Absolute Return Investment Advisers (UK) Ltd operates this website and is responsible for the processing of your personal data and is the data controller for all such information. We regard your privacy as very important. Any personal information you provide to us through this website will be dealt with in accordance with this privacy policy, the Terms of Use of this website and any signed authority form that you give to us.
This privacy policy describes the information we may collect from you and the purpose for our collection of it.

1. Data Protection
As data controller we take all necessary steps to comply with the Data Protection Act 1998 and its relevant subordinate legislation when handling any personal information.
1.1 When you supply any personal information to us we will meet our legal obligations to you in the way that we deal with that information.
1.2 In accordance with the Data Protection Act 1998 we are required to collect the information fairly and to let you know how we will use it (see paragraph 2 below) and whether we will pass the information on to anyone else (see paragraph 3 below).
1.3 We will comply with the Principles set out in the Data Protection Act 1998 and we will ensure all personal information supplied to us is held securely.
1.4 We will ensure that any information will be held only as long as is necessary to ensure our service runs smoothly.
1.5 We use up to date industry procedures to keep personal data as safe and secure as possible against loss, unauthorised disclosure or access.
1.6 You have a right to access information we hold about you. Should you wish to obtain a copy of the personal data we hold on you please write to the Compliance Officer, at ARIA Capital Management, Ground Floor, 2 Bell Court, Leapale Lane, Guildford, Surrey, GU1 4LY with a cheque for £10 payable to Absolute Return Investment Advisers (UK) Ltd for our administration costs. As soon as we are satisfied as to your identity we will send you, within 40 days of receipt of your written request and the fee, a copy of all the data we hold concerning you. Please contact us at the same address if you have any reason to believe the data we hold on you is inaccurate.

2. What personal information do we collect and why do we collect it?
2.1 We will collect and use personal information about you in order to administer the services to be provided to you, for banking and credit assessment, for market research and statistical analysis and for marketing to you products and services which we feel will be of interest to you.
2.2 If you do not wish to be contacted about or receive marketing information from us send an e-mail to compliance@ariacm.co.uk or write to The Data Protection Officer at the address set out in clause 1.6 above.

3. To whom will we supply your personal data?
3.1 Any personal data provided by you to us at any time will be processed in accordance with the Data Protection Act 1998. We will mainly use your personal data in connection with the provision of our services to you, but may also use it to contact you in connection with other services. We will not provide information to organisations without your consent, unless we are obliged to by the law or are requested to do so by HM Revenue & Customs, FCA, the LSE or any other regulatory body. For further information write to The Data Protection Officer at the address set out in clause 1.6 above.
3.2 where we need to share the information to provide a service you have requested
3.3 to assist licensed credit reference agencies in relation to credit assessment or if you breach the terms of any agreement we have with you
3.4 to prevent fraud or other crime
3.5 where we need to send the information to persons, agents, sub-contractors or other organisations who work on our behalf to provide a service to you but such persons or organisations may only use this information in order to provide such product or service and not for any other purpose
3.6 where we are required to forward the information in order to comply with a regulatory or legal process.

4. Links to other websites
This Privacy Policy only extends to this website and does not, therefore, extend to your use of, provision of data to and collection of data on any website not connected to Absolute Return Investment Advisers Ltd to which you may link by using the hypertext links within this website.

5. Cookies
We use a cookie only in the circumstance where you have asked us to remember your home branch. No other persistent cookies are used on this site.

6. Changes to this Privacy Policy
We may edit or amend this Privacy Policy from time to time. If we make any substantial changes in the way we use your personal information we will notify you by posting a prominent notice on the Home page of our website.

7. Contacting Us
If you have any questions about our Privacy Policy or any other aspect of this website please contact us at:
ARIA Capital Management, Ground Floor, 2 Bell Court, Leapale Lane, Guildford, Surrey, GU1 4LY
Telephone: 0203 137 3840
E-mail: compliance@ariacm.co.uk
Office Opening Times: 9.00am – 5.30pm

ARIA Capital Management is a trading name of Absolute Return Investment Advisers (ARIA) Limited. Office: Ground Floor, 2 Bell Court, Leapale Lane, Guildford GU1 4LY. Absolute Return Investment Advisers (ARIA) Ltd is authorised and regulated by the Financial Conduct Authority.
 
The information on this site is issued by ARIA CAPITAL MANAGEMENT. ‘ARIA’ and ‘ARIA CAPITAL MANAGEMENT’ are TRADING NAMES of ABSOLUTE RETURN INVESTMENT ADVISERS (ARIA) Limited, who are authorised and regulated by the Financial Conduct Authority in the UK, with Firm Reference number 527557. A Limited Company registered in England and Wales No: 7091239. Contact Address: Ground Floor, 2 Bell Court, Leapale Lane, Guildford GU1 4LY. Telephone: +44 (0)203 137 3840 The information on this site is directed only at persons or entities in any jurisdiction or country where such access to information contained herein and use thereof is not contrary to local law or regulation. In particular, the information on this site is not directed at any person in the United States and this site is not intended to be used by any person in the United States. Accordingly, all persons who access this site are required to inform themselves of and to comply with any such restrictions. Sales Restrictions United Kingdom: there are funds referred to on this site, which are not recognised collective investment schemes for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the 'Act'). The promotion of such investment funds and the distribution of offering materials in relation to such funds in the United Kingdom are accordingly restricted by law. The information contained on the restricted part of this site (the 'Intermediary Centre') is directed only at persons to whom such investment funds may lawfully be promoted by a person authorised under the Act (an 'authorised person') by virtue of Section 238(5) of the Act and Chapter 4 (part 12) of the FCA New Conduct of Business Sourcebook. Investors in the investment funds referred to in the Restricted Area will not benefit from the rules and regulations made under the Act for the protection of investors, nor from the Financial Services Compensation Scheme. Shares in the investment funds referred to in the Intermediary Centre are not dealt in or on a recognised or designated investment exchange for the purposes of the Act, nor is there a market maker in such shares, and it may therefore be difficult for an investor to dispose of his shares otherwise than by way of redemption. General: it may be illegal to access or download the information contained in this site in certain countries and ARIA disclaims all responsibility if you access or download any information from this site in breach of any law or regulation of the country in which you are residing. Access to the Intermediary Centre requires possession of a valid password and no other person should attempt to gain access to it. An application for shares in the investment funds referred to on this site should only be made having read fully the relevant prospectus and other information contained on this site. It is your responsibility to use such documentation and by making an application you will be deemed to represent that you have read such applicable documentation and agree to be bound by its contents. No Advice The information on this site is provided solely on the basis that you make your own investment decisions and does not constitute a personal recommendation or investment advice. Should you have any queries about the investment funds or services referred to on this site, you should contact your financial adviser. Taxation will depend on an individual financial circumstances and the country of residence. Please seek professional advice in relation to any taxation issues which may arise from your interest in investment funds or services referred to on this site. Risk Factors Past performance may not be repeated and should not be seen as a guide to future performance. The value of investments and the income from them may go down as well as up and investors may not get back the amount originally invested. Because of this, you are not certain to make a profit on your investments and you may lose money. Exchange rates may cause the value of overseas investments and the income arising from them to rise or fall. The levels and bases of and reliefs from taxation may change. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. Investors should consult their own tax adviser in order to understand any applicable tax consequences. ARIA has taken every step to ensure the accuracy of the information and statistics on this site and within its literature but cannot accept any liability for errors or any direct or consequential loss arising from the use of this document or its contents. Before taking any action you should consult your financial adviser as to the suitability to you of any investments or services mentioned on this site or within any literature available on this site. Accuracy of Information The information contained on this site (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by ARIA to be reliable, but is not guaranteed as to its accuracy or completeness. Such information is provided without obligation on the part of ARIA and its associated companies and on the understanding that any person who acts upon it or changes his investment position in reliance on it does so entirely at his own risk. The information contained on this site does not constitute an offer to buy or sell or an invitation to make an offer to buy or sell shares in any investment funds referred to herein. Information posted on this site is current only as at the date it is first posted and may no longer be true or complete when viewed by you. All information contained on this site may be changed or amended without prior notice although ARIA does not guarantee to update this site regularly. No Liability No representation, warranty or undertaking is given as to the accuracy or completeness of the information contained on this site by ARIA or any of its associated companies and no liability is accepted by such persons for the accuracy or completeness of such information. In no event will ARIA or any of its associated companies be liable to any person for any direct, indirect, special or consequential damages arising out of any use of the information contained on this site, or on any other hyper-linked site, including, without limitation, any lost profits, business interruption, loss of programs or data on your equipment, or otherwise, even if ARIA is expressly advised of the possibility or likelihood of such damages. This does not exclude or restrict any duty or liability that ARIA has to its customers under the regulatory system in the United Kingdom. You should be aware that the Internet is not a completely reliable transmission medium. ARIA does not accept any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to any direct, indirect or consequential damage, arising out of the use of the products or services referred to herein. This does not exclude or restrict any duty or liability that ARIA has to its customers under the regulatory system in the United Kingdom. Indemnity You agree to indemnify, defend, and hold harmless ARIA, its affiliates and licensors, and the officers, partners, employees, and agents of ARIA and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this site or any literature available on this site. Material Interest ARIA and its partners, officers and/or employees may have holdings in the investment funds referred to on this site and may otherwise be interested in transactions that you effect in those funds. Linked Websites This site may be linked to third party websites or contain information provided by third parties. ARIA does not make any representation as to the accuracy or completeness of such websites or information, has not and will not review or update such websites or information, and cautions browsers that any use made of such websites or information is at their own risk. ARIA does not accept any liability arising out of the information contained on any linked website or information on this site provided by a third party and the use of such sites and information is at your own risk. This does not exclude or restrict any duty or liability that ARIA has to its customers under the regulatory system in the United Kingdom. Copyright, Trademarks and Other Rights Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by ARIA, its licensors or relevant third party content providers. You may use the information on this site and reproduce it in hard copy for your personal reference only. Such information may not otherwise be reproduced, distributed or transmitted to any other person or incorporated in any way into another database, document or other materials. Nothing on this site should be considered as granting any licence or right under any trademark of ARIA or any third party. Privacy and Cookies ARIA is as concerned as you are about the privacy of any personal information you may provide to it through this site. A 'cookie' is a piece of information that is saved to your computer's hard disk by the web server. Confirmation of reading and accepting these terms and conditions will place a cookie on your computer's hard disk. This will ease your navigation around this website by not popping up these terms and conditions again during this browser session. This cookie is temporary and will be removed when you close your browser. The cookie is not used for any other reason. Data Protection ARIA may collect certain personal information about you such as your name, address, telephone number, email address details and other information when it is voluntarily submitted to ARIA on this site, including in connection with its registration procedures. ARIA uses this information to ensure compliance with its obligations under the UK regulatory regime and for its own internal purposes. Please note that by submitting personal information you are consenting to such information being processed for the purposes referred to above. You also agree that ARIA has the right to use and store such data on its internal systems and to transfer it to its associated companies, whether inside or outside the European Union, for the purpose of providing services to you. You should also be aware that the level of protection in relation to the processing of personal data may not be the same in countries outside the European Union as in the United Kingdom. FRC Stewardship Code The Stewardship Code (“the Code”), which has been published by the Financial Reporting Council, sets out principles for institutional investors in relation to engagement with the companies in which they have invested. The FCA’s regulations oblige any firm which manages investments for institutional clients to publicly disclose the nature of its commitment to the Code, or where it does not commit to the Code its alternative approach. ARIA’s investment strategy, notwithstanding that this may vary depending on the mandate received from the client, is in general such that the firm does not consider it to be appropriate for it to engage directly with companies in which it invests. The scale on which the firm manages investments for institutional clients is such that engagement would not be cost-effective and appropriate for those clients. The firm does not consider that those institutional clients for whom it manages investments expect engagement.
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