Privacy & Cookie Policy

Privacy Notice

The Company and its service providers may control or process personal data regarding individuals for the purposes of data protection law, such as the European Union’s General Data Protection Regulation. All such personal data will be processed in compliance with data protection law.

The Company’s service providers who may control or process personal data in connection with the Company include its administrator, Northern Trust International Fund Administration Services (Guernsey) Limited and its registrar, Computershare Investor Services (Guernsey) Limited.

Types of personal data

This personal data may include:

  1. Information provided by individual persons who are, or may be connected with, shareholders of the Company. This might include a person’s name and address (including proof of name and address), contact details, date of birth, nationality, signature, occupational history, job title, tax residency and tax identification information. Such information might be provided in an application form or in other documents (as part of an application process or at other times), face-to-face, by telephone, by email or otherwise.
  2. Information that the Company or its service providers collect or generate. This might include information relating to a shareholder’s investment, emails (and related data), call recordings and website usage data.
  3. Information obtained from other sources. This might include information obtained for the purpose of know-your-client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-person checks, sanctions checks, among other things), information from public websites and other public sources and information received from the applicant’s advisers or from intermediaries.

Use, and reasons for use, of personal data

Personal data may be stored and processed for the following purposes:

  1. Assessing and processing applications for shares in the Company, conversions of shares and other share dealings.
  2. Compliance with legal and regulatory obligations and industry standards, including know-your-client procedures, the automatic exchange of tax information and legal judgments.
  3. Investor relations and communication purposes.

The Company and its services providers are entitled to process personal data in these ways for the following reasons:

  1. The entry into an investment contract with the Company and the performance of that contract.
  2. To discharge a relevant legal or regulatory obligation.
  3. For the legitimate business interests of the Company, its manager, administrator, registrar or another person, such as:
    1. carrying out the ordinary or reasonable business activities of the Company, its manager, administrator, registrar or other persons, or other activities previously disclosed to the Company’s shareholders or referred to in this privacy notice;
    2. ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud;
    3. establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and
    4. ensuring the security of information systems.

Personal data will only be used by the Company and its service providers for the purposes for which it has been collected. No decisions will be made based on automated processing of personal data.

Disclosure of personal data to third parties

The Company and its service providers may from time to time, in accordance with the purposes described above, disclose personal data to other parties, including (a) the Company’s other service providers and their respective affiliates, (b) professional advisers such as law firms and accountancy firms and (c) courts and regulatory, tax and governmental authorities. Some of these persons may process personal data in accordance with the Company’s or its service providers’ instructions and others will themselves be responsible for their use of personal data. These persons may be permitted to further disclose the personal data to other parties.

Transfers of personal data outside the European Economic Area

Personal data may be transferred to and stored by persons outside Guernsey or the European Economic Area (the “EEA”), and in particular may be transferred to and stored by affiliates or service providers of the Company or its administrator outside Guernsey or the EEA.

Where personal data is transferred outside Guernsey or the EEA, the transfer will be subject to appropriate safeguards or otherwise permitted under applicable law. For example, the country to which the personal data is transferred may be approved by the European Commission, the recipient may have agreed to model contractual clauses approved by the European Commission that oblige them to protect the personal data, or the recipient may be located in the United States and be a certified member of the EU-US Privacy Shield scheme.

More details of the protection given to personal data when it is transferred outside Guernsey or the EEA, including a copy of any standard data protection clauses entered into with recipients of personal data, can be obtained by contacting the Company using the details set out under “Contacting the Company” below.

Necessity of personal data for an investment in the Company

The provision of certain personal data is necessary for shares in the Company to be issued or transferred to a proposed shareholder and for compliance by the Company and its service providers with certain legal and regulatory obligations. Accordingly, if certain personal data is not provided when requested, an application for or transfer or conversion of shares might not be accepted.

Retention of personal data

How long personal data may be held for will vary. The retention period will be determined by various criteria, including the purposes for which it is being used (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which the personal data has to be kept).

Your rights in respect of personal data

If you are an individual, you have a number of legal rights in relation to the personal data that the Company and its service providers may hold about you. These rights include the following:

  1. The right to obtain information regarding the processing of an individual’s personal data and access to the personal data that the Company and its service providers holds about an individual.
  2. In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and the right to request that the Company transmits that data to a third party where this is technically feasible. This right only applies to personal data which an individual has provided to the Company and its service providers.
  3. The right to request that the Company or its service providers rectifies personal data if it is inaccurate or incomplete.
  4. The right to request that the Company or its service providers erases personal data in certain circumstances. There may be circumstances where you ask the Company and its service providers to erase your personal data but the Company is legally entitled to retain it.
  5. The right to object to, and the right to request that the Company and its service providers restrict processing of personal data in certain circumstances. There may be circumstances where you object to, or ask the Company or its service providers to restrict, processing of personal data but the Company is legally entitled to continue processing your personal data or to refuse that request.
  6. The right to lodge a complaint with the Guernsey Data Protection Authority or other applicable data protection regulator if you think that any of your rights have been infringed by the Company or its service providers.

You can exercise your rights by contacting the Company using the details set out under “Contacting the Company” below. You can find out more information about your rights by contacting an EU data regulator such as the UK’s Information Commissioner’s Office, or by searching its website at ico.org.uk.

Contacting the Company

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions and requests to [email protected].

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BH Macro Limited Disclaimer

Please read the below disclaimer carefully. You will be asked to accept these terms and conditions before proceeding.

The information on this website is directed only at persons who are shareholders in BH Macro Limited (the “Company”) and is provided for their exclusive use and benefit.

Users of this website are responsible for observing all applicable laws and regulations in their relevant jurisdictions before proceeding to access the information contained herein. By proceeding to access the information, users are deemed to be representing and warranting that the applicable laws and regulations of their relevant jurisdiction allow them to do so. No information, materials or opinions contained on this website (“Materials”) constitute or would be deemed to constitute a recommendation or invitation in any jurisdiction to invest or otherwise deal in the shares of the Company (the “Shares”).

The website that you are seeking to access does not constitute an offer to buy or sell the securities mentioned in the website in any jurisdiction or jurisdictions in which such offers or sales are unlawful prior to registration or qualification under the securities laws of any such jurisdiction. In particular, the securities mentioned in the website have not been and will not be registered under the United States Securities Act of 1933, as amended (the “Securities Act”), and may not be offered or sold in the United States absent registration or exemption from registration under the Securities Act and other securities laws. There will be no public offer of these securities in the United States. Offers and sales of these securities, and distribution of the related information, may also be subject to restrictions in other jurisdictions.

The website that you are seeking to access is not directed at and may not be viewed by or distributed to persons:

  • In the United States or who are U.S persons (as defined in Rule 902 under the Securities Act);
    or
  • Located in a Jurisdiction where it is not lawful to access the materials.

The Materials are provided on an “as is” and “as available basis” and do not purport to be full or complete. The Company and its affiliates believe that the source of the Materials is reliable however they cannot and do not guarantee, either expressly or implicitly, and accept no liability for, the accuracy, validity, timeliness, merchantability or completeness of any information or data (whether prepared by the Company, its affiliates or by any third party) for any particular purpose or use or that the information or data will be free from error. The Company and its affiliates do not undertake any responsibility for any reliance which is placed by any person on any statements or opinions which are expressed herein. Neither the Company, nor any of its affiliates, directors, officers or employees will be liable or have any responsibility of any kind for any loss or damage that any person may incur resulting from the use of this information.

Nothing contained in this website constitutes financial, investment, legal, tax or other advice and is not to be relied on in making an investment or other decision. You should obtain relevant and specific professional advice before making any investment decision.

The Materials on this website are provided for your personal use and informational purposes only and are subject to change without notice. The Company has the right to suspend or withdraw the provision of all or any of the website of the Materials without prior notice at any time.

The value of investments mentioned in this site, and the income from them may go down as well as up and investors may not get back the amount invested. Information on past performance, where given, is not a guide to future performance. Changes in rates of exchange between currencies may cause the value of investments to decrease or increase.

The Guernsey Financial Services Commission has granted consent under the Control of Borrowing (Bailiwick of Guernsey) Ordinance 1959, as amended, for the Company to raise funds by the issue of shares. It must be specifically understood that neither the Guernsey Financial Services Commission nor the States Policy Council takes any responsibility for the financial soundness of the Company or for the correctness of any of the statements made or opinions expressed with regard to it.

Copyright

Copyright of all images and text in this website is owned by or licensed to the Company or one of its affiliates unless otherwise noted. You may imprint, copy, download or temporarily store extracts from this website for your personal information and use. Any other use is prohibited unless you first request and obtain the prior written consent of the Company. You may not alter or otherwise make any changes to any material that you print or download from this website, including, without limitation, removing any identifying marks or legends from such material. In particular, you may not copy or use any part of this website on any other website, or link any other website to this website, without the prior written permission of the Company. You may not use the website for any purpose which is unlawful, abusive, libellous, obscene or threatening.

No Warranty

The Materials contained in this website are provided without any warranty of any kind, either expressed or implied, to the fullest extent permissible pursuant to applicable law. Neither the Company nor its affiliates assume any responsibility for the uninterrupted availability of this website or warrant that it will be error-free, that defects will be corrected, or that this website or the servers that make it available will be free of viruses or other harmful components.

Liability Waiver

You agree that under no circumstances, including, but not limited to, negligence, shall the Company or any of its affiliates be liable for any special or consequential damages that result from the access or use of, or the inability to access or use, the Materials on this website. This does not exclude or restrict any duty or liability that the Company has to its customers under the regulatory system in the United Kingdom or Guernsey.

Privacy Policy

This policy sets out what the Company and its affiliates do with any personal information collected from this website.

Any personal information collected from this website will be processed in accordance with relevant data protection laws.

You may use the public areas of this website without providing the Company or its affiliates with any personal information and the Company and its affiliates do not monitor or collect any personal information through your access to the public areas of this website. The Company and its affiliates do not use cookies to collect information but may gather other anonymous information to assist in improving the services.

If you chose to provide the Company and its affiliates with personal information, this information will only be used for the purposes of the service that you have requested. The Company and its affiliates will not sell or transfer any personal information to third parties without your permission, other than as required by law.

The Company and its affiliates are not responsible for the content or privacy policies of websites to which this website may link.

The Company and its affiliates are committed to protecting your personal information but in the event that the system is infiltrated by unauthorised third parties the Company and its affiliates will not be liable for any resulting misuse of personal information.

Linked Sites

The Company has not reviewed any website linked to this website and is not responsible for the contents of off-site pages or any other websites linked or linking to this website. If you follow any links from this website you do so at your own risk.

Links to this website may not be established without the prior written consent of the Company.

Governing Law

The terms and conditions of this legal notice shall be governed by and construed in accordance with the laws of Guernsey. Users of this website agree that any dispute or action arising out of or relating to these terms or any user’s use of this website shall be commenced only in the courts located in Guernsey, and users of this website hereby consent and submit to the exclusive jurisdiction of such courts for the purposes of any such dispute or action.

By accessing Materials on this website you agree to be bound by the foregoing limitations.

By declining the disclaimer you are unable to enter the website

U.S. Selected

Access to the information contained in this website is restricted under applicable securities laws in the United States. The information contained in this website, therefore, generally is not available to United States persons.

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