Privacy Policy


Black Ant Group LLP (“BAG”) (the “Firm”) and the funds managed/advised by the Group (the "Funds") have requirements under data protection legislation and other regulations that govern the privacy of non-public personal information about clients, investors, potential investors, employees, potential employees and any business contacts, and impose restrictions on the ability to disclose that information.

The following privacy policies and procedures are designed to ensure that we maintain the confidentiality of personal information about you and that we comply with applicable data protection laws and privacy regulations. They also inform you about the Firm's data processing practices which will govern the processing of any personal data.

Any personal data obtained in the course of providing our services to you will be held and processed by us in accordance with the relevant data protection legislation and privacy regulations. Such processing may occur for anyone of the following reasons:

  1. To provide the services described herein;
  2. For purposes required or permitted by law, such as where reasonably necessary to prevent fraud, unauthorised transactions or liability, to respond to judicial process or subpoena, or complying with applicable laws;
  3. For the marketing by the Firm of other financial services and products to you e.g. to analyse and track sales trends and investment performance in aggregate form for your benefit. If you would prefer not to receive promotional material from us you may advise us separately in writing at any time. You can click here if you wish to email Investor Relations to advise them that you do not wish to receive such promotional material.

You provide us with personal information, such as your address, social security number, assets and/or income information, (i) in the Subscription Agreement and related documents, (ii) in correspondence and conversations with the us and our representatives and (iii) through transactions in the Funds.

We do not disclose any of this non-public personal information about our investors, separately managed account clients or prospective or former investors or separately managed account clients to anyone, other than to our affiliates, and except as permitted by law or regulation, such as to our accountants, lawyers, auditors, brokers, regulators and certain service providers, in such case, only as necessary to facilitate the acceptance and management of your investment or account and our relationship with you.

We will also release information about you if you direct us to do so, if compelled to do so by law or regulation, or in connection with any government or self-regulatory organisation request or investigation. For example, it may be necessary, under anti-money laundering and similar laws, to disclose information about investors or separately managed account clients in order to accept subscriptions from them.

We may also disclose information you provide to us to companies that perform marketing services on our behalf, such as third party institutions with which we engage in joint marketing. If such a disclosure is made, we will require such third parties to treat your private information with confidentiality.

We seek to carefully safeguard your private information and, to that end, restrict access to non-public personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. We maintain physical, electronic and procedural safeguards to protect your non-public personal information.

Electronic communications between parties in the course of business may be monitored by us in accordance with the relevant legislation.

You have a right to request access to any personal data held by the Group. You are entitled to ask for a copy of any personal information processed by the Group and to correct any inaccuracies relating to personal data concerning you which we hold or otherwise control for the purpose of processing.

Although we take all reasonable steps to ensure the security of your personal information over the Internet, such as using available means of encryption and privacy protection, the Internet is not an entirely secure environment and for this reason we cannot guarantee that information will not be intercepted read or copied by unauthorised parties. You accept these inherent security implications and will not hold the Firm responsible for any breach of security unless we have been negligent.


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