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DISCLAIMER (U.S.)Last updated 13th March 2018

This website is issued and approved by Lofoten Asset Management Limited (LAM), authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom with registration number 501341. LAM is also a registered investment adviser with the Securities and Exchange Commission of the United States.

When accessing any information or material made available on this website you accept and agree to comply with the terms and conditions as set out below.

No Solicitation

The information on this website is provided to you for informational purposes only. It should not be regarded as an offer or solicitation of an offer to buy or sell any investments or related services that may be referenced on this website.

Accredited Investor and Qualified Purchaser Status

Any information or materials contained on this website are only directed at professional investors or/and US persons (as defined in Regulation S under the U.S. Securities Act of 1933, as amended (“Securities Act”) who are “accredited investors” as defined in Regulation D under the Securities Act and “qualified purchasers” as used in Section 3(c)(7) of the U.S. Investment Company Act of 1940, as amended.

Risk Warning

Investors should consider carefully all specific risks of the products described in this website carefully prior to making an investment. Some general risks to consider include: Past performance of an investment is not a guide to any future performance; the value of investments and any income generated may go down as well as up and is not guaranteed; changes in exchange rates may have an adverse effect on the value, price or income of investments.
Some funds e.g. investment trusts have the ability to borrow money in order to make further investments. This is known as “gearing” and can improve returns of an investment in rising markets but can reduce returns in falling markets. Shares in investment trusts can fluctuate in accordance with demand and supply and may not reflect the underlying net asset value of the shares. Depending on market conditions, the spread between a purchase and sale price can vary widely.

Nothing in this site constitutes any investment, legal, tax and other advice and it is not to be relied upon in making any investment decision. If you are unsure about the meaning of any information in this website you should consult your financial or other professional adviser.

Accuracy of Information

The content of this site is based upon sources of information believed to be reliable, however, save to the extent required by applicable law or regulations, no guarantee, warranty or representation (express or implied) is given to its accuracy or completeness. No responsibility or liability can be accepted for any errors or omissions or for any loss resulting from the use of any materials contained in this site. LAM reserves the right to amend, alter or withdraw any of the information in the site at any time without notice. No liability is accepted for such changes or for pages not being available at all times.

Linked/External Websites

This website may contain links to other websites maintained by third parties over whom LAM has no control. LAM and its employees take no responsibility for approving, screening or reviewing the contents of the linked websites and should not be regarded as an endorsement of the service or the site. LAM makes no representations as to the accuracy, legality or any other aspect of information contained in the linked or other websites. You use such links at your own risk.

Privacy & Cookies

All information provided to LAM through this site is used solely by LAM, its affiliates and employees only. By using this website please be aware that information we hold about you may be disclosed to any regulatory authority to which LAM is subject, or to any person legally empowered to require such information.

When you browse the website we use cookies to allow our site to remember your preferences and whether you accept our terms of use. We do not use cookies that provide information to advertising networks or those who track your activity across multiple sites. By continuing to use this site users will be deemed to have accepted this policy and the use of cookies for these limited purposes only. Further details of our privacy and cookies policy can be found on our Privacy page.

Copyright

The information contained on this site is subject to copyright with all rights reserved. Under no circumstances should any information be copied, reproduced or redistributed without express prior written consent from LAM

Law

This web site is governed by the laws of England.

I HAVE READ, UNDERSTOOD AND AGREE TO THE DISCLAIMER NOTICE ABOVE.

Institutional Investors & Consultants – United Kingdom

Important Legal Information: By clicking “I agree,” the user agrees that I have read the terms detailed below and confirm that I am an investment professional as that term is defined in the Handbook of the Financial Conduct Authority (“FCA”) or that I am acting for an investment professional.

Information contained on this Web site is not intended for investors in any jurisdiction in which distribution of the information or purchase is not authorized or permitted.

This communication is approved by Lofoten Asset Management Limited which is authorised and regulated by the Financial Conduct Authority. Any investments or investment services mentioned on this communication are not intended for retail customers. Consequently, this communication is only made available to professional investors and eligible counterparties and should not be relied upon by any person that does not possess professional experience in relation to investments. If you are in any doubt as to whether you possess suitable experience in relation to investing
please consult your financial adviser. Under no circumstances should this document be forwarded to anyone in the United Kingdom who is not a professional client or eligible counterparty as defined by the FCA.

With investment, your capital is at risk and the value of an investment and the income from it can go up as well as down, it may be affected by exchange rate variations and you may not get back the amount invested. Past performance is not necessarily a guide to future performance and where past performance is quoted gross then investment management charges as well as transaction charges should be taken into consideration, as these will affect your returns.
Any tax allowances or thresholds mentioned are based on personal circumstances and current legislation, which is subject to change.

We do not represent that this information, including any third party information, is accurate or complete and it should not be relied upon as such. Opinions expressed herein reflect the opinion of Lofoten Asset Management Limited and are subject to change without notice. No part of this document may be reproduced in any manner without the written permission of Lofoten Asset Management Limited; however recipients may pass on this document but only to others falling within this category. This information should be read in conjunction with the relevant fund documentation which may include the fund’s prospectus, simplified prospectus or supplement documentation and if you are unsure if any of the products and portfolios featured are the right choice for you, please seek independent financial advice provided by regulated third parties.

Cookie Policy

This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies.

Privacy Policy - Lofoten Asset Management

Privacy Policy

Introduction

Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Lofoten Asset Management Ltd (“Lofoten”) including any Funds to which it is an adviser or manager, where relevant, (“we” or “us”) and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to you and or where you may be a current, prospective and / or former investors to a Fund. This Privacy Notice is being provided in accordance with the requirements of data privacy laws, including the EU General Data Protection Regulation 2016/679 (“GDPR”), and any other law relating to privacy or the processing of personal data and any statutory instrument, order, rule or regulation implemented thereunder, each as applicable to us.  References to “you” or an “investor” in this Privacy Notice means any individual or investor, or any individual or investor connected with you who is a legal person (each such individual, a “data subject”), as applicable.

Identity and contact details of Data Controller

For the purposes of the GDPR, Lofoten is the controller of your data. If you have any queries regarding this policy or complaints about our use of your data, please contact us at the address below and we will do our best to deal with your complaint or query as soon as possible.

 

The types of personal data we may collect and use

The categories of personal data we may collect include names, residential addresses or other contact details, signature, nationality, place of birth, tax identification number, date of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds details or other sensitive information, such as certain special categories of data contained in the relevant materials or documents.

How we collect personal data

We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us; (iii) information that you provide to us through using our web-site by filling in forms on our site; and (iv) recording and monitoring of telephone conversations and electronic communications with you as described below.

We also may receive your personal information from third parties or other sources, such as our affiliates, the Administrator, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

The Website and Cookies

Where applicable, our website may contain links to other websites of interest. However, if you use one of these links to leave our Website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting a linked website and such websites are not governed by this Policy. You should always exercise caution and review the privacy policy applicable to the website in question.

A cookie is a small file which asks permission to be placed on your computer. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular website. Cookies allow web applications to respond to you as an individual.

The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our Website by tailoring it to the needs of users. We only use this information for statistical analysis purposes.

Overall, cookies help us provide a better Website by enabling us to monitor which pages users find useful and which they don’t. A cookie does not give us access to a user’s computer or any information about them, other than the data they choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, this may prevent you from taking full advantage of this Website.

For further details on cookies and how to manage them, we recommend that you visit the All About Cookies website.

Using your personal data: the legal basis and purposes

We may process your personal data for the purposes of administering the relationship between you and us (including communications and reporting), direct marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities with competent jurisdiction over our business). Your personal data will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so.

Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in your subscription in the applicable Fund being rejected or compulsorily redeemed or withdrawn, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

Exceptionally we may be requested or required to disclose to (for example) the Financial Conduct Authority details about you and the services we provide. As such, our disclosure of your personal data to us is on the legal basis of our performance of our compliance with a legal obligation or our legitimate interest in so doing.

How we may share your personal data

We may disclose information about you to our affiliates or third parties, including the Administrator, the Prime Broker and Custodians and the executing brokers and trading counterparties (where relevant) for our everyday business purposes, such as to facilitate transactions, maintain your account(s) or respond to court orders and legal investigations. It may also be necessary, under anti-money laundering and similar laws, to disclose information about the Fund’s investors in order to accept subscriptions from them or to facilitate the establishment of trading relationships for the Funds with executing brokers or other trading counterparties. We will also release information about you if you direct us to do so.

We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us as described below (see “Who to contact about this Privacy Notice“).  We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes.

We do not share your information with non-affiliates for them to market to you.

Monitoring of communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.

Retention periods and security measures

We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Law. Personal data will be retained for a minimum period of five to seven years after the termination of our relationship, and we may retain personal data for a longer period for marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

To protect your personal information from unauthorised access and use, we apply organisational and technical security measures in accordance with Data Protection Law. These measures include computer safeguards and secured files and buildings. We will notify you of any material personal data breaches affecting you in accordance with the requirements of Data Protection Law.

International transfers

Because of the international nature of a fund management business, personal data may be transferred to countries outside the EEA (“Third Countries”), such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the Data Protection Law in the EEA. In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of the Data Protection Law, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries.

Your rights under Data Protection Law

You have certain rights under GDPR in relation to our processing of your personal data and these are, generally: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of direct marketing activities); (vi) where relevant, the right to request the portability; (vii) where your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. You should note that your right to be forgotten that applies in certain circumstances under GDPR is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above.

You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account.

Complaining to supervisory authorities

A complaint in respect of Lofoten may be made to the Information Commissioner’s Office in the United Kingdom.

Who to contact about this Privacy Notice

If you have any queries regarding this policy or complaints about our use of your data, please contact us at the address below and we will do our best to deal with your complaint or query as soon as possible.

Lofoten Asset Management Ltd

Claridge House

32 Davies Street

London.  W1K 4ND

UK

 

For more specific information or requests in relation to the processing of personal data by the Administrator, the Prime Broker and Custodians or any other service provider of the Funds (where relevant), you may also contact the relevant service provider directly at the address specified in the directory section of the relevant memorandum or by visiting their websites.