DISCLAIMER

The disclaimer is composed of:
1 – Group description
2 – Disclaimer for Valeur Group, Valeur SA, Valeur Securities SA and Valeur Concept SA
3 – Privacy policy

GROUP DESCRIPTION
“Valeur Group”* comprises five independent companies:
– Valeur Securities SA – Switzerland
– Valeur SA – Switzerland
– Valeur Concept SA – Switzerland
– Valeur Capital Ltd – United Kingdom

* The current “Group” structure has been in operation since 2016. From 2009 to 2015 Valeur had a different company and group structure.

DISCLAIMER VALEUR GROUP, VALEUR SA, VALEUR SECURITIES SA and VALEUR CONCEPT SA
General information
By accessing this website www.valeur-group.com (hereafter “Site”), you explicitly declare that you have read, understood and accepted the following important legal information concerning both the Site and any material and/or information contained therein. In case of non-acceptance of the following legal information, please do not access the Site and its pages.
Limited access and geographical restrictions
This Site has a purely informative purpose for the existing clients of the various companies belonging to the so-called “Valeur Group”. In particular, the information that directly or indirectly refers to the Swiss companies Valeur SA, Valeur Securities SA and Valeur Concept SA, is addressed exclusively to natural and legal persons, as well as to partnerships and collective entities, with domicile or registered office in Switzerland. In this context, the use of the English language is only intended as an aid for our (non-Italian speaking) foreign current and prospective clients domiciled or residing in Switzerland. The Italian language is used because the aforementioned Swiss companies are active in Switzerland – especially in the Canton of Ticino-, where the Italian language is one of the official languages. The use of the Italian language cannot in any way be interpreted as an element of connection with the Republic of Italy or as an indication that the activity of the said companies is aimed at the Italian market.
More generally, please note that this Site, as a whole or in each of its contents, is not addressed to legal or natural persons who, by virtue of their nationality, type of person, domicile or residence, registered office or for any other reason are subject to a legal system that prohibits or limits access thereto, consultation, availability or publication thereof, the presentation of financial services or the marketing of certain financial products.
Restrictions on investment funds and structured products
The Site may contain information that refers directly or indirectly to structured products, as well as to the collective investment schemes that are registered in different jurisdictions and that are only accessible to persons resident in countries that allow the distribution of such types of collective investment schemes: persons who do not meet these requirements cannot access the content of this information. In particular, the aforementioned information is intended exclusively for qualified investors pursuant to Art. 10 Para. 3, 3bis and 3ter of the Swiss Federal Collective Investment Schemes Act (CISA) and for independent asset managers as defined in Art. 3 Para. 2 lit. c CISA with country of residence in Switzerland. The information on the aforementioned products contained in this Site may only be accessible to – and is addressed only to – such category of investors and may not be publicly distributed. Accordingly, persons who do not fully comply with the above conditions may not access the content of such information.
No offer and no recommendation
The content of the Site (information, opinion, as well as data or any document) is for informational purposes only and in no case constitutes an opinion (legal, fiscal or other type of opinion), an invitation, an offer, a recommendation or an inducement to buy or to sell, to apply for or to subscribe to securities, financial instruments, financial or investment products or services, nor a persuasion to effect transactions. Before you make any decision relating to investments, we recommend that you consult with your advisor.
Exclusion of liability
We decline, without limitation, any liability for losses and/or damages of any nature – whether direct, indirect or consequential – possibly arising from the use and/or access to the Site and its contents, or from links that lead to third party websites.
No reliance
Every care has been taken in preparing the content of the Site; however, no guarantee can be given regarding the correctness, accuracy, completeness, reliability or update of the proposed contents. These contents may be changed at any time, and without notice and there is no obligation to remove information that is no longer up to date from the Site or to explicitly identify it as such.
Link to other websites
No verification is carried out on the websites of third-party providers linked to the Site and therefore we decline any responsibility for the relative contents and for any services offered therein.
Sensitive data
The Site does not collect and does not intend to collect sensitive personal data (such as data concerning political opinions, religious beliefs, health or sex life). To the extent that such data should be collected, your consent will be requested in advance. Please note that if you provide sensitive unsolicited personal data, you consent to the same being used.
Copyright
The content of the Site is covered by copyright: it is therefore not permitted to reproduce (partially or in full), transmit (electronically or otherwise), modify or use the Site, or the content of the same, for any public or commercial purpose without our prior written consent.
Applicable law and place of jurisdiction
Any dispute concerning the use of the Site shall be subject to the Swiss law, which shall exclusively govern the interpretation, application, and effect of all the conditions set out above. The courts of Lugano shall have exclusive jurisdiction over all claims or disputes arising out of or in connection with the Site and its use.
Shareholder Rights Directive (applies to Valeur Capital Ltd)
The Firm has developed an engagement policy with respect to obligations under the Shareholder Rights Directive and will in due course publish in full an appropriate disclosure regarding its policy, related processes, and engagement with investee companies (as per FCA rules at COBS 2.2B.5 R).

I confirm that I have read, understood and accepted all the statements presented in this page, in particular the restrictions concerning the domicile and/or the place of business as well as the limitations pertaining  the investment funds and the structured products, and I declare my intent to access to the contents of the Site at my own exclusive initiative, without having been solicited in any way.

PRIVACY POLICY
IMPORTANT: PLEASE READ THIS PRIVACY POLICY AS IT APPLIES TO ANY PERSONAL DATA YOU PROVIDE US OR WE COLLECT ABOUT YOU, FOR EXAMPLE IF YOU ACCESS THE WEBSITE AT www.valeur-group.com OR ANY OTHER WEBSITE OWNED, OPERATED OR PROVIDED BY VALEUR CAPITAL LTD,  AUTHORIZED AND SUPERVISED BY FCA, REFERENCE NUMBER 754244 INCORPORATED IN ENGLAND, COMPANY # 09903526, REGISTERED OFFICE 20 GROSVENOR PLACE, SW1X 7HN, LONDON, UK (‘WEBSITE’ AND ’VALEUR’, ‘US’, ‘WE’ RESPECTIVELY) OR INVEST IN OR ENQUIRE ABOUT ANY OF OUR FUNDS, PRODUCTS OR SERVICES / USE ANY OF OUR PRODUCTS OR SERVICES (‘SERVICES’).
WE DO NOT MARKET TO OR ENTER INTO CONTRACTS WITH CHILDREN NOR WE DO COLLECT PERSONAL DATA FROM ANY PERSON UNDER 18 YEARS OF AGE.  PLEASE DO NOT ACCESS OR USE THE WEBSITE OR SERVICES IF YOU ARE UNDER 18 YEARS OF AGE.
This policy
This policy sets out what personal data we might collect, how we process and protect that data, the lawful grounds for that processing, and your related rights.  Essentially ‘personal data’ means any information relating to an identified or identifiable natural person, namely one who can be identified, directly or indirectly from that information alone or in conjunction with other information. In most cases, the lawful ground will be that the processing: (i) is necessary for our legitimate interests in carrying out our business, including to raise and invest the funds / maintain, improve and market our products and services, provided those interests are not outweighed by your rights and interests (‘Legitimate Interests’), (ii) is necessary to perform a contract with you (‘Contract’), or (iii) is necessary to comply with our legal obligations (‘Legal Obligation’). Where processing is based on your consent (‘Consent’), we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent.
As data protection law and practice are constantly developing, we’ll need to update this policy from time to time, which we’ll do by posting a new policy on the Website that takes effect from the date stated.  It is your responsibility to return to the Website from time to time and check for changes.
How Do We Obtain Personal Data?
We collect or are provided personal data in the normal course of business, for example:
– you may provide us with your details during discussions about investing in our fund or our fund investing in your business/buying our products or services,
– when you visit the Website, we may collect information about your visit such as your IP address and the pages you visited,
– you may provide us with your details when you ask about our funds or other Services (through the Website, by email or otherwise) and we may obtain legally-compliant lists of potential customers for our funds or other Services for our marketing purposes.
When you provide us with personal data about yourself or another person, you are confirming to us that you are authorised to provide us with that information and that any personal data you give us is accurate and up-to-date.
Sensitive Personal Data
Given the nature of our business, we do not ask for ‘sensitive’ or ‘special categories of personal data’, such as information about your health, political opinions, racial origins or sexual life and we would ask you not to send any to us.
How do we use personal data?
We use personal data in the normal course of our business, for example:
– To respond to enquiries about the funds and other Services, to provide the Websites and Services, to provide advice and support. Lawful basis: Legitimate Interests or Contract.
– To analyze and improve the Website, the funds and other Services, for example for technical or security purposes and to improve the customer experience. Lawful basis: Legitimate Interests, however where for example applicable law requires your consent to use certain cookies, we will ask for your Consent having provided you with relevant information.
– To market our fund(s) and other Services – if we do so, we will provide you with an easy and free way to opt-out of receiving such communications in the future. Lawful basis: Legitimate Interests (or Consent as above).
– To investigate opportunities and make investments by the fund(s).
– In certain circumstances, to share it with a limited number of third parties as described in this policy, for example for operational requirements and business continuity purposes. Lawful basis: most processing will be based on Legitimate Interests, some processing is based on Contract and, where necessary (as above) some processing may be based on your prior Consent.
Sharing Data & International Transfers
We will not give, sell or rent your personal data to third parties so they can market their services to you. Nor do we accept advertising from third parties on the Website.  We may share personal data in the following limited circumstances.
– For provision of the Services, and for our own disaster recovery and business continuity purposes, we may store or transmit personal data to or through third party providers, such as with our contractors and advisors to help us operate, secure and analyze our business. Lawful basis: Legitimate Interests or Contract.
– We may be obliged to disclose your personal data to comply with a law, order or request of a court, government authority, other competent legal or regulatory authority or any applicable code of practice or guideline. Lawful basis: Legal Obligation.
– If we enter negotiations with a third party for the sale or purchase of all or part of our business, we will only disclose personal data to that third party to the extent it relates to that business and only under conditions of confidentiality requiring the third party to be bound by the privacy policy that applies to that data. Lawful basis: Legitimate Interests.
In each case, we share the minimum personal data necessary and we have written contracts in place incorporating relevant wording to safeguard that personal data and comply with applicable laws, and we will only share such data as is necessary for the purpose in question.  Where possible, we keep personal data within the European Economic Area (‘EEA’).  However, in order to carry out the above purposes, we may use third parties and their facilities outside the EEA.  In all such cases we will ensure that appropriate security measures are in place to protect your personal data and a valid legal basis for the transfer applies.
Cookies
Our Website uses cookies and/or similar technologies.  Please review our Cookie Policy which is part of (and incorporated into) this Privacy Policy for more information, including on how to refuse or selectively accept cookies and/or similar technologies.
Retention
As a default position, we will only retain personal data for any statutory retention period, then a reasonable period (if any) necessary for the above purposes.  This is subject, for example, to any valid opt-out or withdrawal of consent where processing is based on consent, or other valid exercise of your data subject rights which is effected.
Security
The security of data is very important to our business.  In accordance with our legal obligations, we take appropriate technical and organizational measures to protect your personal data and keep those measures under review.  However, we can only be responsible for systems that we control, and we would note that the internet itself is not inherently a secure environment.
Anonymized data
We may create anonymised data from personal data, and any anonymisation would be carried out in accordance with applicable law as well as relevant guidelines from regulators such as the UK Information Commissioner (‘UK ICO’).  Anonymisation may, for example, be achieved by aggregating data to the point that no individual can be identified such as aggregating website use statistics to see which web content is working well and which could be improved.  Anonymised data does not allow for the identification of any individual person and, as it is no longer personal data, neither data protection laws nor this Privacy Policy would apply to such data.
Third Party Services
If you access the services of another provider through our websites or services, for example through a link on the Website, your use of those services is entirely at your risk and governed by the terms and privacy policy of that third party provider.  If we resell a service delivered or provided by a third party (‘Third Party Service’), including any software that is delivered or owned by a third party (‘Third Party Software’), it is that third party’s separate privacy policy that will apply to your personal data and your use of the Third Party Service and Third Party Software. Your use of a Third Party Service is not covered by this Privacy Policy. Please therefore review the privacy policy for any Third Party Service and Third Party Software before using it.
Your rights
You have the right to know if we process any personal data about you and, if we are, with certain limitations, to a copy of that personal data.  You also have the right to ask us to remove or correct any of that personal data that is inaccurate, to object to certain processing and to withdraw any consent you may have given us for any processing of your personal data.  You also have the right to ask us to restrict processing certain of your personal data, to erase your personal data, and to ‘port’ certain of your personal data to you or another provider, provided in each case that we have such data and certain conditions are met. You have the right, at any time, to object to the processing of your personal data for direct marketing.
Contact Us
If you’ve any question you can always contact us at the address above or by email to privacy@valeur.eu.  You have the right, at all times, to notify a complaint to any regulator such as the UK Information Commissioner, although we would welcome the opportunity to discuss and resolve any complaint with you first.

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