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Cookies & Privacy Policy

Privacy Policy of LGBR Capital London Limited on behalf of Semper Capital Management


1.1 We are LGBR Capital London Limited (“LGBR”), of 10 Throgmorton Avenue, London EC2N 2DL and we can be contacted regarding this privacy policy at Any personal information processed by LGBR is controlled by us and so we are considered the data controller of your personal information.

1.2 Our data protection officer is located in 10 Throgmorton Avenue, London EC2N 2DL  and can be contacted at


2.1 We have to comply with the Data Protection Act no 2472/1999, Law no 3471/2006 and from 25 May 2018 the General Data Protection Regulation (EU) 2016/679 when keeping personal data about you when we obtain, use, disclose or otherwise process such data.


3.1 We are committed to protecting your personal information and respecting your privacy.

3.2 This policy explains about the personal information that we collect from you, use and otherwise process in connection with your relationship with LGBR as a customer or potential customer. In particular, we explain the kinds of personal information that we collect from you, how we collect it, what we use it for and who we may share your personal information with. By “personal information” we mean information about you where you are, or could be, identified.


4.1 We collect personal information from you such as your name and contact details (such as office address and office email address), FCA number, your transactions with us, information about how you use our services and about how you use access to our websites. This may include information that you provide to us directly or through companies or agents we work with, as well as information which we collect when you use our services or through interviews or face-to-face meetings, applications, agreements, or through inquiries by mail, e-mail or telephone.


5.1 We collect personal information about you whenever you use our services (whether services provided directly by us or by other companies, your investment advisors or agents acting on our behalf), through transaction with us or when you use our websites.


6.1 We use your personal information to conduct our business and to provide you with the best possible services.

6.2 We also use your personal information to:

6.2.1 provide the services, and effect the transactions, you have asked us to provide;

6.2.2 communicate with you about the services you have asked us to provide;

6.2.3 provide you with marketing and offers from us (where we have your permission to do so);

6.2.4 improve our services; and

6.2.5 comply with our security obligations.


7.1 To best serve you, we may share your personal information with service providers that provide support services to us or that help us market our products and services. Service providers are third parties who perform services on our behalf. They are contractually restricted from using your information in any manner other than in helping us to provide you with the products and services available from LGBR.

7.2 We may share your personal information with the managers who’s products we distribute and work with to better perform our services.7.3 We may also disclose your personal information to a third party when you ask us to do so or when we believe it is required by law.


8.1 For data storage reasons we are unable to store all of your personal information in the United Kingdom. Our servers, storing and keeping your information secure, are located in countries which have an adequate level of protection or with which we have signed agreements incorporating the Model Contract Clauses.


9.1 When you came to our website, you were asked to tick a box confirming you have read this privacy policy and that you agree to us collecting your personal information and using it in the ways and for the reasons explained in this privacy policy. You can view this notice again by clicking here:


10.1 We are able to legally collect and use your personal information either because:

10.1.1 you have provided us with your consent to do so as explained above; and/or

10.1.2 collecting and using your personal information is necessary for us to carry out our legitimate business interests in order to carry out any requests made by you via our Website.


11.1 We will only retain your personal information for as long as it is necessary to carry out our services, keep you up to date with LGBR’s promotions, the status of the relevant funds in which you are interested and where you have asked us to send this information or to provide you with the best customer experience possible. Processing is therefore necessary for the purposes of our legitimate interests (for example, to deal with any claims or queries which you have relating our services), or where we are required to do so by law.


12.1 You have the right to:

12.1.1 be informed about the personal information we collect from you and use, which this privacy policy seeks to do;

12.1.2 obtain confirmation from us that your personal information is being collected and used by us and to access the personal information held about you by us;

12.1.3 have your personal information corrected if it is inaccurate or incomplete at any time;

12.1.4 erasure, or the right to be forgotten, which means you can request deletion or removal of any personal information we hold about you at any time;

12.1.5 block or suppress us collecting and using your personal information, which means we can continue to store your personal information but we cannot further collect or use it in any way;

12.1.6 obtain and reuse any personal information we hold about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from LGBR to another place notified by you to us in a safe and secure way without hindrance to the usability of your personal information; and

12.1.7 object to us collecting or using your personal information where this is based on:(a) a legitimate interest or the performance of a task in the public interest; or(b) direct marketing.

12.2 To make any requests as listed above, please contact us at

12.3 We will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.


13.1 You can tell us to stop collecting and using your personal information at any time by emailing us at

13.2 If you tell us to stop collecting and using your personal information, the consequences of doing so are that:

13.2.1 we will be unable to update you on our promotions and product news;

13.2.2 we will be unable to provide you with the best user experience possible to our Website;

13.2.3 we will generally be unable to provide you with the best customer experience we would like to provide you with; and

13.2.4 we will be unable to keep you updated on the performance and/or development of any funds in which any of your clients have invested.


14.1 Our Website uses “cookie” technology.  We use cookies to distinguish you from other visitors, track your IP address and usage of our site, online advertising and to indemnify the name of the website from which you linked to our website.  This information is used for fulfilling contracts with our business partners, and to help us serve you better by improving our website design, as well as our products, services and promotions.  We do not otherwise track any information about your use of other websites.  Non-personal information or anonymised/pseudonymised information obtained through cookies may be shared with or obtained by service providers on our behalf.

14.2 A cookie is a small data file that is placed on the hard drive of your computer when you visit a website.  A “session cookie” expires immediately when you end your session (i.e., close your browser).  A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available.

14.3 When you visit our website, we may use both a session and a persistent cookie.  This LGBR-placed cookie may contain information (such as a unique user ID) that is used to track your usage of our website and in some cases, your email address.

14.4 You can disable cookies at any time by using your browser options.  You can find out more about cookies by following this link:


15.1 We do not knowingly collect any information from anyone under 16 years of age.  Our website, products and services are all directed to people who are at least 16 years old or older.

15.2 If you are under 16, do not use or provide any information on this website or on or through any of its features/register on the website or provide any information about yourself to us, including your name, address, telephone number or email address.

15.3 If we learn we have collected or received personal information from a child under 16, we will delete that information.

15.4 If you believe we might have any information from or about a child under 16, please contact us at


16.1 Our website may include links to other Internet sites, content, or videos (embedded or direct links) maintained by third parties (“Linked Sites”).  We provide Linked Sites to you solely as a convenience, and the inclusion of Linked Sites does not imply endorsement by us of the Linked Sites.  You access Linked Sites at your own risk and by accessing them you leave our website.  Linked Sites are not under our control and we are not responsible for the contents of any Linked Site, including the privacy policies or tracking technologies they may use.  We encourage you to check the applicable privacy policy to determine how they will handle any personal information they collect from you.


17.1 To update us with your information-sharing preferences, you may contact us using one of the following methods:• call 020 3195 7100;• email; or • send your request to 10 Throgmorton Avenue, London EC2N 2DL.


18.1 We shall implement appropriate technical and organisational measures to ensure a level of security appropriate to potential risks, including:

18.1.1 the pseudonymisation and encryption of your personal information where appropriate;

18.1.2 ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;

18.1.3 ensuring we can restore access to personal information in a timely manner if a physical or technical incident occurs; and

18.1.4 regular testing, assessment and evaluation of the effectiveness of our technical and organisational measures to ensure your personal information is secure.

18.2 We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of personal information transmitted to us using our Website.


19.1 As we continue to develop our business, we may undergo a business transition such as acquiring another company, merging with an existing company, or selling a portion of our assets.  In such transitions, customer information is typically one of the business assets that is transferred or acquired by a third party.  In the unlikely event that LGBR or substantially all of its assets are acquired or enter a court proceeding, you acknowledge that such transfers may occur and that your personal information can continue to be used as set forth in this privacy policy.


20.1 This policy replaces all previous disclosures we may have provided you about our information practices.  We reserve the right to change this policy, and to apply any changes to information previously collected, as permitted by law.  If there are material changes to this policy or our information practices change in the future, we will notify you by posting the policy changes on our website.


21.1 We pride ourselves on excellent customer service, but if you would like to make a complaint about the way we have collected or used your personal information, please contact us at

21.2 If you are unhappy about the way we have handled your complaint and/or you would like to take the matter further or make a complaint directly to our regulator without contacting us first, you can do so by contacting the Information Commissioner’s Office (“ICO”) by following this link: or telephoning the ICO helpline, which is 0303 123 1113.

This website has been created by LGBR Capital London Limited, which provides distribution services to Semper Capital Management. Further information on Semper and their products can be found at