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Please read this important information carefully - it contains both regulatory and legal notices relevant to the information contained on the Cohesion website

This information is approved and issued for communication only to Professional Investors in the United Kingdom and is not for access or distribution to the general public

Cohesion Investments Limited is a Private Limited Company registered in England and Wales, registered number 8224886. Cohesion Investments Limited is an Appointed Representative of RGL Capital LLP (together "The Companies"), which is authorised and regulated by the Financial Conduct Authority (FCA)

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The information contained within this site is issued by Cohesion Investments Limited ("Cohesion") for information only. It does not constitute, or form part of, any offer of, or invitation to apply for, securities nor shall it, or the fact of its distribution, form the basis of or be relied upon in connection with any contract or commitment to acquire any securities or funds. Where Cohesion or its associates and affiliates have expressed their own views and opinions, these may change

The investments outlined herein are being made to or directed to in the United Kingdom only to (i) persons who have professional experience in matters relating to investments (being "investment professionals" within the meaning of Article 19 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (the "FPO")) or (ii) persons falling within Article 49(2) ("high net worth companies, unincorporated associations etc") of the FPO or (iii) persons who are otherwise permitted by law to receive it (all such persons being "Relevant Persons"). The information contained on the Cohesion website is not intended to be viewed by, passed on or distributed (directly or indirectly) to, any other category of persons. Any investment or investment activity to which the Cohesion website relates is available only to Relevant Persons and will be engaged in only with Relevant Persons

Subscription for interests in any Fund is to be made on the terms of the relevant prospectus or offering document. No undertaking, representation, warranty or other assurance is given, and none should be implied, as to, and no reliance should be placed on, the accuracy, completeness or fairness of the information or opinions contained herein. The information contained on the website is subject to completion, alteration and verification nor should it be assumed that the information on the website will be updated

Risk Warnings
There are risks associated with investments in the Funds contained herein (non-exhaustive):

Past performance is not an indicator of future performance and the value of investments may fall as well as rise
Any investment in the Funds carries high risks and an investor may not get back the amount invested and may lose all capital invested
The price of shares can go down as well as up and may be affected by changes in rates of exchange
An investor may not get back the amount invested and may lose all capital invested
Other risks are considered to be liquidity, operational, counterparty and interest rate risks (non-exhaustive)

Prior to investing please refer to the risk section in the relevant subscription documents and prospectus for further information

This website is published solely for information purposes and does not constitute investment, legal, tax or other advice nor is it to be relied upon in making an investment decision

The Companies do not guarantee or represent that the functions contained in the material available herein will be uninterrupted or error free, that defects will be corrected, or that this site or the server that makes it available are free of viruses or represent the full functionality, accuracy or reliability of the materials

In no event will the Companies, its associates or affiliates be liable for any loss or damage whatsoever arising from use arising out of or in connection with the use of this website or reliance on its content

Information contained herein (including information from third parties) has been taken from sources considered by Cohesion and its associates or affiliates, to be reliable but no warranty is given that such information is accurate or complete and it should not be relied upon as such. All opinions and estimates should be regarded as indicative, preliminary, strictly non-binding and for illustrative purposes only. All example statements and any indicative terms and features of any solution given are strictly indicative and may be based on certain implicit and explicit assumptions. Such forecasts, opinions, estimates and projections involve known and unknown risks, uncertainties and other factors which may cause the actual results, performance or achievements to be materially different from any future results, performance or achievements expressed or implied by such forecasts, opinions, estimates and projections. Accordingly, no representation or warranty (express or implied) is or will be made or given in relation to, and (except in the case of wilful fraud) no responsibility or liability is or will be accepted by Cohesion or any of its directors, officers, employees, agents or advisers in respect of, such forecasts, opinions, estimates and projections. Information contained herein may not be distributed, published or reproduced in whole or in part or disclosed by relevant persons to any other person. The Funds are available only in jurisdictions where their promotion and sale are permitted

Cohesion will not be responsible for any loss or damage of any kind that arises, directly or indirectly, and is caused by the use of any part of the information contained herein

By clicking accept and entering the Cohesion website you confirm you are a relevant person as defined by the FCA and that you are not subject to any jurisdictional restrictions prohibiting access to information on these Funds

Video content
The information contained in the video’s available herein are provided for use by Professional Investors Only and are not for onward distribution to, or to be used or relied upon by the general public

They are marketing communications. The research and analysis included in them have not been prepared in accordance with the legal requirements designed to promote their independence and have been produced by the fund manager for its own investment management activities, may have been acted upon prior to publication and is made available here incidentally. Any opinions expressed are made as at the date of publication but are subject to change without notice and should not be seen as investment advice. Information obtained from external sources is believed to be reliable but its accuracy or completeness cannot be guaranteed. The mention of any specific shares should not be taken as an endorsement or recommendation to buy or sell. These videos contain forward-looking information that is based on forecasts of future events as of the date of publication. Such forecasts, opinions, estimates and projections involve known and unknown risks, uncertainties and other factors which may cause the actual results, performance or achievements to be materially different from any future results, performance or achievements expressed or implied by such forecasts, opinions, estimates and projections. Accordingly, no representation or warranty (express or implied) is or will be made or given in relation to, and (except in the case of wilful fraud) no responsibility or liability is or will be accepted by Cohesion or any of its directors, officers, employees, agents or advisers in respect of, such forecasts, opinions, estimates and projections. Do not place undue reliance on forward-looking information

These updates and its contents are confidential and proprietary. Information contained in the video’s may not be distributed, published or reproduced in whole or in part or disclosed by relevant persons to any other person without the express written permission of Cohesion

The content of all videos (including facts, views, opinions, recommendations, descriptions of or references to, products or securities) are not to be used or construed as investment advice, as an offer to sell or the solicitation of an offer to buy, or an endorsement, recommendation or sponsorship of any entity or stock cited. Although we endeavour to ensure their accuracy and completeness, we assume no responsibility for any reliance upon it

How we use Cookies
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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website

Privacy Policy
Cohesion takes the security and privacy of your personal information very seriously. We shall respect the privacy of your personal information, treat it as confidential and keep it secure, subject to the provision of the DPA and related and / or subsequent rule law and / or legislation

This policy explains how we will treat your personal information. By using the Cohesion website and agreeing to this policy, you consent Cohesion using your information as set out in this policy and to our use of cookies in accordance with the terms of this policy. To learn more about cookies and how to manage them, visit aboutcookies.org

Cohesion may vary this notice from time to time and any changes will be posted on this page

Uses made of your personal information
Cohesion uses personal information to undertake any activity relating to its policies, products and services. The type of information you consent for us to collect, store and process about you are the personal data ("personal information") you supply to us through this website or otherwise any other additional personal information that you provide to us. This will typically include information such as your name, telephone number, email address and any other personal information that you provide to us

The personal information that you provide to us will be used for a number of different purposes including but not limited: to update, correct and enhance Cohesion’s records; to offer you investment products and services (except where you have asked us not to do so) and to help us develop new ones; to contact you with details of changes to the products you have bought; for internal analysis and research; to comply with legal or regulatory requirements including but not limited to any rule regulation law authority (such as by way of example only, for the prevention of fraud or any other crime) or any direction of any competent. Your personal data may be held in electronic, electro-magnetic and / or paper form

Accessing your personal information
A person whose personal information is held by Cohesion has various rights including the right to:

Have any incorrect personal information corrected; and
Access the personal information held for which a small fee may be charged

Should you require any further details or have any questions about information contained on the Cohesion website, please contact us on 020 7399 6715 or at clientservices@cohesioninvestments.com

© Copyright 2015, Cohesion Investments Limited. All rights reserved

Please select ‘I Agree To The Terms Above’ below to confirm your agreement to the terms and continue to the site. Alternatively please select ‘Reject’ should you disagree and wish to leave the site

Data Protection/Privacy Notice

At Cohesion Investments, we take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our: Cohesion Investments Limited

Our Data Protection Officer: Adam Saunders

Personal data: Any information relating to an identified or identifiable individual

Personal data we collect about you

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

Your name, address and telephone number
Information to enable us to check and verify your identity, e.g. your date of birth or passport details

Personal data we may collect

Electronic contact details e.g. your email address and mobile phone number
Information relating to the matter in which you are seeking our services
Information to enable us to undertake a credit or other financial checks on you
Your financial details so far as relevant to your instructions, e.g. the source of your funds relating to an investment
Information about your use of our IT, communication and other systems, and other monitoring information, (e.g. if using our website or a secure online client portal)
Your National Insurance and tax details
Your bank and/or building society details
Details of your professional online presence, e.g. LinkedIn profile
Details of your spouse/partner and dependants or other family members, e.g. if relevant to an investment or KYC checks
Your employment status and details including salary and benefits
Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information
Details of your pension arrangements
Your employment records including, e.g. if relevant to an investment or KYC checks
Other information relevant to the conduct of due diligence or KYC checks
Information about your use of our information and communications systems
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this information from you direct. However, we may also collect information:

from publicly accessible sources, e.g. Companies House, HM Land Registry, LinkedIn or a your employer’s corporate website;
directly from a third party, e.g:
– sanctions screening providers;
– credit reference agencies;
– client due diligence providers;

from a third party with your consent, e.g:
– your bank or building society, another financial institution or advisor;
– consultants and other professionals we may engage in relation to our service;

via our website; and
via our information technology (IT) systems

How and why we use your personal data

Under data protection legislation, we can only use your personal data if we have a proper reason for doing so, e.g:

to comply with our legal and regulatory obligations;
to take steps at your request prior to entering into a contract;
for the performance of our contract with you; or
for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests

The list below explains what we use (process) your personal data for and our reasons for doing so:

To provide professional services to you
– For the performance of our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our clients and verify their identity
– To comply with our legal and regulatory obligations
Screening for financial and other sanctions or embargoes
– To comply with our legal and regulatory obligations
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business
– To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or regulatory bodies
– To comply with our legal and regulatory obligations
Ensuring business policies are adhered to
– For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
– For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can delivery the best service for you
Ensuring the confidentiality of commercially sensitive information
– For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information
– To comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures
– For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can delivery the best service for you at the best price
Preventing unauthorised access and modifications to systems
– For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
– To comply with our legal and regulatory obligations
Updating and enhancing client records – For the performance of our contract with you or to take steps at your request before entering into a contract
– To comply with our legal and regulatory obligations
– For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services
Statutory returns
– To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
– To comply with our legal and regulatory obligations
– For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to existing and former clients, third parties who have previously expressed an interest in our services, third parties with whom we have had no previous dealings
– For our legitimate interests or those of a third party, i.e. to promote our business
Credit reference checks via external credit reference agencies
– To comply with our legal and regulatory obligations
– For our legitimate interests or those of a third party, e.g. as part of background checks prior to an investment
– For the performance of our contract with you or to take steps at your request before entering into a contract
Preventing fraud
– To comply with our legal and regulatory obligations
– For our legitimate interests or those of a third party, e.g. as part of background checks prior to an investment
– For the performance of our contract with you or to take steps at your request before entering into a contract
Processing invoices and payments
– To comply with our legal and regulatory obligations
– For the performance of our contract with you or to take steps at your request before entering into a contract

Marketing communications

We may use your personal data to send you updates (by email, text message, telephone or post) about market developments, updates or information about our services that might be of interest to you and information about including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

contacting us by email on clientservices@cohesioninvestments.com
using the ‘unsubscribe’ link in emails
communicating your preference to us clearly in any other way

Who we share your personal data with

So far as is necessary, we may share personal data with:

professional advisers where this is relevant to our services, such as accountants, tax advisors or other experts;
representatives of investment funds;
other third parties where necessary to carry out your instructions;
compliance advisers;
our professional advisers (e.g. accountants, lawyers);
credit reference agencies;
our insurers and brokers;
external auditors, e.g. in relation the audit of our accounts;
our bank; and
external service suppliers, representatives and agents that we use to make our business more efficient

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Where your personal data is held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

How long your personal data will be kept

We will keep your personal data after completion of our services. We will do so for one of these reasons:

to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

Transferring your personal data out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g:

with our investment partners and service providers located outside the EEA;
if you are based outside the EEA;
where there is an international dimension to the services we are providing

These transfers are subject to special rules under European and UK data protection law.

We will ensure that any transfer complies with data protection laws and that relevant contracts contain appropriate clauses to confirm this. We will ensure that all personal data will be secure.

Your rights

You have the following rights, which you can exercise free of charge:

Access
– The right to be provided with a copy of your personal data
Rectification
– The right to require us to correct any mistakes in your personal data
To be forgotten
– The right to require us to delete your personal data in certain situations
Restriction of processing
– The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability
– The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object
– The right to object:
- at any time to your personal data being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making
– The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

If you would like to exercise any of those rights, please:

email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and
let us have enough information to identify you (e.g. your full name, address and email or telephone number);
let us have proof of your identity and address (e.g. a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this privacy policy

We may change this privacy policy from time to time. The latest version will be available on our website.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our Contact Details

Cohesion Investments Limited

60 Grosvenor Street

Mayfair, London

W1K 3HZ

clientservices@cohesioninvestments.com

+44 20 7399 6715

Our Data Protection Officer’s Contact Details:

Mr Adam Saunders

Cohesion Investments Limited

60 Grosvenor Street

Mayfair, London

W1K 3HZ

adam@cohesioninvestments.com

+44 20 7399 6715

Download a copy of our Privacy Policy here