For the purposes of the Data Protection Act 1998 (the Act), the data controller is Iron Box Capital Ltd of 8 City Road, London EC1Y 2AA.
1 WHAT TYPE OF INFORMATION DO WE COLLECT FROM YOU?
1.1 We may collect and process the following information from you:
1.1.1 information that you provide by filling in forms on our website www.ironboxcapital.com (our Website);
1.1.2 if you contact us, we may keep a record of that correspondence; and
1.1.3 details of your visits to our Website and the resources that you access.
2 HOW DO WE USE YOUR PERSONAL DATA?
2.1 We use information held about you in the following ways:
2.1.1 to carry out our obligations arising from any contracts entered into between you and us;
2.1.2 to provide you with information, products or services that you request from us or which we feel may interest you, where you have
consented to be contacted for such purposes;
2.1.3 to ensure that content from our Website is presented in the most effective manner for you and for your computer; and
2.1.4 to notify you about changes to our service.
2.2 We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and
services which may be of interest to you and we or they may contact you about these.
2.3 If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the
relevant box situated on the form on which we collect your data.
3 DISCLOSURE OF INFORMATION
3.1 We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding
company and its subsidiaries, as defined in section 1159 of the United Kingdom Companies Act 2006.
3.2 We may disclose your personal information to:
3.2.1 our affiliates or professional advisers;
3.2.2 persons or organisations who work on our behalf to provide a product or a service to you;
3.2.3 companies which perform marketing services on our behalf or with whom we have joint marketing agreements;
3.2.4 other companies who we believe may have products and services of interest to you.
3.3 We may also disclose your personal information to third parties if:
3.3.1 we sell or buy any business assets, in which case we may disclose your personal data to the prospective seller or buyer of such
business or assets;
3.3.2 Iron Box Capital Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by us about our
customers will be one of the transferred assets;
3.3.3 we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or
or others, including exchanging information with other companies and organisations for the purposes of fraud protection and credit
risk reduction. Iron Box Capital Ltd’s LLP Data Protection No is ZA095807 or you can contact the ICO on www.ico.org.uk .How we
protect your data
3.4 The data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA).
It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged
in, among other things, the fulfilment of contracts, the processing of details or the provision of support services. By submitting
your personal data you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your
3.5 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your
personal data, we cannot guarantee the security of your data transmitted to our Website. Any transmission is at your own risk. Once
we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
3.6 We take all reasonable care to ensure the security of the website and of your personal information from access by unauthorised
persons and against unlawful processing, accidental loss, destruction and damage. We will not share your information other than as
4 IP ADDRESSES AND COOKIES
4.1 We may collect information about your computer, including where available your IP address, operating system and browser type,
for system administration purposes.
4.2 Cookies contain information that is transferred to your computer’s hard drive. Cookies allow a web application to tailor its operations
to your needs, likes and dislikes by gathering and remembering information about your preferences.
4.3 This statistical data does not identify an individual. We only use this information:
4.3.1 to gather information on IP addresses and pages visited;
4.3.2 to analyse trends;
4.3.3 to administer the website;
4.3.4 to track users’ movements on the website; and
4.3.5 for purposes of statistical analysis.
4.4 You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your
browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Website. Unless you have
5 LINKS TO OTHER WEBSITES
data on any other website.
5.2 Our Website may from time to time contain links to and from other websites. If you follow a link to any of these websites please note
that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You
should always check these policies before you submit any personal data to these websites.
always available by applying in writing to Iron Box Capital Ltd, 8 City Road, London EC1Y 2AA; or by emailing
firstname.lastname@example.org . It may be necessary to contact you and obtain your consent regarding any significant changes to our
7 YOUR RIGHT TO ACCESS YOUR INFORMATION
7.1 The Act gives you the right to obtain a copy of the personal data we hold about you. The fee for obtaining a copy of your information
is £10 which will go towards meeting our costs in providing you with details of the information we hold about you. We can provide
you with that information further to a request in writing to Iron Box Capital Ltd, 8 City Road, London EC1Y 2AA providing us
with sufficient information to identify you (we may need to request proof of identity in some instances). You have the right to request
an amendment to any information that we hold and which you believe to be incorrect.
8.2 From time to time, Iron Box Capital Ltd or third parties who we think have products or services of interest to you may send you
emails, email newsletters or news updates alerting you to new features, products, promotions, or services pertaining to our Website.
If you no longer wish to receive materials from us and/or from such third parties, you may opt-out of receiving these communications
by writing to us at Iron Box Capital Ltd, 8 City Road, London EC1Y 2AA or by emailing us your request to unsubscribe to
Website Terms and Conditions
1 INFORMATION ABOUT US
1.1 We are a Limited Company registered in England and Wales at Companies House under the name Iron Box Capital Ltd (we, us, our,
and Iron Box Capital Ltd). Our registered office is at 8 City Road, London EC1Y 2AA and our company number is 09321984.
1.2 We are an Appointed Representative of Sturgeon Ventures LLP FRN # 452811 who is authorised and regulated by the Financial
Conduct Authority (the FCA) and entered on the FSA Register with the firm identification number FRN 670397.
1.3 If you have any queries about the Website or any information contained on it, please contact us at 8 City Road, London EC1Y 2AA
or by telephone on +44 207 628 7857; or by email at email@example.com.
2 ACCESSING OUR WEBSITE
2.1 Access to our Website is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on
our Website without notice. From time to time, we may restrict access to some or all of our Website. We will not be liable if for any
reason our Website is unavailable at any time or for any period.
downloaded or printed extracts from the Website.
2.3 You are responsible for making all arrangements necessary for you to have access to our Website.
ensuring that all persons who access our Website through your internet connection and on your computer are aware of these Terms
of Use and that they comply with them. You are also responsible for the use of our Website by any person using your computer.
3.1 Nothing on this Website is intended, nor should it be taken, to create any legal or contractual relationship. Any transmission,
downloading or sending of any information from the Website does not create any contractual relationship.
3.2 The content of the Website is designed for information purposes only. Neither the information nor any opinions stated in the Website
constitutes a solicitation or offer by Iron Box Capital Ltd to buy or sell any securities or other financial instruments or to provide any
3.3 The provision of investment services may be restricted in certain jurisdictions. It is your responsibility to acquaint yourself with any
local laws and restrictions on the usage of this Website and the availability of any services described on it. The information on this
Website is not intended for distribution to or use by any personal entity in any jurisdiction or country where such distribution would
be contrary to local law or regulation. The Services are available only to persons in the United Kingdom and other European
Economic Area countries. The Services are not available to United States persons directly, unless introduced to Iron Box Capital Ltd
by a FINRA registered broker or their United States attorney.
3.4 Nothing in this Website may be published in the press or elsewhere without permission of Iron Box Capital Ltd.
3.5 Iron Box Capital Ltd does not provide legal or tax advice. Clients of Iron Box Capital Ltd and viewers of this Website are encouraged
to consult their own legal and tax advisers before making any investment decision. Private companies in all jurisdictions and
potential investors should take independent legal and taxation and investment advice before proceeding with any type of fund
3.6 While we endeavour at all times to ensure information on our Website is clear, fair and not misleading at the date of publication, we
do not hold the information as impartial and it should not be viewed as wholly objective. Information on this Website is based on
sources that we believe to be reliable but we give no undertaking that it is accurate or complete and Iron Box Capital Ltd cannot and
does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any
particular purpose or at all.
3.7 Any opinions are subject to change without notice and Iron Box Capital Ltd is under no obligation to report or keep information
3.8 This Website is controlled and operated by Iron Box Capital Ltd in the United Kingdom. We make no representations that materials
in the Website are appropriate or available for use in other locations. Those who choose to access the Website from other locations
do so at their own risk and are responsible for compliance with all applicable laws.
4 INTELLECTUAL PROPERTY RIGHTS
4.1 This Website, its contents, any materials downloaded, and all intellectual property pertaining to or contained on the Website
(including but not limited to copyrights, patents, database rights, graphics, designs, text, logos, trade dress, trademarks and service
marks) are owned by or licensed to us and/or from third parties and all rights, title and interest in them shall remain the property of
Iron Box Capital Ltd and/or such third parties (collectively, the Content).
4.2 The Content is protected by copyright, patent and trademark laws, and various other intellectual property rights and unfair
4.3 You are permitted to print copies and download extracts of the content on the Website for your own personal use for information
purposes only, and may draw the attention of others within your organisation to material posted on the Website, subject to the
4.3.1 our status (and that of any identified contributors) as the authors of material on our Website must always be acknowledged;
4.3.2 you must not modify in any way the paper or digital copies of any materials you have printed off or downloaded, and you must not
use any illustrations, photographs, video or audio sequences or graphics separately from any accompanying text;
4.3.3 you must not duplicate, copy, publish, modify, create derivative works from, participate in the transfer of, post on the internet, or in
any way distribute, redistribute or exploit the Website, or any portion of the Website, for any public or commercial use without our
express prior written consent;
immediately and you must, at our option, return to us or destroy any copies of the materials you have made.
5 UNLAWFUL OR PROHIBITED USE
5.1 We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses, trojans, worms, logic bombs or
other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary
material due to your use of our Website or to your downloading of any material posted on it, or on any website linked to it.
5.2 You must not misuse our Website by knowingly or recklessly introducing viruses, trojans, worms, logic bombs or any other material
which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our Website, the server on which
our Website is stored or any server, computer or database connected to our Website. You must not attack our Website via a denial-
of-service attack or a distributed denial-of service attack.
5.3 Any such unauthorised use of our Website may give rise to a claim for damages and/or be a criminal offence under the Computer
Misuse Act 1990. We will report any such activity to the relevant law enforcement authorities and we will co-operate with those
authorities by disclosing your identity to them. In the event of such a breach, your right to use our Website will cease immediately
and without further notice.
6.2 Additionally, by using our Website, you acknowledge and agree that internet transmissions are never completely private or secure.
You understand that any message or information you send to our Website may be read or intercepted by others, notwithstanding our
efforts to protect such transmissions. We are not responsible for any messages which are lost, altered by third parties or intercepted
and we will not be liable to you or anyone else for any damages or otherwise in connection with any message sent by you to us or
by us to you via the internet.
which person is using the computer. The cookies we use record which parts of our Site are being visited and for how long.
6.4 The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 requires that cookies can only be
placed on a computer where the user has given their express consent. You can choose to accept or decline cookies when you first
access our Site. We require you to indicate your choice via an automated “pop-up” box, which explains the cookies we use and
what we use them for. Most web browsers automatically accept cookies, but you can also usually modify your browser setting to
7 EXCLUSION OF LIABILITY
7.1 The material displayed on our Website is provided without any guarantees, conditions or warranties as to its accuracy, originality or
completeness. To the extent permitted by law, we and third parties connected to us hereby expressly exclude:
7.1.1 all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity;
7.1.2 any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our Website or in
connection with the use, inability to use, or results of the use of our Website, any websites linked to it and any materials posted on it,
(a) loss of income or revenue;
(b) loss of business;
(c) loss of profits or contracts;
(d) loss of anticipated savings;
(e) loss of data;
(f) loss of goodwill;
(g) wasted management or office time; and
(h) any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or
otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or
any other claims for direct financial loss that are not excluded by any of the categories set out above.
7.1.3 In jurisdictions which do not allow the exclusion or limitations of certain types of liability, Iron Box Capital Ltd’s liability will be limited
to the maximum extent permitted by law.
liability which cannot be excluded or limited under applicable law.
8.1 By using our Website, you agree to indemnify and hold harmless Iron Box Capital Ltd from and against any and all losses, claims,
damages, costs and expenses (including reasonable legal and accounting fees) that Iron Box Capital Ltd may become obliged to
reserves the right to assume or participate, at your expense, in the investigation, settlement and defence of any such action or claim.
9 LINKS TO THIRD PARTY WEBSITES
9.1 Our Website may contain links to websites and resources maintained by third parties. These links are provided for your information
only. We have no control over the contents of those websites and resources, and accept no responsibility for them or for any loss or
damage that may arise from your use of them. We are not responsible for the content, availability or privacy policies of those sites,
and the existence of such links should not be considered an endorsement or recommendation of those sites or of any product or
service offered on those sites or of any party that is associated with those sites.
9.2 Please note that other websites and resources linked to on our Website may be governed by separate terms and conditions,
including privacy policies. You should refer to the applicable terms and conditions of those websites and resources before using
them and you should direct any questions or comments about the linked website or resource to the appropriate website provider.
10 LINKING TO OUR WEBSITE
10.1 You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take
advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on
our part where none exists.
10.2 You must not establish a link from any website that is not owned by you.
10.3 Our Website must not be framed on any other website, nor may you create a link to any part of our Website other than the home
page. We reserve the right to withdraw linking permission without notice.
10.4 If you wish to make any use of material on our Website other than that set out above, please address your request to
11 REVISION OF TERMS
be superseded by provisions or notices published elsewhere on our Website.
12 JURISDICTION AND APPLICABLE LAW
12.1 The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to our Website. We retain the
right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country.
non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.
rights or terms.
Capital Ltd with regard to your use of our Website, and any and all other written or oral agreements or understandings previously
existing between you and Iron Box Capital Ltd with respect to such use are superseded and cancelled.
14 YOUR CONCERNS
14.1 If you have any concerns about any material which appears on our Website, please contact firstname.lastname@example.org .
Anti-Bribery and Corruption Policy
Iron Box Capital Ltd values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:
• Setting out a clear anti-bribery policy;
• Training all consultants and clients, so that they can recognise and avoid the use of bribery by themselves and others;
• Encouraging its consultants and clients to be vigilant and to report any suspicion of bribery, providing them with suitable channels of
communication and ensuring sensitive information is treated appropriately;
• Notifying all third parties that the Directorship engage with of its policy and zero tolerance of bribery and/or corruption.
• Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant
• Taking firm and vigorous action against any individual(s) involved in bribery.
Iron Box Capital Ltd prohibits the Board of Directors:
the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement
to or from
any person or company, wherever they are situated and whether they are a public official or body or private person or company
any individual consultant, agent or other person or body acting on the Board of Directors behalf
in order to
gain any commercial, contractual or regulatory advantage for the Board of Directors in a way which is unethical
or in order to
gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual
The Board of Directors recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Directors or of the person or body employing or contracting with them or whom they represent.
This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded
• normal and appropriate hospitality
• the giving of a gift for a corporate reason or at another special time, as long as reported in the proper manner within the firm on the
Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the local senior manager with responsibility for this policy before proceeding. If necessary, guidance should also be sought from the Compliance Officer
Consultants and Principles Responsibility within Iron Box Capital Ltd
The prevention, detection and reporting of bribery is the responsibility of all consultants throughout the Board of Directors. Suitable channels of communication by which consultants or others can report confidentially any suspicion of bribery will be maintained via the Anti-Corruption Reporting procedures.
Useful resource: www.transparency.org.uk for the Transparency Index
A fuller Policy and Procedures outlining all the Principals of the Act can be requested
from the Compliance Officer by emailing email@example.com