The information contained on this website (the “Site”) does not constitute or form part
of any offer for sale or subscription of or solicitation or invitation of any offer to buy or
subscribe for any securities nor shall it or any part of it form the basis of or be relied
on in connection with any contract or commitment whatsoever.
None of the information contained on the Site constitutes a recommendation,
solicitation or offer by Tangency Capital Ltd. or Tangency Capital Services Ltd.
(together, “Tangency”) or its affiliates to buy or sell any securities, futures, options or
other financial instruments or provide any investment advice or service.
The information contained on this Site has been prepared without reference to any
particular user’s investment requirements or financial situation. Certain transactions
give rise to substantial risk and are not suitable for all investors. Tangency will not act
for you (or any other investor) and will not be responsible to you for providing
protections afforded to the clients of Tangency’s investment services. Without
prejudice to the generality of the foregoing, Tangency does not provide any
investment service to you (including, without limitation, the provision of investment
advice, or the reception and transmission of orders). The Site is not, and must not be
treated as, investment advice, investment recommendations, or investment
research. Users of the Site must not take (or refrain from taking) any investment
decision on the basis of the information set out in the Site.
Prior to the execution of any transaction by you involving information you received
from this Site, you should consult your business advisor, attorney and tax and
accounting advisors with respect to the price, suitability, value, risk or other aspects
of any stock, mutual fund, security or other investment. Tangency accepts no duty of
care to you in relation to investments.
Pricing and other information generated through the use of data or services made
available herein may not reflect actual prices or values that would be available in the
market at the time provided or at the time that the user may want to purchase or sell
a particular security or other instrument. The information and services provided on
this Site are not provided to and may not be used by any person or entity in any
jurisdiction where the provision or use thereof would be contrary to applicable laws,
rules or regulations of any governmental authority or regulatory or self-regulatory
organization or clearing organization or where Tangency is not authorized to provide
such information or services. Some products and services described in this Site may
not be available in all jurisdictions or to all clients.
The information contained on this Site should not be construed as either projections
or predictions. Tangency makes no representation or warranty, express or implied,
except as required by law or in the case of fraud, regarding the accuracy,
completeness or adequacy of the information. Past performance cannot be relied on
as a guide to future performance.
Notice for persons in the United Kingdom
This Site may be accessed in the United Kingdom by only persons to or at whom it
may lawfully be issued or directed under the Financial Services and Markets Act
2000 (Financial Promotion) Order 2005 including persons who are authorised under
the Financial Services and Markets Act 2000 (“FSMA”), certain persons having
professional experience in matters relating to investments, high net worth
companies, high net worth unincorporated associations or partnerships, or trustees
of high value trusts or persons who qualify as certified sophisticated investors. This
Site is only available to such persons in the United Kingdom and this Site must not
be relied or acted upon by any other persons in the United Kingdom.
Notice for persons in other jurisdictions
Access of this Site may be further restricted by law. Accordingly, this Site may not be
accessed in any jurisdiction except under circumstances that will result in
compliance with any applicable laws and regulations. Persons who access this Site
should inform themselves about and observe any such restrictions. Any failure to
comply with these restrictions may constitute a violation of applicable securities law.
Tangency Capital Ltd. is incorporated in Bermuda and its registered office is Wessex
House, 3rd Floor, 45 Reid Street, Hamilton, HM12, Bermuda. Tangency Capital
Services Ltd. is a wholly owned subsidiary of Tangency Capital Ltd., incorporated
under the laws of England and Wales, and its registered office is 125 Old Broad
Street, London EC2N 1AR, United Kingdom. References to “Management Entity”,
“we”, “us” and “our” are references to Tangency Capital Ltd. and/or Tangency
Capital Services Ltd.
read the Agreement carefully. By using or accessing this Site, you agree to be bound
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The Site may contain links to other websites owned and operated by third parties.
We are not responsible for and have no liability to you in relation to the availability,
accuracy, or completeness of any material contained in the linked websites.
This Site contains general information about our products and services and its
contents are not intended to constitute investment or any other advice (nor any
solicitation to participate in investment or other business) in any country in the world.
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Disclaimer of warranties
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communication obtained through use of this Site. We shall not be liable for the
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information obtained through use of this Site.
Limitation of liability
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data, however caused, arising in connection with the use of or inability to use this
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own discretion and at any time, suspend or terminate your access to or use of this
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enforce any rights or provisions of this Agreement does not constitute a waiver of
such rights or provisions. This Agreement is governed by and construed in
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you consent to the non-exclusive jurisdiction of the Bermuda courts.
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About this privacy notice
We are a data controller in respect of your personal data for the purposes of data
protection law, such as, in the European Union (“EU”), the General Data Protection
Regulation and, in the United Kingdom (“UK”), the Data Protection Act 2018 (“DPA”)
and the UK GDPR (as defined in the DPA). We are responsible for ensuring that we
use your personal data in compliance with data protection law.
This privacy notice applies to you if you are a client or prospective client of the
Management Entity (including an investor or prospective investor in a vehicle or
entity that we manage or advise (“Funds”)), a service provider to us or to a Fund.
This privacy notice sets out the basis on which personal data about you that you
provide to us, that we create about you or that we obtain about you from other
sources, will be processed by us. Please take the time to read and understand this
Personal data that we might use
We might process the following personal data about you:
(a) information provided to the Management Entity or to a Fund or its
administrator by you or (if different) the applicant for interests in a Fund: this might
include your name and address (including proofs of name and address), contact
details, date of birth, gender, nationality, photograph, signature, copies of identity
documents, occupational history, job title, income, assets, other financial information,
bank details, investment history, tax residency and tax identification information.
Such information might be provided in an application form or in other documents (as
part of an application process or at other times), face-to-face, by telephone, by email
(b) information that the Management Entity collects or generates: this might
include information relating to your (or an applicant’s) investment in a Fund, emails
(and related data), call recordings and website usage data.
(c) information that the Management Entity obtains from other sources: this might
include information obtained for the purpose of our know-your-client procedures
(which include anti-money laundering procedures, counter-terrorist financing
procedures, politically-exposed-person checks, sanctions checks, among other
things), information from government or public bodies, public websites and other
public sources and information received from the applicant’s advisers or from
Uses of your personal data
We collect your personal information to fulfil our contractual obligations, our statutory
and regulatory obligations and/or the legitimate business interests of the
Management Entity or a Fund and for other purposes for which the Management
Entity has a lawful basis under the privacy laws, including:
1. Compliance with legal and regulatory obligations and industry standards,
including know-your-client procedures, the automatic exchange of tax
information and legal judgments.
2. General business administration, including communicating with investors,
communicating with service providers and counterparties, accountancy and
audit services, risk monitoring, the administration of IT systems and
monitoring and improving products.
3. Assessing and processing applications for interests in a Fund and other
dealings with the Management Entity, including performing know-your-client
procedures, issuing and redeeming interests, receiving payments from and
making payments to the applicant, calculating net asset value, and overseeing
4. Business activities, such as investor relations, discussions with our or a
Fund’s service providers and counterparties, decision-making in relation to the
Funds, and business strategy, development and marketing.
We are entitled to process your personal data in these ways for the following
(a) you may enter into an investment contract with the Management Entity or a
Fund and some processing will be necessary for the performance of that contract, or
will be done at your request prior to entering into that contract.
(b) processing may be necessary to discharge a relevant legal or regulatory
(c) the processing is necessary for the legitimate business interests of the
Management Entity or a Fund or its administrator or another person, such as:
(i) carrying out the ordinary or reasonable business activities of the Management
Entity, a Fund or its administrator or other persons, or other activities previously
disclosed to you or referred to in this privacy notice;
(ii) ensuring compliance with all legal and regulatory obligations and industry
standards, and preventing fraud;
(iii) establishing, exercising or defending legal rights or for other purposes relating
to legal proceedings; and
(iv) ensuring the security of information systems.
(d) in respect of any processing of sensitive personal data falling within special
categories, such as any personal data relating to the political opinions of a politically exposed person, the processing will be necessary for reasons of substantial public
Disclosure of your personal data to third parties
We may from time to time, in accordance with the purposes described above,
disclose your personal data to other parties, including (a) our affiliates, (b) a Fund’s
administrator and its affiliates, (c) professional advisers such as law firms and
accountancy firms, (d) other service providers of the Management Entity or a Fund
or its administrator, including technology service providers, (e) counterparties and (f)
courts and regulatory, tax and governmental authorities. Some of these persons will
process your personal data in accordance with our instructions and others will
themselves be responsible for their use of your personal data. These persons may
be permitted to further disclose the personal data to other parties.
Transfers of your personal data outside the UK or the European Economic Area
Your personal data may be transferred to and stored by persons outside the UK or
the European Economic Area (the “EEA”) such as a Fund and in particular may be
transferred to and stored by affiliates or service providers of the Funds or their
administrators outside the UK or the EEA.
Where personal data is transferred outside the UK or the EEA, we will ensure that
the transfer is subject to appropriate safeguards or is otherwise permitted under
applicable law. For example, the country to which the personal data is transferred
may be approved by the European Commission or the UK Government (as
applicable) or the recipient may have agreed to model contractual clauses approved
by the European Commission, the UK Government or the Information
Commissioner’s Office (“ICO”) (as applicable) that oblige them to protect the
You can obtain more details of the protection given to your personal data when it is
transferred outside the UK or the EEA, including a copy of any standard data
protection clauses entered into with recipients of your personal data, by contacting
us using the details set out under “Contacting us” below.
Necessity of personal data for us to provide services to you or an investment in a
The provision of certain personal data is necessary for us to provide services to you
or for interests in a Fund to be issued to any applicant and for compliance by the
Management Entity and the Funds and our and their respective service providers
with certain legal and regulatory obligations. Accordingly, if certain personal data is
not provided when requested, we may not be able to provide services to you and/or
an application for interests might not be accepted or interests might be compulsorily
Retention of personal data
How long we hold your personal data for will vary. The retention period will be
determined by various criteria, including the purposes for which we are using it (as it
will need to be kept for as long as is necessary for any of those purposes) and legal
obligations (as laws or regulations may set a minimum period for which we have to
keep your personal data).
You have a number of legal rights in relation to the personal data that we hold about
you. These rights include the following:
(a) the right to obtain information regarding the processing of your personal data
and to access to the personal data that we hold about you.
(b) in some circumstances, the right to receive some personal data in a
structured, commonly used and machine-readable format and the right to request
that we transmit that data to a third party where this is technically feasible. Please
note that this right only applies to personal data which you have provided to us.
(c) the right to request that we rectify your personal data if it is inaccurate or
(d) the right to request that we erase your personal data in certain circumstances.
Please note that there may be circumstances where you ask us to erase your
personal data but we are legally entitled to retain it.
(e) the right to object to, and the right to request that we restrict, our processing
of your personal data in certain circumstances. Again, there may be circumstances
where you object to, or ask us to restrict, its processing of your personal data but we
are legally entitled to continue processing your personal data or to refuse that
(f) the right to lodge a complaint with the data protection regulator (details of
which are provided below) if you think that any of your rights have been infringed by
You can exercise your rights by contacting us using the details set out under
“Website Help” below. Depending on where you are based, you can find out more
information about your rights by contacting the ICO or an EU data regulator or by
searching the relevant regulator’s website.
Changes to our privacy notice
We keep our privacy notice under regular review and may amend it from time to
time. Any material changes we make to our privacy notice in the future will be posted
on this Site and, where appropriate, notified to you by email. We encourage you to
check back frequently to see any updates or changes to our privacy notice.
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