By accessing this site you agree to the following terms and conditions.

The information contained on this site is intended for general information purposes only. Bedrock Group has made all reasonable efforts to ensure that the information on this website is accurate at the time of inclusion, however there may be inaccuracies or occasional errors for which Bedrock Group apologises.

All intellectual property rights for this site, including without limitation all copyright, designs and trademarks, belong to us or are used by us with the permission of the owner. You have no right to copy, reproduce, modify, publish, upload, post, transmit or distribute any logo, graphic, text, sound or image on this website without prior written consent, except to the limited extent necessary to access the contents of this site.

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You shall not use this website for any illegal purposes and in particular agree that you shall not send, use, copy, post or allow any posting which is defamatory or obscene within the meaning of the Obscene Publications Act or which is abusive, indecent or in breach of the privacy of any person. You agree not to send any unsolicited promotional or advertising material, spam or similar materials or any volume messages that may interfere with the operation of this website or with the enjoyment of this website by other visitors.

Bedrock Group reserves the right at any time and without notice to enhance, modify, alter, suspend or permanently discontinue all or any part of this website and to restrict or prohibit access to it.

If you are in breach of these terms or of Bedrock Group's Privacy Policy, Bedrock Group may as its option, suspend or block your access to this website and refuse to provide you with any further access to it.

This website is provided to you free of charge, and Bedrock Group accepts no liability for any direct, special, indirect or consequential damages, or any other damages of whatsoever kind resulting from whatever cause through the use of any information obtained either directly or indirectly from this website. Your sole remedy is to discontinue using this website. These terms may be amended by Bedrock Group from time to time.

Your use of this website and downloads from it, and the operation of these terms & conditions, shall be governed in accordance with the laws of England and Wales. The English courts shall have exclusive jurisdiction over any dispute arising out of your use of this website. We have no liability to you for any loss or damage whatsoever arising in relation to or in any way in connection with this site or those to which it links.

1. Overview Article 5 of the General Data Protection Regulation (GDPR) States that Personal Data must be processed lawfully fairly and in a transparent manner. In line with the GDPR changes we are updating our Privacy Notice so you can better understand why and how we collect, process and destroy your data. We are committed to protecting and respecting your privacy. This policy, (together with the Terms and Conditions and any other documents referred to in it), sets out the legal basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
2. What types of Personal Data do we collect? We collect information about you when you opt-in in our newsletters as well as while onboarding you as a client. We also gather data information when you share information based on consent by participating in surveys or attending events. We may control, process and use your Personal Data, which may include:
   - Names
   - Postal addresses,
   - Email addresses,
   - Telephone numbers,
   - Bank Account statements,
   - Personal Investments
   - Or any other Personal Data that you provide to us.
   
   We may also, in appropriate cases and to the extent permitted by law, control, process and use certain special categories of Personal Data which are more sensitive in nature. Example of some of these cases may arise when undertaking "Know Your Customer" (KYC) on potential clients where potential restrictions may arise from political or religious beliefs; or while collecting information as part of our anti-money laundering (AML) checks, we may come across past criminal conviction offence that you or the directors of any company might have committed.
3. Identity of the FirmBedrock Asset Management (UK) Ltd (“Firm”) is part of Bedrock Holdings SA (“Group”) in Switzerland and its address is 33 Glasshouse St, London W1B 5DG. Other firms within the Group include Bedrock SA whose address is 4 Chemin des Vergers, 1208, Geneva, Switzerland and Bedrock Monaco S.A.M. whose address is 7 Boulevard des Moulins, Le Monte Carlo Palace, Monaco 98000 MC.
4. Lawful basis for Processing Where we act as Data Controller, we rely on the following legal basis for Processing your Personal Data:
   
   • Consent: if you are a recipient of our online direct marketing. If you have consented to receive marketing, you may opt out at a later date.
   • Legitimate Interest: if you are our client or prospect client, business affiliate, employee or potential employee, or our website visitor, we may decide to send you materials of interest such as information about our services/products which we believe it would beneficial to you All such decisions are subject to Legitimate Interests Assessment (LIA) in order to ensure that processing is in line with that Data Subjects’ rights.
   • Performance of Contract: if you are our client, supplier, employee, akin to employee or business affiliate or our website visitor;
   • Legal Obligation: if we process Personal Data according to requirements of domestic legislation as in the case AML checks
   
   Where we act as a Data Processor, we process Personal Data on behalf of Data Controller and we act on their written instructions.
5. Data protection officer The Firm has no regulatory obligations under the GDPR to appoint a DPO; the Firm has no data protection officer (DPO) currently appointed. The GDPR sets out guidelines on when the appointment of a DPO shall be required as follows:
   • where the scope or purpose of collecting data requires a regular systematic monitoring of the Data Subjects;
   • where the Firm processes special categories of data on a large scale;
   • where Processing is carried out by a public authority.
   
   The Firm has instead agreed to name a responsible officer (the “Responsible Officer”) who may be reached on gdpr@bedrockgroup.com.
6. Purpose of data collected The personal information we collect is for the following legitimate interest:
   
   • Provision of financial products and services;
   • Administration of your investments;
   • Promotion of ideas and events relating to services we provide;
   • Keeping your records accurate and up to date,
   • Maintenance of records of communications and management of your relationship with us;
   • Responding to your enquiries;
   • Compliance with any present or future law, rule, regulation, guidance, decision or directive (including those concerning anti-terrorism, fraud, AML and anticorruption);
   • Carrying out, in appropriate cases, KYC checks and other procedures that we undertake prior to you becoming a customer of ours;
   • Prevention and detection of fraud and other illegal activity or misconduct; and
   • Informing you about compliance with legal and regulatory obligations and provide related guidance.
7. Who we share our information with We will not share personal information about you with third parties without your consent. We are required, by law, to sometimes pass on some of this Personal Data to:
   
   • law enforcement agencies; financial regulators and other relevant regulatory authorities; government bodies; tax authorities; courts tribunals and complaints/dispute resolution bodies;
   • other bodies as required by law or regulation; or • related financial institutions such as trustees, custodians and sub-custodians; insurers; fraud protection agencies; and/or similar suppliers or service providers.
   
   To fulfil our contract with you, the Firm may sometimes pass information to:
   
   • Intra group entities who provide additional or complementary services
   • Third party IT Service Providers
   • Any other third-party services providers e.g. HR consultants.
8. International transfer outside the EEA The Firm does not transfer your personal information outside of the European Economic Area (EEA) unless the transfer is necessary for one of the reasons set out in the GDPR including the performance of a contract between the Firm and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving consent and, in some limited cases, for our legitimate interest.
   
   In these cases, we will follow the GDPR Guidelines in protecting the transfer of data to countries outside the EEA to ensure that the level of data protection afforded to individuals by the GDPR is not undermined.
   
   The Firm will only transfer Personal Data outside the EEA if one of the following conditions applies:
   
   • the European Commission has issued a decision confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subjects’ this refers to (individual’s resident rights and freedoms); this Includes Switzerland,
   • appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the Responsible Officer; this includes Monaco,
   • the Data Subject has provided Explicit Consent (Explicit Consent is where permission has been given by the Data Subject in writing to the proposed transfer after being informed of any potential risks).
9. Retention We will keep your Personal Data for no longer than reasonably necessary. We will retain your personal information in accordance with legal and regulatory requirements as set out in our Data retention policy.
10. Your rights and your Personal Data You have a right:
    
    • to request a copy of your Personal Data which the Firm or related data Controller holds about you;
    • to request the Firm or any related Data Controller to correct any Personal Data if it is found to be inaccurate or out of date;
    • to request your Personal Data is erased where it is no longer necessary for the Firm or related Data Controller to retain such data;
    • to withdraw your consent to the Processing at any time if consent constitutes the lawful basis for processing;
    • to object to Processing based on grounds relating to the Data Subject situation if the processing is necessary for the performance of a task carried out in the public interest or the processing is necessary for the purposes of the legitimate interest by us or a third party, unless such interest is overridden by your fundamental rights and interests;
    • to request a restriction is placed on further Processing;
    • to lodge a complaint with the Information Commissioners Office (the UK Supervisory Authority); you can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;
    • not to be subject to a decision based on automated Processing; the Firm does not practice such decision making.
11. Further Processing Where we may seek to further process your data other than for the original purpose for which it was collected, the Firm shall only further process such data where the new Processing is compatible with the original purpose.
12. Safeguarding measures We take your privacy seriously and take every reasonable measure and precaution to protect and secure your Personal Data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including, without limitation, encryptions.
13. Special Categories of Data Owing to the products and services that we offer, such as onboarding investors, performing AML checks, and other background checks, we sometimes need to process special categories of data which are deemed to be more sensitive in nature. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so. Where we rely on your consent for Processing Special Categories Data, we will obtain your explicit consent through electronic means.
14. Legitimate Interests (if applicable) We occasionally process your personal information under the Legitimate Interests’ legal basis. Where this is the case, we have carried out a LIA to ensure that we have weighed your interests and any risk posed to you against our own and that such interests are proportionate and appropriate such as for the purposes of HR, marketing and day-to-day operations.
15. Marketing When sending marketing materials to customers, we may have the option to rely on your consent or legitimate interest.
    
    We only use legitimate interests for marketing if we have assessed that the information being sent is beneficial to the customer, and have weighed our interests against your own and there is little to no risk posed, the method and content is non-intrusive, and the material being sent is something you would usually expect to receive.
16. Cookies, analytics and traffic data Cookies are small text files which are transferred from our website, applications or services and stored on your device. We use cookies to help us provide you with a personalised service, and to help make our website, applications and services better for you.
    
    We provide the following information with some explanations to ensure transparency to our users:
    
    what types of cookies are set;
    how long they persist on your user’s browser;
    what data they track;
    for what purpose (functionality, performance, statistics, marketing, etc.;
    where the data is sent and with whom it is shared;
    how to reject cookies, and how to subsequently change the status regarding the cookies.
17. Changes to our Privacy Policy Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email.

The information on this site has been approved and issued by Bedrock SA and Bedrock Asset Management (UK) Ltd, ( together “Bedrock). Bedrock Asset Management (UK) Ltd is authorised and regulated by the Financial Conduct Authority (“FCA”). This website contains information which is a financial promotion for the purposes of the FCA’s Handbook of Rules and Guidance (“FCA Rules”).

Pillar 3 Disclosure

The information does not constitute an offer or solicitation in any jurisdiction in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such an offer or solicitation. Persons interested in acquiring any investment should inform themselves as to: (i) the legal requirements within the countries of their nationality, residence, ordinary residence or domicile for such acquisition; (ii) any foreign exchange control requirement which they might encounter on the acquisition or sale of investments; and (iii) the income tax and other tax consequences which might be relevant to the acquisition, holding or disposal of any investment.

Restrictions on access to the information on this site:

United Kingdom:

To the extent investment funds are referred to on this site (together, the “Funds”), they are not recognised collective investment schemes for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the “Act”). Information on this site is exempt from the restriction in section 238 of the Act on the communication of an invitation or inducement to participate in a collective investment scheme on the grounds that such information is communicated to and/or directed at only persons who are categorised as professional clients or eligible counterparties (within the meaning of the FSA Rules) in relation to the Funds. The investments and investment services to which this site relates are only available to such persons and other persons should not act or rely on it. In particular, any investment or investment service to which this site relates is not intended for persons who are retail clients and will not be made available to retail clients.

United States:

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.

Other jurisdictions:

The information on this site is not directed at any person in any jurisdiction where it is unlawful to access and use such information.

It may be illegal to download the information contained in this site in certain countries and “Bedrock” and its associated companies disclaim all responsibility if you download any information from this site in breach of any law or regulation of the country in which you are residing.

Applications for shares in the Funds:

An application for shares in any of the Funds should only be made having read fully the relevant prospectus. It is your responsibility to read such prospectus and by making an application you will be deemed to represent that you have read such prospectus and agree to be bound by its contents.

Role of “Bedrock”

“Bedrock” does not provide investment advice to, nor receives and transmits orders from, investors in the Funds. “Bedrock” does not carry on any other activities for investors that constitute “MiFID or equivalent third country business” for the purposes of the FSA Rules.

Nothing contained in this site constitutes investment, legal, tax or other advice, nor is anything on this site a recommendation to invest in the Funds, any security, or any other instrument, nor is this site to be relied upon when making investment or other decisions. The information on this site is provided solely on the basis that you make your own investment decisions. Should you have any queries about the investment funds referred to on this site, you should contact your financial adviser.

Risk Factors:

Past performance is not a reliable indicator of future performance. The value of investments in the Funds, and the income from them may go down as well as up, and investors in the Funds may not get back all or any amount originally invested. Because of this, investors in the Funds are not certain to make a profit on their investments and investors may lose some or all of the money invested in the Funds. Returns may increase or decrease as a result of currency fluctuations.

Where this site refers to a particular tax treatment, please note that tax treatment depends on the circumstances of each investor in the Fund and may be subject to change in the future. Investors should consult their own tax adviser in order to understand any applicable tax consequences.

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 “Bedrock” and its associated companies to be reliable, but is not guaranteed as to its accuracy or completeness. Such information is provided without obligation on the part of “Bedrock” 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 Fund.

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 neither “Bedrock” nor any of its associated companies undertakes to update this site regularly.

No Liability:

The information and opinions contained in this site have been compiled, or arrived at, in good faith and on the basis of publicly available information, internally developed data and sources believed to be reliable as at the date of publication. However, no representation, warranty or undertaking, express or implied, is made by “Bedrock”, its associated companies or any other person as to the reliability, accuracy or completeness of the information contained on this site and no liability is accepted by such persons for the reliability, accuracy or completeness of such information. In no event will “Bedrock” or any of its associated companies or any of their directors or other employees be liable to any person for any direct, indirect, special or consequential losses or damages of any kind arising out of any use of this site or any other hyper-linked site or in reliance on the information and opinions contained in it from time to time, including without limitation, any loss of profit, business interruption, loss of programs or data on your equipment or otherwise.

You should be aware that the Internet is not a completely reliable transmission medium. Neither “Bedrock” nor any of its associated companies accepts 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. In addition, neither “Bedrock” nor any of its associated companies accept any responsibility for the security or confidentiality of information transmitted across the internet to or from “Bedrock” or any of its associated companies and any such transmission of information is entirely at your own risk.

Notwithstanding any statement on this website, “Bedrock” does not exclude or restrict any duty or liability that it has to its clients under the regulatory system in the United Kingdom.

Material Interests:

“Bedrock”, its associated companies and its and their members and/or directors, officers and/or employees may have holdings in the Funds and may otherwise be interested in transactions that investors effect in the Funds.

Linked Websites:

This site may be linked to third party websites or contain information provided by third parties. Neither “Bedrock” nor any of its associated companies makes any representation as to the accuracy or completeness of such websites or information, have not and will not review or update such websites or information. “Bedrock” cautions users of this site that any use made of such websites or information is at their own risk. Neither “Bedrock” nor any of its associated companies accepts 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.

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 “Bedrock”, its associated companies, their 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, stored in a data retrieval system or transmitted, in any form or by any means - electronic, mechanical, photocopying, recording or otherwise - without the prior written permission of “Bedrock”. Nothing on this site should be considered as granting any licence or right under any trademark of “Bedrock”, its associated companies or any third party.

Governing Law:

You agree that your use of this site and any dispute arising in relation to this site is subject to English law and you submit to the jurisdiction of the English courts in connection with any such dispute.

“Bedrock”:

“Bedrock Asset Management (UK) Ltd is a Limited Liability Company Registered in England and Wales with Registration Number 05171393 and Registered Office: 33 Glasshouse Street, London W1B 5DG

Bedrock SA is a Swiss company limited by shares incorporated in Geneva, Switzerland with registered number CH-660-0675004-1 and registered Office at 4 Chemin des Vergers, 1208 Geneva, Switzerland.