Privacy & Cookies Policy

Markham Rae LLP, in conjunction with Ashenden Capital Management LLP, and Ovington Capital Management LLP, (“we”, “our” or “us”) recognises the importance of protecting your personal data when you visit our website.  Please read this Privacy Policy, which includes our Cookies Policy,  and which explains our approach to data protection and how we use any personal data which we hold.

We may collect and process the following information:

• personally identifiable information such as names and addresses from people who have voluntarily input such information either when registering to use certain sections of the website and/or in order to contact us;
• if you contact us, we may keep a record of that correspondence as well as your e-mail address;  
• our computers automatically collect certain non-personally identifiable information when you visit our website, such as the type of browser you are using or the domain name of your Internet service provider. We may also collect aggregate information on the site pages our users visit and how long you visited for.

Like many websites, we may use “cookies.” A cookie is a piece of data stored on a user’s device containing information about the user’s visit. Cookies make it easier for you to log on to and use our website during future visits.  They also help us to improve our website by enabling us to monitor website traffic, to store information about your preferences, to speed up your searches and to recognise you when you return to this website.

You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Services. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.

We understand that you may want to know more about cookies. Here are some useful resources that provide detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org or www.allaboutcookies.org. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:

• Mozilla Firefox®
• Microsoft® Internet Explorer
• Google Chrome™
• Safari®

The personal data we hold is kept securely and is only accessed by authorised personnel.  To the extent permitted by law, we will not sell any of the information we collect online.

We may use your information to improve our website and the information that we provide or to respond to your requests or questions.  

We restrict access to personal information about our customers to those employees and agents who need to know that information in order to provide products and services to you.  We maintain physical, electronic and procedural safeguards to protect your personal information. 

Unfortunately, the transmission of information via the internet is not completely secure.  Therefore, although we have implemented security controls, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk.

If we choose to dispose of any personal information that we are not legally bound to maintain, then we will do so in a manner that reasonably protects such information from unauthorised access.

How long we hold your personal information for will vary and will depend principally on:

• the purpose for which we are using your personal information - we will need to keep the information for as long as is necessary for the relevant purpose, and
• legal obligations - laws or regulation may set a minimum period for which we have to keep your personal information.

You have the right to access information held about you and may request that we amend, delete or update such information.

You may submit a request to: info@markhamrae.com.  

Please note that there may be circumstances where we cannot delete information that we hold about you because of our legal obligations.  Additionally, we may charge a reasonable fee in order to meet our costs in actioning your request.

If you have concerns about the way we handle your personal data, you can contact the ICO or raise a complaint.

For questions about this Privacy Policy, please contact us at: info@markhamrae.com.

Disclaimer

Welcome to the Markham Rae LLP (“Markham Rae”) website. 

IMPORTANT:  Please read the following information carefully before using the site.  In accessing the website, you are acknowledging that you accept and agree to these terms and conditions, which are subject to change without notice from Markham Rae.

By entering this site, you acknowledge and agree that the use of this site is at your own risk and to the extent permissible by applicable law, in no circumstances, including (but not limited to) negligence, shall Markham Rae be liable for any direct, indirect, incidental, special, consequential, or punitive damages, losses, costs or expenses nor for any loss of profit that results from the use of, or inability to use this site or any material on any site linked to this site (including but not limited to any viruses or any other errors or defects or failures in computer transmissions or network communications) even if we have been advised of the possibility of such damage.  In addition, no liability can be accepted by us in respect of any changes made to the content of this site by unauthorised third parties.  All express or implied warranties or representations are excluded to the fullest extent permissible by law.  In accessing this website, every user fully discharges and releases Markham Rae and all its subsidiaries and their respective partners, directors, employees and agents from any responsibility, demand or claim of any kind whatsoever arising from such loss or damage.

Material on this Website: This website is issued by Markham Rae LLP, which is authorised and regulated by the Financial Conduct Authority of the UK (“FCA”). The funds to which the material on this website pertains (each a “Fund”, and together the “Funds”) are each not a recognised collective investment scheme for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the “Act”).

The material on this website constitutes a financial promotion under the Financial Services and Markets Act 2000 and accordingly, with respect to investors in the UK (“UK Investors”), this material is directed at only persons (A) who are professional investors, as defined in the UK AIFMD Regulations; or (B) to whom it may lawfully be made or directed at under the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (as amended) or chapter 4, section 4.12 of the FCA's Conduct of Business Sourcebook, including authorised persons, certain persons having professional experience of participating in unregulated schemes, high net worth companies, high net worth unincorporated associations or partnerships, trustees of high value trusts, persons who qualify as certified sophisticated investors and clients of the person making the distribution for whom that person has taken reasonable steps to ensure that the investment in the Funds is suitable.

The contents of this site have been prepared solely for information purposes.  Whilst Markham Rae uses every reasonable effort to ensure that the information contained on this website is current and accurate at the date of publication, no guarantee is given, whether express or implied, as to its accuracy, reliability or completeness.  Markham Rae may change the content of this website at any time without notice.  Users of this site should take appropriate steps to verify all information on this website before acting upon it.  We do not warrant that this website does not infringe any intellectual property rights of third parties.  Comments or statements made herein do not necessarily reflect those of Markham Rae.

Markham Rae takes all reasonable steps to ensure the security of the website and your personal information.  However, the nature of the internet is such that we cannot give an absolute guarantee of security.  Our privacy policy sets out details of how we handle the personal information you provide to us.  By using this website, you are agreeing to the terms of our Privacy Policy. 

With respect to investors that are domiciled or has its registered office in the European Union or European Economic Area (together, the “EU”) but which are not UK Investors (“EU Investors”), the material on this website is directed at only those persons who are professional investors, as defined the Alternative Investment Fund Managers Directive (2004/39/EC).

With respect to investors other than UK Investors or EU Investors, the material on this website is directed at only those persons to whom information about the Funds may be provided in accordance with the relevant rules and restrictions as applicable in the jurisdiction of the investor.

Switzerland: CISA Swiss disclosure. The representative in Switzerland is ARM Swiss Representatives SA, Route de Cité-Ouest 2, 1196 Gland, Switzerland. The paying agent in Switzerland is Banque Cantonale de Geneve, 17 quai de l’Ile, 1204 Geneva, Switzerland. The place of performance and jurisdiction is the registered office of the representative in Switzerland with regards to the Shares distributed in and from Switzerland. The Private Placement Memorandum, the Articles of Association and the annual financial statements can be obtained free of charge from the representative in Switzerland and are available only to Qualified Investors.

• Payment of retrocessions: Markham Rae LLP and its agents do not pay any retrocessions to third parties in relation to the distribution of the Shares of the Fund in or from Switzerland.
• Payment of rebates: Markham Rae LLP and its agents do not pay any rebates which aim to reduce fees and expenses paid by the Fund and incurred by the investors.

In the US, the Funds discussed within this website are only available to “accredited investors” (as defined in Rule 501(a) of Regulation D promulgated under the US Securities Act of 1933, as amended), which also qualify as “qualified purchasers” (as defined in Section 2(a)(51) of the US Investment Company Act of 1940, as amended (the “Investment Company Act”) and the regulations promulgated thereunder.)  The Fund is not and will not be registered as an investment company under the Investment Company Act.

This material must not be relied or acted upon by any other persons. None of the products or services referred to within this website are available to the general public in any jurisdiction. The contents of this website are not intended to and shall not in any way constitute an offer to sell nor a solicitation to buy an interest in any of the investment products that are mentioned. This website is not intended to furnish any investment advice or services and it is provided solely for informational purposes and do not constitute investment, legal, tax or other advice.

The internet is not a reliable transmission medium and neither GSA nor any of their affiliated companies accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from GSA or any of their affiliated companies. Any such transmission of information is entirely at your own risk.

This site uses cookies to store information on your computer.  Some of these cookies are essential to make our site work and have already been set. Others help us to improve by giving us some insight into how the site is being used or help to improve the experience of using our site but will only be set if you consent.

Markham Rae LLP is registered in England and Wales at 1 Knightsbridge Green, London SW1X 7QA, with number OC354686. Phone Number: 020 7590 5100.