Please read these terms of use carefully before you start to use the Website. By using the Website, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using the Website.
Recipients of Communication
This Website is established by Altruid Systems Limited ("Altruid", "we" or "us") for and on behalf of various investment entities (the "Funds") for professional clients only and is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence, or otherwise) we would become subject to license or registration regulations of the jurisdiction, or the publication or availability of this Website is prohibited. Persons in respect of whom such prohibitions apply must not access this Website.
Risk Considerations
Past performance of the Funds described herein cannot be relied upon as a guide to future performance. No representation or warranty, express or implied, is made regarding future performance. Opinions and/or estimates reflect a judgement at the original date of publication and are subject to change without notice. The price, value, and income from any of the investments mentioned on this Website may fall as well as rise and we cannot guarantee that any capital invested will maintain or increase in value. Users of this Website should seek independent financial advice prior to making any investment decision and no information herein shall constitute general or specific investment, legal, tax, or accounting advice of any kind.
Accuracy of Information
No representation, warranty, or undertaking is given by us that the information contained on this Website is accurate, complete, comprehensive, or up to date, and no liability is accepted by us for such information. In particular, we shall not be obliged to remove any outdated information from this Website or to expressly mark it as outdated. In no event will we be liable to any person for any direct, indirect, special, or consequential damages arising out of any use of the information contained on this Website, or on any other hyper-linked website, including, without limitation, any lost profits, business interruption, loss of programs or data on your equipment, or otherwise, even if we are expressly advised of the possibility or likelihood of such damages. This does not exclude or restrict any duty or liability that we have under any regulatory system where to do so would breach law or regulation.
No Offer or Advice
Neither the information posted on nor any opinions contained within pages of this Website constitutes a public offer under any applicable legislation or an offer or solicitation or recommendation to buy or sell any securities or financial instruments, to effect any transactions, or to conclude any legal act of any kind whatsoever. If the information and opinions contained on this Website would be categorized as constituting a public offer under the legislation of the jurisdiction from which you wish to access the Website, you must not access the Website. The information included on this Website has been prepared for information purposes and does not constitute any financial, investment, legal, tax, or other advice or recommendation with respect to any securities or other financial instruments referred to herein, it is not tailored for any particular investor, and does not otherwise constitute, and may not be construed as, individual investment advice. You should obtain relevant and specific professional advice before making any investment decision.
General Selling Restrictions
Any Funds' shares have not been and will not be registered under the US Securities Act of 1933, as amended (the "US Securities Act") or any other applicable law of the United States. The Funds have not been registered under the US Investment Company Act of 1940, as amended. Shares in the Funds may not be offered, sold, transferred, distributed, or otherwise delivered directly or indirectly in the United States or to or for the account of any US Person (as defined in Regulation S under the US Securities Act). Subject to certain exceptions, the securities referred to herein and on the pages that follow may not be offered, sold, resold, taken up, exercised, renounced, transferred, delivered, or distributed, directly or indirectly, in Australia, Canada, or Japan or to any resident or citizen of Australia, Canada, or Japan. The offer and sale of the securities referred to herein and on the pages that follow have not been and will not be registered under the applicable securities laws of Australia, Canada, or Japan.
Important Information for Investors in the UK
In the UK, this Website is directed only at persons who (i) have professional experience in matters relating to investments who fall within Article 19(1) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 ("FPO"), (ii) are high-net-worth companies, unincorporated associations, etc. within Article 49 FPO, or (iii) are persons to whom it otherwise lawfully may be communicated. All persons who fall within the above categories are deemed "Relevant Persons". Any investment or investment activity to which this Website relates is available only to, and will be engaged in only with, Relevant Persons. Any person who is not a Relevant Person should not act or rely on this Website or any of its content.
Important Information for Investors in Switzerland
Persons who access information on this Website agree to the following terms and conditions: Any special agreements with respect to individual services or products shall be complementary to these terms and conditions, although in the event of any conflict, the provisions contained in any such special agreement shall prevail. The Funds mentioned on this Website have not been registered with the Swiss Financial Market Supervisory Authority FINMA as foreign collective investment schemes pursuant to Article 120 of the Swiss Collective Investment Schemes Act ("CISA"). Accordingly, the interests in the Funds may not be publicly offered in or from Switzerland, and no offering or marketing materials relating to the interests in the Funds may be made available through a public offering in or from Switzerland. The interests in the Funds may only be offered and any offering or marketing materials may only be distributed or otherwise made available, in or from Switzerland by way of private placements exclusively to qualified investors as such term is defined in the CISA and its implementing rules and regulations. Neither the contents of this Website nor any offering or marketing materials relating to the interests in the Funds have been or will be filed with, or approved by, any Swiss regulatory authority. The investor protection afforded to investors of interests in collective investment schemes under the CISA does not extend to acquirers of interests in the Funds. This Website does not represent a prospectus as defined in Article 652a or 1156 of the Swiss Code of Obligations.
Important Information for Investors in the European Economic Area
In the European Economic Area, the information on this Website is not to be issued or distributed to, nor directed at, persons other than "Qualified Investors" within the meaning of Article 3(2)(a) of Directive 2003/71/EC (the "Prospectus Directive"). The information contained on this Website must not be accessed by, acted on, or relied on by persons in the European Economic Area who are not Qualified Investors. Within the European Economic Area, any investment or investment activity to which the information on this Website relates is only available to Qualified Investors and will be engaged in only with Qualified Investors.
Important Information for Investors in Hong Kong
In Hong Kong, this Website is directed only at persons who qualify as "professional investors" as defined in the Securities and Futures Ordinance (the "SFO") and the Securities and Futures (Professional Investor) Rules made under the SFO. The information contained on this Website does not constitute an "offer to the public" within the meaning of the Companies Ordinance, and is not an advertisement, invitation, or document relating to any securities or collective investment schemes or any other investment under the SFO. None of the funds and/or products described on this Website has been authorized by any regulatory authority in Hong Kong. Any investment or investment activity to which this Website relates is available only to, and will be engaged in only with, professional investors. Any person who is not a professional investor should not act or rely on this Website or any of its content.
Copyright, Trademarks, and Other Rights
We and our associates own the copyright in the content of this Website, unless otherwise stated. Such information may not be reproduced, distributed, or transmitted to any other person or incorporated in any way into another database, document, or other materials without our written permission. Nothing on this Website should be considered as granting any license or right under any trademark of us, our associates, or any third party.
Jurisdiction
Use of this Website shall be governed in accordance with the laws of Malta and the courts of Malta shall have exclusive jurisdiction over any dispute arising out of your use of this Website.
Changes to the Website
The information on this Website, including these terms and conditions, are subject to change without notice. We have the right to suspend or withdraw the provision of all or any of the information on the Website without prior notice at any time. You agree to review these terms of use regularly and your continued use of the Website will mean you agree to any changes.
Severability of Provisions
Any provision of these terms of use that is prohibited or unenforceable in any jurisdiction is ineffective as to that jurisdiction to the extent of the prohibition or unenforceability. That does not invalidate the remaining provisions of these terms of use nor affect the validity or enforceability of that provision in another jurisdiction.
Indemnity
You shall be liable to us for any loss, liability, or cost we suffer as a result of your use of the Website or any breach of these terms. You agree to indemnify, defend, and hold harmless us and our agents, employees, and third-party sources from and against any and all suits, losses, claims, demands, liabilities, damages, costs, and expenses (including properly incurred attorneys' fees) that arise from or relate to: (a) your use of the Website; (b) your breach of these terms; or (c) your violation of any applicable law, statute, ordinance, regulation, or of any third-party's rights.
This statement describes how Altruid Systems Limited (“we”) processes your personal data.“Personal data” means any information relating to an identified or identifiable individual. It includes, for example, your name, your contact information, your date of birth, details from your passport, photographic or video images, communication records and, within the context of providing our services to you, any information we may be legally required to obtain from you in the context of our customer due diligence. We treat your personal data with care and in accordance with the applicable legislation, including the EU General Data Protection Regulation (GDPR). Keeping personal data secure is one of our most important responsibilities. We maintain physical, technical, electronic, procedural, and organizational safeguards and security measures to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access. Our employees are bound by internal policies that require confidential treatment of personal data.
Use of Our Website
When you use our website, various data is registered. For example, the type of connection, the browser used, your computer's operating system, your IP address and, when relevant, the details filled out on contact or other forms. Some of these data may contain personal data, as described below.
IP Address
When you visit our website, your IP address is saved automatically. Based on your IP address, information about the location from which the website is being visited can be obtained. Our website is maintained by an external service provider. This service provider has access to your IP address. We can obtain your IP address from the service provider upon our request. We have entered into a data processing agreement with the service provider. In case you wish to receive more information about this provider, please contact us. Our website is hosted at an external service provider. This provider has access to your IP address. We have entered into a data processing agreement with the service provider. If you wish to receive more information about the service provider, please contact us. The use of our website is monitored and analyzed. Your IP address is used to distinguish unique users and includes an indication of your location in the analysis. The analysis is available to us on an aggregated and/or anonymous basis only. For this analysis, Google's “Analytics” and services are used. This means Google may also have access to this data. Please refer to the paragraph “analytical cookies” for more information about these services.
Contact Form and Subscription for Updates
If you enter your name and contact details in the contact form designated for this purpose on our website, we will process your personal data to contact you and, if relevant, stay in contact with you and provide you with any information you may request (please refer to the paragraph “clients” or “other contacts” in such case). If you subscribe for our updates and newsletters through the designated form, we process your personal data for this purpose. We process your personal data based on your consent that you gave by filling out and sending the relevant form. You have the right to withdraw your consent and you can unsubscribe from our mailing list at any time. We will store your data until you withdraw your consent or as long as relevant to stay in contact with you.
Use of Cookies
A cookie is a file that is sent from a website and is saved by your browser to your computer's hard drive. Cookies are used by us to store data linked to the use of our website. These data can be read and written by us when you visit our website. You will find further information regarding how to switch cookies on or off or delete or prevent them in the instructions of your browser's Help function. Our website uses the following cookies:
Functional Cookies
Functional cookies are used to ensure that the website works properly. Our website uses both session cookies and permanent cookies. Permanent cookies are saved for a longer period. Session cookies are deleted when you close your browser. Cookies enable us to recognize you when you return to our website. This enables the website to tailor the user experience to your preferences. For instance, cookies are used to record that you gave your permission for the placement of cookies and to record your language preference. This means that you do not have to re-enter your preferences on each visit. You may delete the cookies via your browser settings or other tools at any time.
Analytical Cookies
Analytical cookies allow us to analyze the use of our website. This allows us to improve the website so your visit is more enjoyable and you can access the information you are looking for more easily. These cookies are used to collect data on, for example, the number of visitors, or the most popular pages and subjects. Google's “Analytics” service is used for this purpose.
Google Analytics
A Google cookie is placed via our website as part of Google's “Analytics” service. We use this service to monitor how users use the website and generate relevant reports. Google may share this data with third parties if it is legally required to do so, or insofar as this data is processed by third parties on behalf of Google. We do not have any influence on this process. We have not permitted Google to use the Analytics data obtained for other Google services. The data collected by Google is anonymized as far as possible before it is processed by Google and provided to us. Your IP address is partially masked and is not processed in its entirety. We have a data processing agreement with Google in place. The data is transferred to Google and saved to their servers in the United States. Google has committed to the Privacy Shield principles and adheres to the Privacy Shield program of the US Department of Commerce. This means that a certain level of protection is applied to the processing of any personal data. We do not use any other Google services in combination with the “Analytics” cookies.
Hyperlinks
Our website may contain hyperlinks to websites of third parties. By clicking on a hyperlink, you will be directed to an external website. Such external website may use cookies. Please refer to the privacy or cookie policy of such website to find out more about its use of cookies and the processing of any personal data.
LinkedIn Application
The website integrates components of the LinkedIn Corporation. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
Processing of Personal Data
The paragraphs below describe the processing of personal data by us, other than through the use of our website.
Clients and Potential Clients
We process data of private and institutional clients and potential clients, including personal data of contact persons, employees, directors, representatives, shareholders, ultimate beneficial owners, and other associated persons (“Investors”, “potential Investors”, or, within this paragraph, “you”).
Investor Information
We may process your personal details, such as your name, gender, business contact details, title or position, and any other information you have provided to us during our conversations, meetings, by e-mail, or by any other means. We store this information in an in-house developed contact management system and e-mails received are stored in personal e-mail boxes. We process this data to maintain contact with you, to provide you with our services, to maintain and optimize the quality of our services and our relationship with you, to provide you with relevant information about your investment(s) or planned investment(s) to provide you with updates and newsletters about us and our services, to provide you with any other information that may be of interest to you and to verify any agreements made with you. Pursuant to anti-money laundering and counterterrorist financing legislation as well as know-your-customer legislation applicable to us, we have to conduct customer due diligence before we provide our services to Investors and periodically afterwards during our relationship with Investors. We collect data from our Investors directly, indirectly, or through a world-check database, sanction lists, or publicly accessible sources. Failure to provide certain requested data may result in the impossibility to invest or stay invested with us. Information gathered in context of our customer due diligence include personal data, such as your full name, place and date of birth, a copy of your passport, information about your regulatory listings, information about investigations or sanctions you are or may have been subject to, and information in relation to the source of wealth of Investors. Personal data may also be included in promotional material, certificates, any other know-your-customer and anti-money laundering related information we need to obtain from you and in documents we process for the purpose of recording and verifying our agreements with Investors, such as authorized signatories lists, contracts, and related documents. We process your data because this is necessary for compliance with legal obligations to which we are subject, or with our legitimate interest, each as described above. When we provide you with newsletters and updates, this may be based on your consent. You have the right to withdraw your consent at any time and you can unsubscribe from our quote distribution mailing list at any time. We will store your personal data as long as relevant within the context of our relationship. Personal data gathered pursuant to our customer due diligence will be kept on file for at least five years after termination of our relationship. If retention is necessary for the effective implementation of internal measures for the prevention or detection of money laundering or terrorist financing, the files will be kept on file for up to an additional five years. Personal data contained in contracts and related documents will be kept on file as long as necessary to exercise or defend actual or potential legal claims. Any data may be archived or backed up. Please refer to the paragraphs below for information about the recording of communications, the visiting of our premises, and the transfer of data to third parties.
Other Contacts
We may process personal data of our potential service providers, current service providers of our clients, suppliers, other contacts and, where applicable, any of their representatives and employees. Personal details may include your name, gender, contact details, title or position, and any other information you may have provided us during our conversations, meetings, by e-mail, or by any other means. Personal data may also be included in any materials provided to us, and in documents, such as contracts and authorized signatories lists. We may store your personal details in an in-house developed contact management system. We process your personal details data to maintain contact with you, for example in order to use your services, purchase your products or to service clients, and for relationship management purposes. Emails, contracts, and related documents are stored to be able to verify any agreements made with you or your company. Upon your request, we may also use your contact details to provide you with updates and newsletters about us and our services. We process your personal data based on the legitimate interest we have. Processing may also be required for the performance of a contract with you. When we send you newsletters or updates this may be based on your consent. You have the right to withdraw your consent and you can unsubscribe from our mailing list at any time. We will store your personal data as long as relevant within the context of our relationship. Contracts and related documents will be kept on as long as necessary to exercise or defend actual or potential legal claims. Any data may be archived or backed up.
Recording of Communications
We may record communications, including telephone conversations or communications by any other means. We record several of our telephone lines, including those of our traders and our Investor Relations team. We do this to comply with a legal obligation. Pursuant to applicable regulation, we have to record communications that, among others, result in transactions. Communications are also recorded with the legitimate interest for record keeping as proof of a transaction or related communication in the event of a disagreement, for verification of agreements or instructions, and for investigation and fraud prevention purposes. Communication records will be retained for a period of five years or, upon request of a regulator, for a period of seven years starting from the date of the recording. Communication records other than telephone recordings may be archived or backed up as well.
Visiting Our Premises
Video images are obtained from visitors inside and outside of our premises by security cameras. We process these data with the legitimate interest to secure our premises and the safety of our employees and visitors. Access cannot be granted without processing this data. Recordings of security cameras will be kept either for a maximum of four weeks after the recording or until after an identified incident has received adequate follow-up.
Transfers to Third Parties
In addition to what is described above in relation to specific data transfers, we may also share data with our affiliates, professional advisors, and auditors to the extent required. Any such party will be subject to obligations of confidentiality. Where possible and appropriate, any personal data transferred will be anonymized. We may also have to transfer data to any court, governmental, tax, or supervisory authorities, at the authorized request of a regulator, when this may be required pursuant to applicable regulations or pursuant to any court order. Should this be the case, we will use reasonable endeavors to notify you in advance of such transfer, to the extent we are allowed to do so. We may need to transfer personal data to parties that are located in countries outside of the European Economic Area (EEA) that are not recognized to provide an adequate level of data protection according to EEA standards. We will adopt safeguards to ensure an appropriate level of protection of your personal data. In particular, we may transfer personal data to affiliates with offices around the world. For this purpose, we have entered into an inter-affiliate data transfer agreement in which we have included standard EU clauses regarding the protection of personal data.
Request Related to Personal Data
You can contact us if you have any of the following requests: Access to your personal data. If you wish, we can provide you with an overview of your personal data processed by us. Rectification: you can request us to rectify any inaccurate personal data. Erasure: you can request us to erase any personal data that we hold of you. Restriction of processing: in certain circumstances, you may request us to restrict the processing of your personal data. Data portability: in certain circumstances, you can request us to provide you, in a structured, commonly used and machine-readable format, with the personal data that you provided to us earlier. You can request us to transmit this data to another party. In principle, we will meet any of the above requests. Please note, however, that there may be circumstances in which we will not be able to do so. For example, we are not allowed to erase any information which we are legally required to retain, e.g. for recordkeeping purposes. There may also be residual information that will remain within our databases and other records, which cannot be removed. If you have any of the abovementioned requests, please contact us at support@altruid.com or +356 270 40 416. We will respond to your request as soon as possible, but at least within 30 business days. To prevent abuse, we may ask you to adequately identify yourself.
Complaints
If you have a complaint about our processing of your personal data, please do not hesitate to share this complaint with us. You may also lodge a complaint with the competent authority of your home EU member state.
Amendments
This privacy statement may be amended from time to time, without notifying you personally. The date of the latest amendment is 20 May 2018. Use of our services following these changes, or your continued provision of personal data to us, signifies acceptance of the revised statement.
Contact
If you have any questions about this privacy statement, please contact us at support@altruid.com or +356 270 40 416. You may also contact us through your usual contact person.
