Flexagon Capital Management Limited (“Flexagon”) is licensed to conduct Investment Services in Malta by the Malta Financial Services Authority. License Number: IS/73862. Flexagon is authorized to act as a full scope alternative investment fund manager (“AIFM”) in terms of the Directive 2011/61/EU and a UCITS (“undertakings for the collective investment in transferable securities”) manager in terms of the Directive 2009/65/EC of the European Parliament.

The use and access of pages of this website is subject to the terms and conditions set out below.

The investment products and services offered by Flexagon are only available to professional clients and are not available to retail clients.

This web site is subject to international copyright laws and other intellectual property rights with all rights reserved. No information contained in this web site, any part of this web site, or associated documents (collectively the “Information”), may be redistributed in whole or in part, stored in a retrieval system, modified, linked into, republished, uploaded, transmitted in any form or by any means electronic or mechanical, or by photocopying, recording or otherwise without the express prior written permission of Flexagon.

Any Information on this web site is confidential, is not intended to influence you in making any investment decisions, is non-binding and is posted for illustration and discussion purposes only.

Any Information on this web site does not constitute and should not be considered as advice or as an offer to sell or as a solicitation of an offer to buy or subscribe any investment vehicle or any other securities, to or from any person in any jurisdiction. In no way it should be considered as a recommendation to invest.

It is important that you do not rely upon any Information on this web site for investment decisions. Any offer to invest based on the content of this web site will not be capable of acceptance. Any failure to comply with these restrictions may constitute a violation of distribution and securities law in any applicable jurisdiction. It is the responsibility of any person who accesses the information contained in this website to observe all applicable laws and regulations of their jurisdiction. This web site is not directed to, and shall not be visited by, any person or entity who is a citizen or resident of or located in any locality, state, country or other jurisdiction where the content or use or visitation of this web site would be contrary to law or regulation or which would subject us to any registration or licensing requirement within such jurisdiction. If you are visiting our web site from any such jurisdiction, please kindly disconnect from our web pages.

And Information in this web site may not be suitable for all investors and investors must make their own investment decisions using their own independent advisors and relevant offering material. Any investment decisions must be based upon an investor’s specific financial situation and investment objectives and should be based solely on the information in the relevant offering memorandum. Income from or the price or value of any financial instruments may rise or fall. All investments involve a degree of risk and past performance is not necessary a guide to future performance. The value of the investment and the income derived from it (if any) may vary and are not guaranteed. Investments in the strategy (ies) are speculative and may involve a high degree of risk, and you could lose all or a substantial amount of your investments.

The Information on this website is intended for information only and is not intended directly or indirectly to bring about any transaction between any visitor to the site and Flexagon. The information contained herein does not constitute a distribution, an offer to sell or the solicitation of an offer to buy any securities in any jurisdiction in which such distribution or offer is not authorised to any person.
Flexagon assumes no responsibility or liability for the correctness, accuracy, timeliness or completeness of the Information contained in this website or for any loss, damage or lost opportunities resulting from the use of the Information. Any views, opinions or assumptions may be subject to change without notice.

The content of this web site is not directed at or intended for persons, individuals or entities that are US Persons (as defined by Regulation S of the US Securities Act of 1933, as amended) and no securities or services are being offered in the United States or to US Persons. Flexagon does not hold itself out as an investment adviser in the United States and does not offer its services to the general public in the United States.

Privacy & Cookies Policy - Flexagon Capital Management Limited

Privacy & Cookies Policy

Flexagon Capital Management
Website Privacy Policy
This privacy policy sets out how Flexagon Capital Management as Controller of the Information, uses
and protects any information that you give us when you use this website.
We are committed to ensuring that your privacy is protected. Should you provide us with any
personal information when using this website, you can be assured that it will only be used in
accordance with this Privacy Policy
We may change this policy from time to time by updating this page. You should check this page from
time to time to ensure that you are happy with any changes. This policy is effective from ___ June

1. What data do we collect and process on this website?
We may collect and process the following data about you:
1. Details of your visits to this site for traffic overview. This information is collected in line with
our Cookie Policy (add link).
2. The Internet address of the website or the domain name of the computer from which you
accessed the site.
3. Information that you provide by filling in your details in the Contact form.
4. Information that you provide when you communicate with us by any means.
If we start to collect any other data that is not in line with the above, this Privacy Policy shall be
2. Why do we collect this data?
We may use your personal information for the following purposes:
1. We may use personal information collected about you from any applications or forms you may
complete for the purposes of establishing a client relationship with you.
2. We may also use the information we collect in order to inform you about changes to this
3. We may also use the information to respond to your enquiries or comments submitted through
the website.
4. Your information may be used for legal and regulatory compliance purposes, including as
necessary: to respond to governmental or regulatory entities requests; to comply with our legal
obligations under current Anti-Money Laundering Laws and Regulations and current local and
international tax Laws including the Common Reporting Standards and the Foreign Account Tax
Compliance Act in relation to the exchange and automatic forwarding of tax related information;
to identify misuse of our systems and any fraud or other illegal or unlawful activity or any other
activity which is or may be contrary to our legal and regulatory compliance obligations.
If we start to collect any other data for purposes that are not in line with the above, this Privacy
Policy shall be updated.

3. Data retention
Personal data will be retained for as long as it is necessary for the purposes set out above and in
accordance with our legal and regulatory obligations.
4. Where we store your personal data
We will not transfer or store your personal data outside the EU.
5. Disclosure of Information
We may disclose your personal data to external service providers for operational and compliance
purposes, for example, if it is necessary to provide you with something which you have requested
(e.g. newsletter subscription). These service providers include:
– IT Service Providers;
– Google Analytics (a web analytics service provided by Google Inc, which uses the information
to evaluate your use of the Site, compile reports on site activity and provide other site
activity and internet related services); and
– Email Newsletter Platforms;
We shall enter into arrangements which such third parties which require them to use personal
information only for the provision of such services to us and in a manner that is consistent with
applicable data protection laws and regulations.
We may also transfer your data if we are under a duty to disclose or share your personal data in
order to comply with any legal or regulatory obligation.
If we start to disclose data to any other party not in line with the above, this Privacy Policy shall be
6. Third Party Links
On occasion we may include links to third party websites on this website. Once you have used these
links to leave our site, we do not have any control over that other website. Therefore, we are not
responsible for the protection and privacy of any information which you provide whilst visiting such
sites and such sites are not governed by this privacy policy. You should review the privacy policy of
these websites before providing any personal data to them.
7. Security
We are committed to ensuring that your information is secure. We have implemented measures and
procedures to prevent unauthorised access or disclosure of your information. Likewise, we seek to
keep confidential all information you send to us.
This site uses Secure Sockets Layer (SSL) to ensure secure transmission of your personal data. You
should be able to see the padlock symbol in the status bar on the bottom right hand corner of the
browser window. The URL address will also start with https:// depicting a secure webpage. SSL
applies encryption between two points such as your PC and the connecting server.

8. What are your rights?
Right to Transparent Information – you have the right to be informed in a clear manner on any
personal data pertaining to you that may be processed by us. Such information is being provided to
you in this Privacy Policy.
Right of Access to Information – you have the right to request confirmation from us whether
personal data relating to you is being processed and if so to access such personal data.
Right to Rectification – you have the right to request from us the rectification, without delay, of any
inaccurate personal data pertaining to you.
Right to Be Forgotten – you have the right to request from us the erasure of all personal data
pertaining to you without delay, where the data has been processed with your consent as the basis
for processing and/or where the processing is no longer lawful.
Right to Restrict Processing – you have the right to request from us the restriction of processing if:
processing is unlawful; you are contesting the accuracy of data; the data is no longer required by the
controller but you require us to keep it in order to establish, exercise, or defend a legal claim; or if
you have previously objected to the processing. Once data is restricted, we cannot process it in any
way other than to store it unless: we have your consent; or if it is required for the establishment,
exercise, or defence of legal claims; or if it is for the protection of the rights of other persons; or if it
is for reasons of important public interest.
Right to Data Portability – you have the right to receive from us personal data which you have
provided to us and to transmit that data to another controller without hindrance from us. This right
applies where the data is being processed with your consent, or for the performance of a contract,
and when processing is carried out by automated means.
Right to Object – you have the right to object at any time to the processing of personal data
pertaining to you where the processing is based: on our legitimate interest; or the performance of a
task in the public interest/exercise of official authority; or on direct marketing (including profiling);
or on processing for purposes of scientific/historical research and statistics.
You also have the right to object to profiling based on our legitimate interests or on the performance
of a task in the public interest/exercise of official authority.
You also have the right to object to automated decision making, including profiling, and therefore to
not be subject to a decision which is based solely on automated processing, including profiling,
which produces legal effects or significantly affects you.
Any requests or objections are to be made in writing by mail or email to our Data Protection


Our website uses cookies to improve functionality and performance. This helps us provide you with a good
experience when you browse our website and also allows us to improve our site.
What is a cookie?
Cookies are small text files automatically placed on your computer, smartphone, or other device you use to
visit a website or an application, which enable the website or the application to recognise visitors. The
information stored in a cookie may relate to your browsing habits or may contain a unique identification
number to allow the website to remember you on return visits.
How may cookies be used?
Cookies can be helpful in a variety of ways such as allowing you to move between web pages efficiently,
remembering your browsing preferences, measuring how you use the website so we can make sure it meets
your needs, and in general improving your browsing experience. Cookies also help by ensuring that content
and advertisements you see on a website are more relevant to your preferences.
The cookies that we use can be split into the following categories:
 Strictly necessary cookies. These are cookies that are required for the operation of the website. They include,
for example, cookies that enable you to log into parts of the website.
 Analytical/performance cookies. These cookies allow us to recognise and count the number of website
visitors and to see how they move around within the website when they are using it. This helps us to improve
the way the website works, for example, by ensuring that users are finding what they are looking for easily.
 Functionality cookies. These are used to recognise you when you return to the website. This enables us to
personalise our content for you, greet you by name and remember your preferences (for example, your choice
of language or region).
 Targeting cookies. These cookies record your visit to the website, the pages you have visited and the links you
have followed. We may share this information with third parties (see our Privacy Policy for more information
on how we use information we collect from you).
The table below explains the cookies we use and why.

If you wish to withdraw your consent to our use of cookies at any time, you will need to delete your cookies
using your internet browser settings. In addition, your browser or device may offer settings that allow you to
choose whether browser cookies are set. For more information about these controls, visit your browser or
device's help material. Certain parts of the website may not work properly if you have disabled browser cookie