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Privacy Statement

I.               Responsibility for personal data

Apera Asset Management (“Apera”) is committed to the following policies that protect your privacy and comply with current international data protection laws and regulations with respect to personal data.

Apera is the “data controller” for the personal information provided to Apera through This means that Apera will become responsible for how the personal data is dealt with by it and its associated third parties.

II.            Personal data collected

Apera will only obtain personal data from you for specified and lawful purposes and any personal data which Apera obtains will be processed fairly and lawfully.

Apera will take all reasonable steps to ensure that the data held is adequate, relevant and not excessive for the relevant purposes.

The servers hosting Apera’s website automatically record certain information about you when you use this site.  Apera may use this information to understand who has seen which pages in order that Apera can monitor and improve the Apera website.

If you submit information to us directly through this website (for example, in a request for general information or through the submission of information through the tools available on this website) we may record and use any personal data that you provide, such as your name, telephone number and e-mail address. This information may be used to respond to your request or for other internal business purposes.

III.          Disclosure to third parties

In relation to personal data processed in connection with Apera, Apera’s structure involves legal entities affiliated with it to allow it to operate and fulfil its aims.

Apera also relies on third parties to provide services to it. Apera may, therefore, transfer personal data to third parties from time to time including:

(a)     Apera’s legal and other advisers; and

(b)     Apera’s outsourced administrator or other providers, that provide administrative services to Apera and its affiliates.

There may also be circumstances where Apera is obliged by law to disclose personal data, including to law enforcement agencies and applicable regulators or in connection with legal proceedings.

IV.          Location of personal data

It may be necessary for Apera or associated third parties to effect cross-border transfers of personal data, including to the United States of America and to other countries outside the European Economic Area (the “EEA”).  In some cases, personal data may be transferred to jurisdictions outside of the EEA that are not deemed to have data protection frameworks that are equivalent to those of the EEA countries, such as the United States of America. Such transfers may be to other Apera entities, to governmental, regulatory or judicial authorities, auditors, legal advisors or agents as well as to sub-contractors engaged by Apera. Apera uses data transfer agreements incorporating standard contractual clauses approved by the European Commission to transfer personal data to such jurisdictions.

V.             Retention periods

Apera and those third parties to whom personal data is transferred will retain that data as long as is necessary for the purposes set out in Section II.  The retention period may extend where necessary for Apera’s legitimate interests, including to comply with legal or regulatory obligations or to facilitate the Apera’s on-going administration and performance.

VI.          Individual rights

Individuals whose personal data is processed by Apera have certain legal rights in respect of the information.  These include:

  • The right to request access to personal data.
  • The right to obtain information about the use of personal data including: (i) the purposes for which personal data is being used; (ii) the categories of personal data being used; (iii) to whom personal data has been or will be disclosed; (iv) where possible, the period for which data will be retained; (v) the right to require rectification or erasure of personal data or restrict or object to its use; (vi) the right to lodge a complaint with a supervisory authority; and (vii) whether personal data is subject to any automated decision-making including profiling.
  • The right to require rectification (correction) of errors in personal data without undue delay.
  • The right to have personal data erased without undue delay in certain circumstances including where: (i) the personal data no longer needs to be processed for the purposes for which it was collected; (ii) the personal data has been processed unlawfully; and (iii) erasure is required by applicable law.
  • The right to restrict the processing of personal data in certain situations including where: (i) the data subject is contesting the accuracy of the personal data; (ii) the data is being processed unlawfully but the data subject does not want the data erased; (iii) the personal data is no longer needed for the purposes for which the data subject provided it but the data subject requires that data to help establish, exercise or defend legal claims.
  • The right to receive personal data in a structured, commonly used and machine-readable format and transmit that data to a third party.

If an individual wishes to exercise any of these rights and Apera has transferred that person’s data to a third party, Apera will communicate that request to the relevant third party unless it would be impossible or involve disproportionate effort for Apera to do so.

VII.        Feedback or Complaints

Any questions about the statement of this Policy or Apera’s use of personal data should be addressed to Robert Shaw via email at or post at 33 Cavendish Square, London W1G 0PW, United Kingdom.

Issues or concerns individuals have regarding their personal data can also be brought to the attention of the UK Information Commissioner’s Office or any applicable supervisory authority.

Information regarding the UK Information Commissioner’s Office and its powers can be found on its website at

Information regarding the Luxembourg National Commission for Data Protection and its powers can be found on its website at