Flexagon Capital Management
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
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
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.
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
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.
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
these websites before providing any personal data to them.
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
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
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
on how we use information we collect from you).
The table below explains the cookies we use and why.
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