Privacy Policy

Privacy Policy

Avery Row Capital (“Avery Row” or “We”) are committed to protecting and respecting your privacy. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in compliance with the EU General Data Protection Regulation (“GDPR”)1. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting http://www.averyrow.com you are accepting and consenting to the practices described in this policy.

For the purpose of GDPR the data controller is Avery Row Capital Partners LLP (“ARC LLP”) an affiliate of Avery Row.

Why do we collect information about you?

Avery Row may use such personal information for the purposes of administering the relationship between us, marketing of products and services, monitoring and analysing our activities, and complying with any legal or regulatory requirements. We will use one of the permitted grounds under GDPR to collect your information. Such rights include circumstances where you have given your consent and instances where your consent is not required, such as where we are required to comply with a legal obligation, or where we or a third-party has a legitimate interest to collect personal information.

Information we may collect from you

Avery Row may collect and process the following data about you:

  • • Information you give us. You may give us information about you by filling in forms on our site http://www.averyrow.com (“our site”) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial information, personal description and employment information.
  • Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
  • Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

Cookies

This website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the site.

What are cookies & how do we use them?
o to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

This website uses the following cookies:

Cookie Name Purpose
Google Analytics Collects information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
rememberMe346 A cookie to remember if you have agreed to the Terms & Conditions

How do I manage cookies?
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Uses made of information

We use information held about you in the following ways:

  • Information you give to us. We will use this information:
    • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
    • to to notify you about changes to our service;
    • to to ensure that content from our site is presented in the most effective manner for you and for your computer.
  • Information we collect about you. We will use this information:
    • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
    • to allow you to participate in interactive features of our service, when you choose to do so;
    • as part of our efforts to keep our site safe and secure;
    • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
    • to ensure that we comply with our legal and regulatory obligations in the jurisdictions that we operate
  • Information we receive from other sources.
    • We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 and any other affiliate member. We may share your information with selected third parties including:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.
  • Any other party that you inform us about
  • Our website internet service provider where required
  • Regulators, courts of law, governmental or law enforcement agencies, including the police where required, requested by or permitted to do so, or in connection with legal proceedings
  • Any person if we determine it is necessary or desirable to comply with any law or to protect or defend our rights or property
  • Any person to whom we have a right or duty to disclose personal data. For example, if we are required to provide certain transaction information to authorities or other official bodies to assist in the prevention of terrorism, money laundering and other crimes
  • Credit reference agencies or other third-parties acting as our agents in order to help us identify a client or confirm your contact details
  • Consultants such as for marketing analysis purposes
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Avery Row, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Avery Row will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have certain rights in respect of the personal data we hold about you and which you may exercise in accordance with GDPR. These rights are, generally:

  • the right to request access to your information
  • the right to request rectification of your information
  • the right to request erasure of your information
  • the right to restrict the processing or use of your information
  • the right to object to the processing or use of your information
  • where relevant, the right to request the portability of your information
  • where relevant, the right to withdraw your consent at any time
  • the right to lodge a complaint with a competent supervisory authority.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at info@averyrow.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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. Please check these policies before you submit any personal data to these websites.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

Changes to our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@averyrow.com.

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1 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Avery Row Capital
Building Partnerships and Creating Value

 

Important Information

This website is provided by Avery Row Capital (“Avery Row”). Avery Row Capital LP is registered as an Excluded Person under Section 5(2) and Schedule 4 of the Securities Investment Business Law (2015 revision) of the Cayman Islands Monetary Authority. Avery Row Capital Limited is licensed by the Guernsey Financial Services Commission. Avery Row Capital Partners LLP is authorised and regulated by the Financial Conduct Authority (FRN: 756430). Avery Row Capital Partners LP, Avery Row Capital Limited and Avery Row Capital Partners LLP and are all wholly owned affiliates of Avery Row.

Intended Recipients. This website is not directed at, or intended for use by, any person in any jurisdiction or country where such communication or use would be contrary to local law or regulation. In the United Kingdom, this website is directed only at persons who are: (i) investment professionals within the meaning of Article 19 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (“FP Order”) or Article 14 of the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (“PCIS Order”), as applicable; (ii) high net worth companies and certain other entities falling within Article 49 of the FP Order or Article 22 of the PCIS Order; or (iii) any other persons to whom such communication may lawfully be made. It must not be used, or relied upon, by any other persons.

The website is not intended for the account of U.S. persons (as defined in Regulation S under the United States Securities Act of 1933, as amended (the “Securities Act”)) other than persons who are “qualified purchasers” (as defined in the United States Investment Company Act of 1940, as amended) and/or “accredited investors” (as defined in Rule 501(a) under the Securities Act).

No Offer or Solicitation. This website is not intended and must not be construed as an offer or solicitation to purchase, or an offer to sell, shares of any fund or another investment product referenced on this website (“Investment”) in any jurisdiction. In particular, this website is not intended as marketing of any alternative investment fund in any member state of the European Economic Area for the purposes of the EU Directive 2011/61/EU on Alternative Investment Fund Managers. Any offer of Investment will only be made on the basis of the prospectus or offering memorandum relating to any such Investment.

Third Party Websites. Any links to third party websites are provided solely for your convenience and do not constitute any endorsement, sponsorship or approval of the materials appearing in such sites. Avery Row accepts no responsibility for the content of such third-party websites.