Privacy Policy

Welwing Privacy Notice (UK, DIFC, EEA, Hong Kong and Cayman Islands)

Welwing Capital Group Limited (“WCG”), Welwing Capital Management (UK) LLP, Welwing Capital (UK) Limited and Welwing Capital Management (DIFC) Limited (collectively, “Welwing” or “we“, “our” or “us“) aim to protect your privacy as far as possible. Welwing is what is known as a “data controller” or “data user” for the purposes of UK, EEA, Dubai International Financial Centre (“DIFC”), Hong Kong and Cayman Islands data protection laws.Welwing may amend this notice from time to time without prior notification to intended recipients. This notice was last updated on 24 August 2026.

Applicability of this Privacy Notice

This notice describes how we use personal data. It applies to employees, contractors, recruitment applicants, former employees, professional contacts, visitors to our website, or others with whom we may communicate.

If you are (a) an individual who has invested in a fund for which WCG is the investment manager (a “Fund”), or who has invested in a Cayman Feeder Fund (an “Individual Investor”), or (b) an individual who is an authorised person (such as a partner, director, significant shareholder, founder, trustee, beneficiary or authorised signatory) of a legal person that has invested in such a Fund or Cayman Feeder Fund (an “Authorised Person”, and such legal person, an “Institutional Investor”), you should read this Privacy Notice together with the Supplemental Privacy Notice for Investors in WCG Funds and Cayman Feeder Funds and Related Authorised Persons set out below, which provides additional information about how Welwing handles your personal data in that context.

How we obtain your information

We may collect personal information from you when you use our website or otherwise engage in communication with us including, for example, submitting an employment application, or when you (or any entity you represent) enter into a contractual relationship with us, including, for example, as an employee or service provider.

We collect information about you from a variety of sources and generate certain information about you, which may include:

our communication or correspondence with you, such as when you contact us by letter,
telephone, email or any other means of electronic or personal communication;
your use of our website (including by use of cookies; for our cookie policy, please visit Terms of Use on www.welwingcapital.com);
your use of the Guest Wi-Fi services on your personal device(s) at our Hong Kong office (Room 1705-08, St George’s Building, 2 Ice House Street, Central), our London office (3 St James Square, London, SW1Y 4JU) or our DIFC office (Unit 39 and 40, Level 20, Central Park Towers, Sheikh Zayed Rd, DIFC, Dubai, United Arab Emirates); or
agents, intermediaries, service providers and other third parties, such as:
recruitment agencies and background screening providers, in connection with potential employment or other contractual engagement. and

Please note that, in accordance with regulatory requirements, we record calls made on certain employees’ landline and mobile telephone lines.

The information we collect

Depending on the nature of your relationship with Welwing, we may collect or may have collected the following categories of data about you:
your name, title, contact details;

your name, title, contact details;
other personal information such as your age, date of birth and marital status;
information related to your occupation, such as your job title and CV;
unique identifiers such as your government-issued social security number, national insurance number, tax file number, IP address and information related to that IP address;
details from your passport, as required and permitted by applicable laws and regulations addressing due diligence and related matters;
photographs and video footage as required for the purpose of:
– generating and maintaining our internal directories and our website;
– promoting work-related events; and
– generating publicity materials and marketing communications;
financial information such as your bank account details; and
other information you or others may provide to us during your communications or relationship with us, for our operational or business purposes.

In limited cases, we may also collect sensitive personal data, which may include:

“special categories” of personal data, which may include personal details relating to your immediate family members and details relating to any senior political figures (e.g. senior military or government official) to whom you are connected, information relating to political affiliations or trade union membership; and
information about actual or alleged criminal convictions and offences.

Certain information may be required for legal or regulatory compliance purposes, or to enter into or perform a contract with you or the organisation you represent. Our request for personal data is mandatory, unless we tell you otherwise at the point of collection that it is optional. Where relevant, we will explain the possible consequences of not providing the requested data.

If you provide personal data on behalf of another person, it is your responsibility to notify that individual that you have provided their information to us and direct them to this notice.

Our use of your information

We may share your information within Welwing’s group, with our third party business partners, business associates, subcontractors and other third parties for the purposes set out below.

Communications and relationship management
- to communicate with you and manage our relationship with you;
- to respond to your enquiries, correspondence and requests; and
- to maintain contact records and internal directories.
Recruitment and engagement
- to consider and process applications for employment or other contractual engagement with us;
- to carry out recruitment activities; and
- to take steps before entering into a contract with you or the organisation you represent.
Contractual, employment and business administration
- to enter into, perform, administer and manage contracts and other working or business relationships with you or the organisation you represent;
- to administer and manage employment and contractor relationships; and
- to administer and manage the operation of our business.
Website, systems and office-related services
- to operate, administer and improve our website, including through the use of cookies and similar technologies; and
- to provide and administer Guest Wi‑Fi services at our offices.
Marketing, publicity and business promotion
- to promote our business, including to clients and prospective employees and workers;
- to include photographs or video footage on our website, where relevant;
- to promote work-related events; and
- to prepare publicity materials and marketing communications, including direct marketing communications, where permitted by applicable law.
Legal, regulatory and compliance purposes
- to comply with applicable legal and regulatory obligations;
- to carry out due diligence and related checks, where required or permitted by applicable laws and regulations;
- to process and share relevant personal data with investors or prospective investors in connection with investor due diligence (including background checks on key personnel);
- to verify identity and background information, where relevant to a potential or ongoing employment or contractual relationship;
- to record calls made on certain employees’ landline and mobile telephone lines in accordance with regulatory requirements; and
- to maintain compliance with internal policies and procedures.
Workforce and group management
- to ensure a consistent approach to the management of our employees and workers, and those of our affiliate companies worldwide.
Sensitive information / special category data purposes (where relevant)
- to comply with legal or regulatory requirements relating to special category or similar sensitive information;
- to protect health and safety;
- to monitor equality and diversity;
- to prevent or detect crime or similar misconduct;
- to manage occupational pension schemes; and
- to establish, exercise or defend legal claims.

We process your information for the purposes set out above because the processing is necessary for the performance of a contract with you, or in order to take steps at your request before entering into a contract with you; because it is necessary to comply with applicable laws or regulations; because it is necessary for legitimate interests; or on the basis of your consent.

Our legitimate interests include:

allowing us to effectively and efficiently administer and manage the operation of our business;
allowing us to promote our business, both to clients and to prospective employees and workers as a place to work;
allowing us to carry out recruitment of employees and workers;
ensuring a consistent approach to the management of our employees and workers and the employees and workers of our affiliate companies worldwide; and
maintaining compliance with internal policies and procedures.

Where we process “special categories” of information about you, we do so on one of the following bases: your explicit consent, legal or regulatory requirements, health and safety, monitoring of equality and diversity, prevention or detection of crime or similar misconduct, management of occupational pension schemes, or because the processing is necessary for the establishment, exercise or defence of a legal claim. Personal data relating to criminal convictions and offences are processed only where the processing is carried out under the control of official authority or is authorised by applicable law.

Automated decision-making and profiling

We do not make decisions about you based solely on automated processing (including profiling) that produce legal or similarly significant effects for you. If we do introduce such processing, we will inform you beforehand.

How we share your information

We may share your information within Welwing’s group, with our third party business partners, business associates, subcontractors and other third parties for the purposes set out below.

Within the Welwing group, to our third party service providers and trading counterparties: We may disclose your personal information to third parties, including our affiliates, subcontractors, agents and any person who provides professional, legal, tax or accounting advice or other services to Welwing. We may also disclose your personal information to trading counterparties as necessary to facilitate a transaction. All such third parties are required to maintain the confidentiality of such information to the extent they receive it.
Potential buyers, transferees, merger partners or sellers: We may disclose your personal information to a potential buyer, transferee, or merger partner or seller and their advisers in connection with any actual or potential transfer or merger, sale, acquisition, assignment, transfer, or other disposition of part or all of Welwing’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
Legal reasons: We may also disclose your personal information or any portions thereof (a) as required by, or to comply with, applicable law, regulation, court process or other statutory requirement; and (b) to respond to requests from any regulatory, supervisory or governmental authorities.

How we transfer your information

Due to the global nature of our business, your information may be transferred to jurisdictions outside the UK, EEA, DIFC, Hong Kong or the Cayman Islands. Such jurisdictions may not offer the same level of data protection as in your home jurisdiction and may not be regarded by the European Commission or other relevant regulators as providing an adequate level of data protection.

Where we transfer your information outside of your home jurisdiction, we will ensure that personal data is protected and transferred in accordance with applicable legal requirements, which can be done as follows:

the country to which we send personal data may be one that has been recognised by the European Commission or under the UK, DIFC, or Cayman Islands data protection laws (as applicable) as having adequate level of protection for personal data; or
the recipient may have signed a contract based on standard contractual clauses approved by the European Commission or other contractual transfer safeguards recognised under applicable data protection laws, obliging them to protect your personal information.

You can obtain more details about the protection given to your personal data when it is transferred outside the UK, DIFC and EEA (including a copy of the applicable contractual safeguards which we have entered into with recipients of your personal data) by contacting us as further described in the “Contact us” section below.

Security and retention of information

We take the protection of your personal information seriously, and have security measures, controls and policies in place.

We will hold your personal information on our systems for the longest of the following periods:

as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with us;
the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;
any retention period that is required by law; or
the end of the period in which litigation or investigations might arise in respect of your use of our website or the services that we provide to you.

Cookies

For further information on our use of cookies, please refer to Terms of Use on our group website at www.welwingcapital.com.

Your rights

Depending on the country in which you reside or the laws that apply to the Welwing entity that you are engaging with, data protection laws may provide you with rights to access data, as well as rights for data to be erased, corrected, used for only limited purposes, not used at all, or transferred to you or a third party.

You may have the following rights under data protection laws:

Right of subject access: The right to make a written request for details of personal data about you held by Welwing and a copy of that personal data.
Right to rectification: The right to have inaccurate information about you rectified.
Right to erasure (‘right to be forgotten’): The right to have certain personal data about you erased.
Right to restriction of processing: The right to request that your personal data is only used for restricted purposes.
Right to object: The right to object to the use of personal data at any time, including for direct marketing communications, and (if applicable) to object to automated processing (including profiling) that has legal or similarly significant effects, with the right to require manual review where applicable.
Right to data portability: The right to ask for personal data you have made available to us to be transferred to you or a third party in machine-readable formats. Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal data. If you withdraw your consent, this will not affect the lawfulness of Welwing’s use of your personal data prior to the withdrawal of your consent. If you have given consent for us to use your personal data for direct marketing, you have the right, at any time, to withdraw such consent and request that we cease using your personal data for direct marketing purposes.
Right to Complain: The right to raise a complaint with Welwing regarding the processing of your personal data
Right to non-discrimination: The right not to be discriminated against for exercising any of these rights.

Even if they do apply under data protection law, these rights are not absolute: they do not always apply and exemptions may be applicable. We may, in response to a request ask you to verify your identity and to provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.

To exercise any of these rights, or if you have any other questions about our use of your information, please email us at: compliance@welwingcapital.com.

If you are unhappy with the way we have handled your information you have a right to complain to your local data protection regulator.

In the UK, your local regulator is the Information Commission, whose website is available at https://ico.org.uk
In Hong Kong, your local regulator is the Office of the Privacy Commissioner for Personal Data, who can be contacted at complaints@pcpd.org.hk
In the DIFC, your local regulator is the DIFC Commissioner of Data Protection, who can be contacted at commissioner@dp.difc.ae

Contact Us

If you have any questions about this privacy notice, or our privacy related practices, you can contact: compliance@welwingcapital.com and Welwing Capital Group Limited, Room 1705-08, St George’s Building, 2 Ice House Street, Central, Hong Kong.

Supplemental Privacy Notice for Investors in WCG Funds and Cayman Feeder Funds and Related Authorised Persons

This notice sets forth the personal data privacy practices of WCG and other Welwing entities ¹ with respect to the personal data of Individual Investors and Authorized Persons (collectively, “Investor Parties”).

This supplemental notice should be read together with the main Welwing Privacy Notice. If there is any inconsistency between this supplemental notice and the main Welwing Privacy Notice, this supplemental notice will prevail to the extent necessary to resolve that inconsistency.

¹ For the purpose of this supplementary notice, “Welwing” encompasses its offices and subsidiaries worldwide. These include, but are not limited to, Welwing Capital Group Limited, a licensed corporation regulated by the Securities and Futures Commission (“SFC”) in Hong Kong (CE#: BOP594), as well as registered as an Exempt Reporting Advisor with the Securities and Exchange Commission in the United States (CRD#: 306751). Welwing Capital Management (UK) LLP (FRN: 985443) is authorised and regulated by the Financial Conduct Authority (FRN: 985443). Welwing Capital Management (DIFC) Limited is authorised and regulated by the Dubai Financial Services Authority (FRN: F009043). Welwing Master Fund (1607745), Welwing Fund (1607572) & Welwing US Fund (1607594), registered with the Cayman Islands Monetary Authority.

Data We Collect

Welwing collects personal data of Individual Investors, including: last name, first name, date and place of birth, contact information, bank information, tax identification number(s), country of tax residence(s), residence address (including proof thereof), source of funds, official government-issued identification (such as a passport or national ID), net worth standard qualification, as well as financial information, such as assets held in the account or payments made with respect to the account, account balances, proceeds from the sale or redemption of property paid or credited to the account together with any other information which may be necessary to satisfy our know-your customer obligations or which is required by applicable laws.

Welwing also collects names and identity verification documents of Authorized Persons, as applicable.

Use of Investor Parties’ Personal Data and Legal Basis for Processing.

Welwing will use Individual Investors’ or Authorized Persons’ personal data in the course of business for the purposes of conclusion and performance of contracts with Individual Investors or Institutional Investors, including, specifically: (a) entering into the Subscription Agreement, (b) processing subscriptions, redemptions/withdrawals, transfers and other changes in an investor’s status, (c) maintaining the registers of investors, (d) providing financial and other information to Investor Parties, (e) maintaining global client records and providing centralized administrative and investor relations and related services and (f) complying with applicable anti-money laundering rules, tax reporting requirements and other legal obligations.

In the case of Individual Investors, Welwing processes personal data because it is necessary for the performance of a contract or to satisfy an applicable regulatory or legal obligation, which may arise under applicable laws. In the case of Authorized Persons, Welwing processes personal data on the basis of a legitimate business interest (including administering subscriptions, redemptions/withdrawals, transfers and other changes in investor status, maintaining investor registers, providing financial and other information to Investor Parties, and maintaining global client records and centralized administrative and investor relations and related services), as a necessary element of entering into and performing contracts with Institutional Investors, or to satisfy an applicable regulatory or legal obligation, which may arise under applicable laws.

Disclosure to Certain Third Parties

Welwing may disclose certain personal data: (a) to its affiliates and service providers, such as fund administrators, auditors, legal and tax advisors or broker-dealers; (b) to fraud prevention agencies and law enforcement agencies; (c) to courts, governmental and nongovernmental regulators, tax authorities and ombudsmen; (d) to any third party that acquires, or is interested in acquiring, all or part of Welwing’s assets or shares, or that succeeds Welwing in carrying on all or a part of its business, whether by merger, acquisition, reorganization or otherwise; (e) as required or permitted by law, including to comply with a subpoena or similar legal process or government request, or when Welwing believes in good faith that disclosure is legally required or Welwing has a legitimate interest in making a disclosure, such as where necessary to protect Welwing’s rights and property; or (f) as directed or authorized by the subject of the personal data.

Obligations of Institutional Investors.

Each Institutional Investor must ensure that it has complied, and shall continue to comply, with its obligations relating to personal data that apply to it under the applicable data privacy laws in the UK, EEA, Dubai, Hong Kong or Cayman Islands, and any other jurisdiction in which that Institutional Investor has any operations.

Institutional Investors are reminded that it is their responsibility to: (a) provide adequate notice, and obtain valid consents from, Authorized Persons, in each case, to the extent necessary for Welwing to process personal data in connection with any Subscription Agreement that the Institutional Investor and Welwing are parties to (including cases in which the Institutional Investor may transfer personal data to Welwing in the UK, Hong Kong, Dubai or Cayman Islands and/or countries both within and outside of the EEA); (b) ensure that they shall not, by act or omission, cause Welwing to violate any data privacy law notices provided to, or consents obtained from, individuals as a result of processing personal data for any purpose relating to any Subscription Agreement, a shareholder’s ownership of shares in a Fund or an Institutional Investor’s ownership of interests in a Fund (as applicable); and (c) ensure that Welwing is informed when an Authorized Person is no longer associated with the Institutional Investor.

For any questions regarding this notice, please contact compliance@welwingcapital.com.

Terms of Use

1. Welwing Capital Management (UK) LLP
  - 1.1 The UK Terms of Use stated below is issued by Welwing Capital Management (UK) LLP (“WCUK” or the “Company”, “we”, or “us”) which is authorised and regulated by the Financial Conduct Authority of the United Kingdom (the “FCA”) (Reference Number: 985443). You can gain access to the FCA’s rules and guidance notes from the following link: http://www.fca.org.uk.
  - 1.2 WCUK is a limited liability partnership registered in England (Company Number: OC439846), with its principal business address at 3 St James Square, London, SW1Y 4JU and its registered office at 4th Floor, Phoenix House, 1 Station Hill, Reading, Berkshire, RG1 1NB, United Kingdom.
  - 1.3 General enquiries about this Website should be sent to info@welwingcapital.com.
    Enquiries about investments in any WCUK managed product should be sent to ir@welwingcapital.com.
2. These Terms
  - 2.1 These Terms set out the terms on which you may use this Website, and apply to all pages, even where they are not individually disclaimed. These Terms also incorporate our Cookies and Privacy Notice (please refer to section 3 below) and all other policies and procedures that we may publish from time to time on this Website. Each of these is incorporated by reference and may be updated from time to time without notice.
  - 2.2 By using this Website, you confirm that you accept these Terms, and that you will comply with them. If you do not agree to these Terms, you are not permitted to use this Website.
3. Cookies and Privacy
  - 3.1 This Website uses cookies. By continuing to use this Website you are giving consent to cookies being used.
  - 3.2 For information on cookies and how you can disable them, please visit our Cookies Policy.
  - 3.3 For information on how WCUK uses certain other types of personal data, please refer to our Privacy Notice.
4. The Financial Reporting Council’s Stewardship Code
  - 4.1 Under the rules of the FCA Handbook, WCUK is required to include on this Website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Stewardship Code”) or, where it does not commit to the Stewardship Code, its alternative investment strategy.
  - 4.2 WCUK’s Stewardship Code disclosure statement is available on this Website.
5. Intended Audience of the Website
  - 5.1 This Website is directed only at persons who are professional investors (for the purposes of the Alternative Investment Fund Managers Directive (2011/61/EU) (“AIFMD”)) (“Professional Investors”); professional clients or eligible counterparties (for the purposes of the Markets in Financial Instruments Directive (Directive 2004/39/EC) (“MiFID”)) (“Professional Clients” or “Eligible Counterparties”); or as otherwise defined under applicable local regulations and at whom this site and the information on it may lawfully be directed in any relevant jurisdiction. Please contact us at info@welwingcapital.com if you require any further information on your status.
  - 5.2 By accepting these Terms, you hereby certify that you are a Professional Investor, a Professional Client or an Eligible Counterparty.
  - 5.3 It is your responsibility to inform yourself, and to comply with, all relevant legal or regulatory requirements of any jurisdiction of which you are a citizen, in which you are resident, or in which you are accessing this Website which may affect your eligibility to access the Website or subscribe to any investment services that WCUK offers. In particular, it may be illegal to view and/or download the information contained on this Website in certain countries and we disclaim all responsibility if you access or download any information from this Website in breach of any law or regulation of the country in which you are a citizen, or in which you are resident or domiciled.
  - 5.4 The services, funds, and products described on this Website are not available in all countries or to all investors. As such, this Website and the information on it are not addressed to any person resident in the territory or country or jurisdiction where such distribution would be contrary to local law or regulation. Some funds are not available, and offering materials relating to them will not be distributed, to persons resident in any country where such distribution would be contrary to local law or regulation.
  - 5.5 Any person subscribing for an investment, product, or service referred to on this Website must be able to bear the risks involved with such investment, product, or service, and must meet the applicable suitability requirements relating to such investment, product or service. Some or all investment programs offered by WCUK may not be suitable for certain investors.
  - 5.6 If you are not clear about the meaning of anything on this Website or other information provided by WCUK, you should seek professional advice.
6. Right to Deny Access
  - 6.1 WCUK reserves the right to deny you access to this Website. We may immediately suspend or terminate your access to this Website or disable any username or password (whether chosen by you or allocated to you by us), at any time, and at our sole discretion.
  - 6.2 We may have reason to update the Website from time to time, though we are not under any obligation to do so. We may update or remove information from the Website without notice. From time to time, we may restrict or suspend access to some parts of the Website, or the entire Website, for example for maintenance purposes. As such, access to the Website is not necessarily permanent or guaranteed.
7. Your Responsibilities
  - 7.1 When you use this Website, you agree that you will not:
    - a. use the Website for any unlawful, improper or illegal purpose or activity, nor will you use this Website to damage our name or reputation, or that of any third party;
    - b. misuse the Website by knowingly introducing viruses, Trojan horses, worms, logic bombs or other material which is malicious or technologically harmful. You must not try to gain unauthorised access to the Website, the server on which the Website is stored, or any server, computer or databases connected to our website. You must not attack the Website using a denial-of-service attack or a distributed denial-of service attack;
    - c. violate our, or any third party’s copyright, trademark, proprietary or other intellectual property rights, as outlined further below;
    - d. access, copy, or otherwise use the Website, except as authorised by these Terms or as otherwise authorised in writing by WCUK in its sole and absolute discretion; and/or
    - e. impersonate any person or entity, use a fictitious name, or misrepresent your affiliation with a person or entity.
8. Use of Website Content
  - 8.1 In the United Kingdom, the issue and communication of this Website has been approved by WCUK. If you are in the United Kingdom or in any EEA member state, you should note that this Website may contain information or documents which constitute a financial promotion for the purposes of the Financial Services and Markets Act 2000 and the FCA Rules. This Website is issued only to and/or is directed only at persons who are Professional Clients, Eligible Counterparties or Professional Investors.
  - 8.2 The information in this Website does not constitute an offer of, or an invitation to apply for or purchase any securities, investments, products or services. WCUK does not provide investment advice to, nor receive and transmit orders from, investors in any funds, nor do we carry on any other activities with or for such investors that constitute ‘MiFID or equivalent third country business’ for the purposes of the FCA Rules.
  - 8.3 The information and opinions on this Website do not constitute an investment recommendation, or other information recommending or suggesting an investment strategy.
  - 8.4 The information and opinions contained on this Website have been compiled, or arrived at, by us from sources believed by us to be reliable as at the date of publication, however it is subject to change with no notice. The information and opinions do not in any way constitute investment, legal, tax or other advice and are for background purposes only.
  - 8.5 This Website is not intended to provide a sufficient basis on which to make any investment decision and you should not solely rely on it in evaluating the merits of investing in any investments, products or services referred to on this Website. Any decision to purchase securities or interests with respect to any funds must only be made having thoroughly read the relevant prospectus or offering memorandum for the relevant fund, including any supplements, which must be received and reviewed prior to any investment decision and which may contain information which is different from the information and opinions contained on this Website.
  - 8.6 There is no way to invest through the Website. Enquiries about investments in any WCUK managed product should be sent to ir@welwingcapital.com
9. Accuracy of Information
  - 9.1 We have taken reasonable care to ensure that the information on this Website is accurate, current, fit for its intended purpose and compliant with applicable law and regulation. However, errors and omissions may occur due to circumstances beyond our control, and neither WCUK nor its affiliates offer any warranties or representations regarding the accuracy, validity or completeness of the information on this Website.
  - 9.2 As such, WCUK and its affiliates expressly exclude liability and responsibility arising from your reliance on the information and other materials on the Website, or the reliance of anyone with whom you share the materials.
  - 9.3 You must conduct your own due diligence and investigations rather than relying on any information on this Website. Any person who acts on, or changes their investment position in reliance on, the information contained on this Website does so entirely at their own risk.
10. Our Liability
  - 10.1 Further to paragraph 9, neither we nor our affiliates accept any responsibility for any reliance which is placed by any visitor to this Website, or by anyone who may be informed of any of its contents, on any information or opinions which are expressed herein and, to the extent permitted by law, expressly exclude all conditions, warranties, representations, undertakings and other terms which might otherwise be implied by statute, common law or in equity.
  - 10.2 WCUK and its affiliates shall have no 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 our Website or other services.
  - 10.3 Further, you agree that if you transmit confidential or proprietary information through the Website, you do so entirely at your own risk.
11. Your Indemnity
  - 11.1 You agree to indemnify, defend, and hold harmless WCUK, its affiliates and our respective officers, partners, employees, and agents from and against all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your breach of the Terms and/or access to or use of this Website.
12. Third Party Websites
  - 12.1 At times this Website may contain links to or from other websites over which WCUK has no control. These links are solely for your convenience or information, and may be subject to their own terms and conditions. We cannot verify the accuracy of any information contained in third party websites, nor does the inclusion of these links represent an endorsement or a recommendation of the third-party websites. WCUK accepts no liability for the content of any website to which the Websites link.
13. Investment Performance
  - 13.1 You should note that investments do involve risk and past performance is not a guide to future performance. The value of your investments and the income from them may go down as well as up, and returns are not guaranteed. Tax reliefs may change as per the UK budget from time to time, as they have done previously, and rates of exchange may cause the value of investments to go up or down.
14. Calls Recorded
  - 14.1 For the protection of all parties, telephone calls to WCUK or its affiliates may be recorded.
15. Intellectual Property
  - 15.1 We are the owner of all intellectual property rights in the Website, and the material published on it, including, among other things, all trademarks, logos, service marks and service names, whether they are registered or not. These works are protected by, among other things, copyright laws and treaties around the world. We reserve all such rights.
  - 15.2 You may use, download, and reproduce in hard copy, the Website and any materials located on it for your own reference only. You must not otherwise copy, reproduce, republish, disassemble, decompile, reverse engineer, download, post, broadcast, transmit, make available to the public, or otherwise use Website content in any way without licence from us. You also agree not to adapt, alter or create a derivative work from any Website content.
  - 15.3 Nothing on this Website should be construed as granting any licence or right in relation to any of our trademarks, or any third party.
16. Changes to Terms
  - 16.1 We may revise these Terms from time to time by updating this page. The revised Terms will take effect when they are posted. You are expected to check this page from time to time and to take notice of any changes we may have made, as by using this Website you acknowledge that you have accepted any such amendments.
17. Severability
  - 17.1 In the event that any provision of these Terms is determined to be unlawful, void or unenforceable, such provision shall nonetheless be enforceable to the fullest extent permitted by applicable law, and the unenforceable portion shall be deemed to be severed from these Terms (such determination shall not affect the validity and enforceability of any other remaining provisions). When used in these Terms the words ‘includes’, and ‘including’ shall be deemed to be followed by the phrase ‘without limitation’.
18. Material Interests
  - 18.1 We and our partners, officers and/or employees may have holdings in the investment funds referred to on this Website and may otherwise be interested in transactions that you effect in those funds.
19. Term and Termination
  - 19.1 These Terms will apply to you as soon as you access the Website and will continue to have effect until they are terminated or if you are no longer interacting with us.
  - 19.2 We may terminate your right to use the functions of our Website at any time, including if you violate or breach these Terms or if allowing you to access and use the Website or its related functions would violate any applicable local, state, provincial, national and other laws, rules and regulations, or would expose WCUK to any legal liability whatsoever.
  - 19.3 If these Terms are terminated or you are no longer interacting with WCUK, these Terms may no longer apply. However, any provisions of the Terms that by their nature should continue to apply after termination of these Terms will do so. This includes, without limitation, all limitations on liability, choices of law and judicial forum and intellectual property protections and licences.
20. No Waiver
  - 20.1 No waiver by us shall be construed as a waiver of any preceding or succeeding breach of any provision.
21. Third parties
  - 21.1We shall have the benefit of the rights conferred on us by these Terms but otherwise no person who is not a party to these Terms may enforce its terms under the Contracts (Rights of Third Parties) Act 1999.
22. Entire agreement
  - 22.1 These Terms (incorporating our Cookies and Privacy Notice) and our Disclaimer shall form the entire agreement between you and us in relation to your use of this Website.
23. Governing Law
  - 23.1 These Terms and any non-contractual obligations arising from or connected with them shall be governed by and shall be construed in accordance with English law. English courts will have exclusive jurisdiction over any dispute arising from, or related to, use on this Website (whether arising out of or in connection with contractual or non-contractual obligations) (‘proceedings’) and it is a condition of using this Website that you waive any objection to proceedings in such courts on the grounds of venue or that proceedings have been brought in an inconvenient forum, although we retain the right to bring proceedings against you for breach of these Terms in your country of residence or any other relevant country.