Privacy Policy

This privacy policy only covers the AcenciA website.

AcenciA Debt Strategies (referred to as “AcenciA”, “we” or “us”) is committed to maintaining the confidentiality, integrity and security of personal information about our current and prospective investors. We recognise that you may entrust important personal information to us, and we wish to assure you that we take seriously our responsibilities in protecting and safeguarding this information. Any personal information or details that you submit or provide to us will be treated and kept in confidence and will not be provided to any third party except as expressly set out herein.

This Privacy Policy describes in detail how we deal with information that we may collect on this Website, use and share data about you. This Policy may be updated at any time to reflect changes in our business and or to reflect changes in the law. If we make any substantial changes to the way we use your personal information, we will notify you by posting a prominent announcement on this Website.

We will retain your personal information in accordance with applicable data protection laws for so long as it is needed.

Information we may collect:

Any personal information or details you submit will be used by Acencia (and its Investment Manager and Sub-Investment Manager) for assessment and analysis purposes only. This may also include market and product analysis (for the purposes of developing and enhancing the services offered by Acencia, its Investment Manager and the Sub-Investment Manager) as well as analysis of the use of the AcenciA Website to enable us to provide you with relevant information through Acencia's marketing programme from time to time. It is also used to enable AcenciA (and its Investment Manager and the Sub-Investment Manager) to provide you with information you have requested from AcenciA on this website.

From time to time, we may use password-protections to allow access to portions of our website. If you register to use or access such areas, we will ask you to provide us with certain information about yourself. This information may include your name, company name, title, address, country of residence, e-mail address, telephone number, account number, assets, income and financial situation. We use such information about you to verify your identity and eligibility to receive certain products or services, to provide information to you about products and services that we believe may be of interest to you, to record your interest in products and services that we offer, and to respond to your requests for information. We may also use cookies or web bugs on such portions of our Site to collect Usage Information, and to facilitate your movement within the Site (e.g. remembering passwords during a session and recording the country you may have elected as your country of residence).

We may collect information concerning the attachments you open within newsletters that are sent to you electronically. We may also collect personal information about you from applications, forms or questionnaires you may complete or agreements you enter into with us or in the course of your establishing or maintaining a customer relationship with us, including information about your credit history or financial situation, and your transactions with us or others who provide services to us. If you decline to provide us with the personal information we require then we may not be able to make investment products available to you or to provide other services to you.

Cookies:

We may send cookies to your computer. Cookies are strings of information that are sent out by a website and saved in your computer. We may use session specific cookies and “web bugs” to automatically collect data about website usage when you visit this Site, including your IP address, “click-stream” data regarding the portions of the site that you visit and the information or other services you obtain or input (including domain name, Internet service provider, protocol, browser type, operating system etc.) (“Usage Information”). This information is collected primarily for purposes of administering the Site, compiling demographic information and monitoring usage and performance of the Site. If you turn off the cookie function you may not receive all the information on the website.

When you visit our website, cookies are either served directly by us, or by our business partners. Here is a description of the different kind of cookies we use.

Essential cookies These cookies allow you to use the basic functionality of our website. For example, browsing our website and remembering that you have accepted our disclaimer.
Performance cookies We also use these cookies to help improve the user experience.
Website analytics cookies These cookies allow us to get to know how you use our website. They are used to analyse visitor information such as usage and visitor numbers.

List of cookies:

Security of Data Transfers:

Please note that data that is transported over an open network, such as the Internet or e-mail, may be accessible to anybody. Saltus cannot guarantee the confidentiality of any communication or material transmitted via such open networks. When disclosing any personal information via an open network, you should remain mindful of the fact that it is potentially accessible to others, and consequently, can be collected and used by others without your consent.

In particular, while individual data packets are often encrypted, the names of the sender and recipient are not. A third party may therefore be able to trace an existing bank account or relationship or one that is subsequently created. Even if both the sender and recipient are located in the same country data may also be transmitted via such networks to other countries regularly and without controls, including to countries that do not afford the same level of data protection as your country of domicile. For certain services, we use strong encryption to transfer your data. In these cases you will be told separately about the treatment of this data and about the details of encryption.

Your data may be lost during transmission or may be accessed by unauthorised parties. We do not accept any liability for direct or indirect losses as regards the security of your data during its transfer via Internet. Please use other means of communication if you think this is necessary or prudent for security reasons.

Protection, Processing and use of Personal Data:

We use your personal information to enhance the quality of the products or services we wish to provide to our customers or in connection with your investments with or through us and to maintain contact details for those with whom we deal. We restrict access to personal information about you to those employees, agents or other parties who need to know that information to provide products or services to you or in connection with your investments with or through us.

We maintain physical, electronic and procedural safeguards to guard your personal information, including firewalls, individual passwords and encryption and authentication technology. We do not use for purposes other than as set out above, or disclose to any third party any personal information about our existing customers or past customers, except with such customer’s consent or as otherwise permitted or required by law.

In cases where we believe that additional products and services may be of interest to you, we may share your personal information with affiliates of Saltus to the extent permitted by applicable law (including transfers outside the EEA to jurisdictions where the level of data protection may not be as high as within the EEA). Where such transfers are made, Saltus will take steps to ensure that the use of your personal information will be for the purposes outlined in this Statement. We may also disclose this information to firms that perform services on our behalf to the extent permitted by applicable law. These service providers are required to treat the information confidentially and use it only for the purpose for which it is provided. Certain jurisdictions may have more stringent privacy requirements that will prevent disclosure of your personal information to any other person or entity, including affiliates.

Links to Other Sites:

The AcenciA Website contains links to other Websites. You should be aware that our Privacy Policy does not apply to these linked sites nor to the use of third party cookies. You are advised to read and understand the Privacy Policies of any Website to which you link via the our Website as they may be in different jurisdictions and subject to different data protection legislation.

Further Information:

For further information on this Policy, please contact:

The Data Protection Manager

Saltus Partners LLP
72 New Bond Street
4th floor
London W1S 1RR

+44 (0)207 499 0200

Aggreement:

I have read and understood the above Privacy Policy and by continuing to use the AcenciA Website, consent to the terms set out in this Privacy Policy. If you do not agree to the terms of this Website, please exit the Website immediately. If you wish to withdraw your consent to this Privacy Policy or should you wish your data to be deleted or amended for any reason, please contact us at the address above.

Data Protection Act 1998:

We treat all customer information in a confidential and secure manner. We comply with the Data Protection Act 1998, which lays down a set of standards that must be followed whenever personal information is processed. We may use the information provided by you to check and verify your identity, and the identity of any other persons that may provide monies on behalf of any investments made in your name. We may provide this information to credit reference and fraud prevention agencies that will record this information and may make this information available to others in order to verify your identity. If we are unable to verify your identity initially, we may request further information from you. If you provide false or inaccurate information that result in us suspecting fraud, we will notify the relevant authorities. We may transfer your information to a jurisdiction outside the European Economic Area but will only do so if that jurisdiction ensures an adequate equivalent level of protection for your rights and freedom in relation to the processing of your information. You have the legal right to find out what information, if any, is held by us about you and the details of the agencies that we may obtain information from and may record information with about you. A request for this information may be subject to a fee by us and by the agencies and must be in writing to us. For further details on our Data Protection policy see the Library section of this website under General Documents. Our Subject Access Request Form (SAR Form) is also in the Library under General Documents.