set your web browser to decline their use, you will have only limited functionality in
7 EXCLUSION OF LIABILITY
7.1 The material displayed on our Website is provided without any guarantees,
conditions or warranties as to its accuracy, originality or completeness. To the extent
permitted by law, we and third parties connected to us hereby expressly exclude:
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7.1.1 all conditions, warranties and other terms which might otherwise be
implied by statute, common law or the law of equity;
7.1.2 any liability for any direct, indirect or consequential loss or damage
incurred by any user in connection with our Website or in connection with
the use, inability to use, or results of the use of our Website, any websites
linked to it and any materials posted on it, including:
(a) loss of income or revenue;
(b) loss of business;
(c) loss of profits or contracts;
(d) loss of anticipated savings;
(e) loss of data;
(f) loss of goodwill;
(g) wasted management or office time; and
(h) any other loss or damage of any kind, however arising and whether
caused by tort (including negligence), breach of contract or
otherwise, even if foreseeable, provided that this condition shall not
prevent claims for loss of or damage to your tangible property or any
other claims for direct financial loss that are not excluded by any of
the categories set out above.
7.1.3 In jurisdictions which do not allow the exclusion or limitations of certain
types of liability, 1167’s liability will be limited to the maximum extent
permitted by law.
8.1 By using our Website, you agree to indemnify and hold harmless 1167 from and
against any and all losses, claims, damages, costs and expenses (including reasonable
legal and accounting fees) that 1167 may become obliged to pay, arising or resulting
1167 reserves the right to assume or participate, at your expense, in the
investigation, settlement and defence of any such action or claim.
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9 LINKS TO THIRD PARTY WEBSITES
9.1 Our Website may contain links to websites and resources maintained by third
parties. These links are provided for your information only. We have no control over
the contents of those websites and resources, and accept no responsibility for them
or for any loss or damage that may arise from your use of them. We are not
responsible for the content, availability or privacy policies of those sites, and the
existence of such links should not be considered an endorsement or
recommendation of those sites or of any product or service offered on those sites or
of any party that is associated with those sites.
9.2 Please note that other websites and resources linked to on our Website may be
governed by separate terms and conditions, including privacy policies. You should
refer to the applicable terms and conditions of those websites and resources before
using them and you should direct any questions or comments about the linked
website or resource to the appropriate website provider.
10 LINKING TO OUR WEBSITE
10.1 You may link to our home page, provided you do so in a way that is fair and legal and
does not damage our reputation or take advantage of it, but you must not establish
a link in such a way as to suggest any form of association, approval or endorsement
on our part where none exists.
10.2 You must not establish a link from any website that is not owned by you.
10.3 Our Website must not be framed on any other website, nor may you create a link to
any part of our Website other than the home page. We reserve the right to
withdraw linking permission without notice.
10.4 If you wish to make any use of material on our Website other than that set out
above, please address your request to email@example.com
11 REVISION OF TERMS
expected to check this page from time to time to take notice of any changes we
make, as they are binding on you. Some of the provisions contained in these terms
of use may also be superseded by provisions or notices published elsewhere on our
12 JURISDICTION AND APPLICABLE LAW
12.1 The English courts will have non-exclusive jurisdiction over any claim arising from, or
related to, a visit to our Website. We retain the right to bring proceedings against
you for breach of these conditions in your country of residence or any other relevant
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them or their subject matter or formation (including non-contractual disputes or
claims) shall be governed by and construed in accordance with the law of England
not constitute a waiver of such rights or terms.
circumstance is held to be invalid or unenforceable to any extent, the remainder of
enforced to the fullest extent permitted by law.
the entire agreement between you and 1167 with regard to your use of our Website,
and any and all other written or oral agreements or understandings previously
existing between you and 1167 with respect to such use are superseded and
14 YOUR CONCERNS
14.1 If you have any concerns about any material which appears on our Website, please
1167 Capital LLP have been appointed investment manager and distributor for the ICAV. Please note that 1167 Capital LLP are hosting the documents of the ICAV (the “Fund Documents”) only, in the absence of the ICAV’s own website facilities. The publication of the Fund Documents is for informational purposes only. 1167 Capital LLP is not responsible for the content, accuracy, reliability or completeness of the Fund Documents. The Fund Documents are solely the responsibility of the ICAV and have not been published by 1167 Capital LLP.
The Fund Documents and this website of 1167 Capital LLP (the “Website”) are for information purposes only. Nothing contained therein constitutes or shall be deemed to constitute a financial, legal, tax or other advice of any kind and no information on the Website shall constitute or deem to constitute a solicitation or an offer to purchase, or invest in, any financial products which are listed or referred to on this Website. This Website is specifically not aimed at parties who are residents of any country where the ICAV is not registered or approved for marketing and/or sale or dissemination of information on the funds or services is not permitted. 1167 Capital LLP cannot make any representation or warranty of any nature, expressly or implicitly, about the Fund Documents. You should not rely solely on the information contained on the Website.