High-conviction investing in real estate & digital infrastructure

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Dromeus Capital Group Privacy Notice

Privacy Notice

Dromeus Capital Management (UK) Limited is a company registered in England and Wales with company number 09459348. Dromeus Capital Management (UK) Limited is authorised and regulated by the Financial Conduct Authority (“FCA”) with Firm Reference Number 679041.

For the purposes of the General Data Protection Regulation (‘GDPR’), Dromeus Capital Management (UK) Limited will be the ‘controller’ of the personal data you provide. Please read the following information carefully in order to understand the Firm’s practices in relation to the treatment of your personal data. Should you have any questions, please email us at info@dromeuscapital.com .

What data privacy principles does the Firm adhere to?

• The Firm will process all personal data in a lawfully, fair and transparent manner;
• The Firm will only collect personal data where it is necessary;
• For the Firm to provide a service to you;
• For you to provide a service to the Firm;
• For the Firm to keep you informed of its products and services; or
• For the Firm to comply with its legal and regulatory obligations.
• The personal data collected by the Firm will be adequate, relevant and limited to what is necessary in relation to the specific purpose for which your data will be processed;
• The Firm will take all reasonable steps to ensure that personal data is accurate and, were necessary, kept up-to-date;
• The Firm will maintain personal data in a form that permits identification no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with the Firm’s record retention requirements as mandated by the Financial Conduct Authority;
• The Firm will hold and process person data in a manner that ensures appropriate security;
• The Firm will only share personal data where it is necessary to provide the agreed service or where it is necessary for the Firm to comply with its legal and regulatory requirements.
• The Firm will only utilise a service provider based outside of the EEA for the processing of personal data where this is strictly necessary to facilitate our services to you. In all cases, we will ensure service providers are fully compliant with GDPR ahead of transferring any personal data.

What personal data does the Firm collect and why?

In the course of providing products/services to you, the Firm may collect information that is considered personal information (e.g. name, contact details, address, passport number, driving licence).

As a client, contact or employee of Dromeus Capital Management (UK) Limited, we will require some personal information in order to verify your identity and have the applicable relationship with you. Some of this information may be required to satisfy legal obligations (e.g. to comply with obligations arising under the money laundering regulations whereas other information may be required in connection with the provision of services to you). The information collected will vary depending on the service the Firm provides to you or you provide to the Firm, but typically includes:

Where does the Firm store my personal data?

The Firm has comprehensive policies and procedures in place to ensure your personal data is kept sage and secure, with these including:

• Data encryption;
• Firewalls;
• Intrusion detection;
• 24/7 physical protection of the facilities where your data is stored (i.e. Microsoft’s UK data centres);
• Background checks for personnel that access physical facilities; and
• Security procedures across all service operations.

How long does the Firm retain personal data?

As a regulated entity, the Firm is required to maintain its books and records for a prescribed period (five years from either the ceasing of a business relationship, or, in the case of non-clients, from the making of a record – or alternatively, for seven years, where specifically requested to do so by the Financial Conduct Authority). As such, information that falls in scope of either of these requirements is retained in line with the mandated timeframe. 

Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.

What are my rights?

Once you have provided your details to the Firm, you have certain rights which apply, depending on your relationship with the Firm, the information you have shared with us and the Firm’s legal and regulatory obligations.

You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email the Firm at EMAIL. The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.
You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.
As a client, you have the right to request that any information the Firm holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as ‘data portability’.
You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact info@dromeuscapital.com.

You have the right to object to your information being processed, for example for direct marketing purposes.
You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
You have the right to object to any decisions based on the automated processing of your personal data, including profiling. 
You have the right to lodge a complaint with the Information Commissioner’s Office if you feel that we have not processed your data in accordance with GDPR, any contractual agreements or this privacy notice.

Dromeus Capital Group Legal Disclaimer

All persons using the Dromeus Capital Group website (the "Website") expressly agree to the foregoing disclaimer as a pre-condition to using this Website for any purpose whatsoever. The materials on the Website including, without limitation, news articles, informational materials and all other manager-specific information, have been prepared for informational purposes only and do not constitute financial, legal, tax or any other advice. All information contained herein is provided "as is" and Dromeus Capital Group expressly disclaims making any express or implied warranties with respect to the fitness of the information contained herein for any particular usage, its merchantability or its application or purpose. Prior to making any investment or hiring any investment manager you should consult with a professional financial advisor, legal and tax advisor to assist in due diligence as may be appropriate and determining the appropriateness of the risk associated with a particular investment. In no event shall Dromeus Capital Group be responsible or liable for the correctness of any such material or for any damage or lost opportunities resulting from use of this data.

By accessing the password-protected area of this site, you agree not to invest in any posted hedge fund or alternative investment vehicle (other than hedge funds or alternative investment vehicles in which you or your affiliates are already invested, have already been solicited for or are already actively considering an investment in) for thirty (30) days after the approval of your application. Dromeus Capital Group reserves the right to terminate, at any time, any registered user's account with Dromeus Capital Group (as well as access to the latter's website), without giving notice or a reason for such termination to the user.

Additionally, by accessing the password-protected area of this Website , you agree to immediately contact Dromeus Capital Group if there is any change in your status as an "accredited investor" under Regulation D promulgated under Securities Act of 1933. For individuals such changes may include, for example, a registered user's net worth declining below $1,000,000, an expectation that income for the next twelve months may total less than $200,000, or an expectation that the registered user's combined income with his or her spouse may total less than $300,000 in the next twelve months

All registered users, including individuals and entities, should communicate with their legal advisors if they believe that their status as an accredited investor has changed. If a registered user's status as an accredited investor has changed, such registered user agrees to immediately notify Dromeus Capital Group of such change. Nothing in this Site may be considered as an offer or solicitation to purchase or sell securities or other services. If any provision in this Disclaimer Agreement is held to be invalid or unenforceable, then the remaining provisions shall continue in full force and effect.

Users of the Dromeus Capital Group website may view, download and print information and materials on this Website for its personal and internal business use provided that all hard copies contain all copyright and other applicable notices. All users may not reproduce, modify, copy, alter in any way, distribute, sell, resell, transmit, transfer, license, assign or publish any information obtained from this Site. Registered User shall not use this Website at any time for any purpose that is unlawful or prohibited and shall comply with any applicable local, state, national or international laws or regulations when using this Site.

Dromeus Capital Group, and the logos and marks included on the Dromeus Capital Group site that identify Dromeus Capital Group services and products are proprietary materials. The use of such terms and logos and marks without the express written consent of Dromeus Capital Group is strictly prohibited. Copyright in the pages and in the screens of the Site, and in the information and material therein, is proprietary material owned by Dromeus Capital Group unless otherwise indicated. The unauthorized use of any material on the Dromeus Capital Group website may violate numerous statutes, regulations and laws, including, but not limited to, copyright, trademark, trade secret or patent laws.

Dromeus Capital Management (UK) Ltd is regulated by the Financial Conduct Authority – Reg No 679041.