Disclosures

Key Definitions

• “Personal Data” or “Personal Information” means any information about an individual from which that person can be identified. Personal Data and/or Personal Information does not include data where the identity has been removed (i.e. anonymous data).
• “Special Categories of Personal Data” means more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation.
• “Data Subject” refers to any individual person who can be identified, directly or indirectly, via an identifier such as name, ID number, or location data.

Identification

For the purposes of the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018, the following entities determine the means and purposes of processing your personal data (each, a “Data Controller”):

• Future Value Capital LLP, a limited liability partnership registered in England and Wales with Companies House number OC359493, and whose registered office is at 167-169 Great Portland Street, London, England, W1W 5PF; and
• Future Value Capital Spain S.L., a limited liability company registered in Spain with number B09783945, and whose registered office is at Paseo de la Castellana 77, 28046 Madrid, Spain;

together, collectively referred to as “Future Value Capital”, “FVC”, “we”, “us”, or “our”.

The terms “you” and “your” shall refer to the user of this website.

Information We Collect

The information we collect varies depending on which part of the website you visit and how you interact with it, and may be collected without you being aware of it.

Through our website, you can register to gain access to monthly investor reports, fact sheets, and investment-related news articles (the “Service”). The types of Personal Information collected might include name, date of birth, e-mail address, postal address, telephone number, country of domicile, and the organisation for which you are acting.

Lawful Basis for Processing

Where we act as Data Controller, we rely on the following legal bases for processing your Personal Data:

• Consent — for instance, where you have subscribed to our online marketing materials.
• Legitimate interest — where we have balanced our legitimate interest against your fundamental rights.
• Performance of a contract — we may process Personal Data to perform a contractual obligation we have agreed with you.
• Legal obligation — we comply with applicable laws and regulations which may require us to process certain Personal Information from time to time.

We may also process Personal Data on behalf of a Data Controller, acting on their written instructions. In such cases, we act as a “Data Processor”.

Special Categories of Personal Data

We do not process Special Categories of Personal Data, nor Personal Data relating to any minors under the age of 18, through this website. Where we inadvertently collect any such Personal Information, we will endeavour to delete it from our systems and networks as soon as practically feasible.

How We Use Your Information

The Personal Data we collect is used for the following legitimate interests:

• Provision of financial products and services.
• Promotion of ideas and events relating to services we provide.
• Accuracy of client records.
• Maintenance of records of communication and management of your relationship with us.
• Responding to your enquiries.
• Compliance with any present or future law, rule, regulation, guidance, decision or directive (including those concerning anti-terrorism, fraud, AML and anti-corruption).
• Carrying out, in appropriate cases, KYC checks and other procedures undertaken prior to you becoming a customer of ours.
• Prevention and detection of fraud and other illegal activity or misconduct.
• Informing you about, and providing guidance on, compliance with legal and regulatory obligations.

The information which you supply will be used purely for the purpose(s) described above.

If you wish to cancel your registration with us, please let us know by writing to us at the address given at the end of this Notice.

If our company (or part of it) is sold, we may share your information with the purchaser, who may then provide you with access to the Service.

Who We Share Your Information With

We will not share personal information about you with third parties without your consent. We are, however, required by law to sometimes pass on some of this Personal Data to:

• Law enforcement agencies; financial regulators such as the FCA and other relevant regulatory authorities; government bodies; tax authorities such as HMRC; and courts, tribunals and complaints/dispute resolution bodies.
• Other bodies as required by law or regulation.
• Related financial institutions such as trustees, custodians and sub-custodians; insurers; fraud protection agencies; and similar suppliers or service providers.

Subject to applicable laws and regulations, we may not be able to notify you of such transfers of Personal Data.

To fulfil our contract with you, Future Value Capital may also pass information to:

• IT service providers, including client relationship management platforms.
• Government and self-regulatory agencies as required.
• Intragroup, to related affiliates working on providing you with related services.

International Transfers Outside the EEA and/or the UK

Future Value Capital does not transfer your personal information outside of the EEA (respectively, the UK) unless the transfer is necessary for one of the reasons set out in the GDPR — including the performance of a contract, reasons of public interest, to establish, exercise or defend legal claims, or to protect the vital interests of a Data Subject who is physically or legally incapable of giving consent — and, in some limited cases, for our legitimate interest.

In these cases, we follow the GDPR guidelines in protecting the transfer of data to countries outside the EEA (respectively, the UK) to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. We will only transfer Personal Data outside the EEA (respectively, the UK) if one of the following conditions applies:

• The European Commission (respectively, the Secretary of State) has issued a decision confirming that the recipient country ensures an adequate level of protection for Data Subjects.
• Appropriate safeguards are in place, such as binding corporate rules, standard contractual clauses approved by the European Commission (respectively, the international data transfer agreement issued by the Information Commissioner’s Office), an approved code of conduct, or a certification mechanism — a copy of which can be obtained from our Compliance team.
• The Data Subject has provided explicit consent, having been informed in writing of any potential risks of the proposed transfer.

Privacy and Cookies

We use “Cookies” and other tracking software to personalise your visit to our website and enhance your experience, by gaining a better understanding of your particular interests and customising our pages for you. A cookie is a message given to a web browser by a web server, which is then stored by the browser in a text file; each time the browser requests a page from the server, this message is sent back, enabling the user to be recognised.

We may use the information provided by cookies to analyse trends, administer the site, or for research and marketing purposes. No information which personally identifies you, other than your IP address, will be collected through cookies. It is possible to modify your cookie preferences through the tools tab in your browser window — see our Cookie Policy for further detail.

Data Retention

We will keep your Personal Data for no longer than reasonably necessary. Personal data is retained for up to six years after the end of the client relationship or transaction, as required by FCA rules and UK GDPR obligations, unless a legal or regulatory basis necessitates longer retention.

We will retain your personal information in accordance with legal and regulatory requirements.

Further Processing

Where we may seek to further process your data other than for the original purpose for which it was collected, Future Value Capital shall only further process such data where the new processing is compatible with the original purpose.

Your Privacy Rights

As a Data Subject, you have the following rights under the GDPR and the UK Data Protection Act 2018:

• To request a copy of the Personal Data which Future Value Capital, or a related data processor, holds about you.
• To request that we, or a related data processor, correct any Personal Data found to be inaccurate or out of date.
• To request erasure of your Personal Data where it is no longer necessary for us, or a related data processor, to retain it.
• To withdraw your consent to processing at any time, where consent is the lawful basis for that processing.
• To object to processing carried out for a task in the public interest, or for our (or a third party’s) legitimate interest, unless overridden by your fundamental rights and interests.
• To request that a restriction be placed on further processing.
• To lodge a complaint with the National Supervisory Authority (see below).
• Not to be subject to a decision based on automated processing — Future Value Capital does not utilise any automated decision-making.

Your rights as a Data Subject are subject to applicable laws and regulations, which may require us to retain certain Personal Information.

National Supervisory Authority

While Future Value Capital will take all reasonable steps to resolve any queries we receive from Data Subjects, you have the right to lodge a complaint directly with the competent National Supervisory Authority under Article 51 of the GDPR.

In the UK, the competent authority is the Information Commissioner’s Office (ICO): Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Tel: 0303 123 1113. ico.org.uk/global/contact-us/email/

If you are located in an EEA country, please refer to the directory of Member State supervisory authorities under the GDPR maintained by the European Data Protection Board at edpb.europa.eu.

Links

Our website may sometimes contain links to other websites belonging to third parties. We do not control the privacy practices of these other sites, and you access them at your own risk.

Legitimate Interests

We occasionally process your personal information on the Legitimate Interests legal basis. Where this is the case, we carry out a Legitimate Interests Assessment (LIA) to ensure that your interests, and any risk posed to you, are weighed against our own, and that reliance on this basis is proportionate and appropriate — such as for HR, marketing, and day-to-day operations.

Marketing

When sending marketing materials to customers, we may rely on your consent or on our legitimate interest.

We only rely on legitimate interest for marketing where we have assessed that the information being sent is beneficial to you, weighed our interests against your own with little to no risk posed, ensured the method and content is non-intrusive, and confirmed the material is something you would usually expect to receive.

Security

We recognise the need to ensure that personal information gathered via this website remains secure, and have security measures in place to protect against loss, misuse and alteration of the personal information under our control.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to your Personal Data is limited to employees, agents, contractors and other third parties on a ‘need to know’ basis, who will only process it on our instructions and are subject to a duty of confidentiality.

We will only transfer Personal Data to a third party if they agree to comply with our procedures and policies, or put in place adequate measures prior to receiving it. Maintaining data security means guaranteeing the confidentiality, integrity and availability, for authorised purposes, of the Personal Data.

We have put in place procedures to deal with any suspected Personal Data breach, and will notify you and any applicable regulator of a breach where we are legally required to do so.

You acknowledge that, although we take steps to exercise care and security, there remains a risk that information transmitted over the internet and stored by computer may be intercepted or accessed by an unauthorised third party.

Changes to this Notice

We reserve the right, at our sole discretion, to modify, add or remove sections of this Privacy Notice at any time. Any changes will be notified to you via the e-mail address you have given us, or by an announcement on this site. Your continued use of this site following the posting of changes will mean you accept those changes.

Privacy Notice Review

This Privacy Notice is reviewed annually by the Compliance Officer to ensure it remains accurate, relevant, and fully compliant with evolving UK GDPR and FCA requirements.

Privacy Queries

If you have any questions regarding this Privacy Notice, or wish to exercise any of your Data Subject rights, please contact us:

• Future Value Capital LLP — Colonnade Walk, 123 Buckingham Palace Road, SW1V 1PX London, United Kingdom. Tel: +44 203 318 06 09.
• Future Value Capital S.L. — Calle José Abascal, 41, 28003 Madrid, Spain. Tel: +34 91 0606 977.
• Email: info@futurevaluecapital.com

Thank you for visiting Future Value Capital.