DATA PROTECTION
Privacy & Cookie Policy
Last updated: October 2027
1. WHO WE ARE
Fodero Sigma Fund Ltd. (the “Fund”, “we”, “us”), a company incorporated in the British Virgin Islands (company no. 2221395), registered office Mandar House, Johnson's Ghut, P.O. Box 2196, Road Town, Tortola VG1110, British Virgin Islands, is the data controller for personal data processed through this website and in connection with investments in the Fund. Questions about this policy may be sent to info@foderocapital.com.
2. WHICH LAWS APPLY
We process personal data in accordance with the BVI Data Protection Act, 2021. Where we process personal data of individuals in the European Economic Area or the United Kingdom, we also apply the EU and UK General Data Protection Regulation (GDPR) to the extent they apply.
3. WHAT WE COLLECT
- Enquiries: your name, email address and any information you provide when you contact us.
- Investors and prospective investors: identification and contact details, nationality, date of birth, tax residence, source of funds and wealth, bank details, investment details and other information required for subscription, anti-money laundering and know-your-client checks.
- Investor portal: login credentials and records of your use of the portal.
- Technical data: IP address, browser type and access times, recorded in server logs for security purposes.
4. WHY WE USE IT
- To respond to enquiries.
- To assess and process subscriptions and redemptions and to administer your investment.
- To comply with legal and regulatory obligations, including anti-money laundering, sanctions and tax reporting requirements (including FATCA and CRS).
- To keep this website and the investor portal secure.
We process personal data because it is necessary to perform our agreement with you or take steps at your request, to comply with legal obligations, or for our legitimate interests in operating the Fund securely. We do not use personal data for marketing profiling and we do not sell it.
5. WHO WE SHARE IT WITH
Only where necessary, with the Fund’s service providers and advisers, including its administrator, registered agent, auditor, legal advisers, banks, custodian and brokers, and IT and hosting providers, all of whom are bound by confidentiality obligations. We may also disclose data to regulators, tax authorities and law enforcement where required by law.
6. INTERNATIONAL TRANSFERS
Our service providers may process personal data outside the British Virgin Islands and outside the EEA. Where required, we use appropriate safeguards for such transfers, such as standard contractual clauses.
7. HOW LONG WE KEEP IT
Enquiry data is kept for as long as needed to handle the enquiry. Investor data is kept for the duration of the investment and thereafter for as long as required by law; anti-money laundering records are kept for at least five years after the relationship ends.
8. SECURITY
We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss or misuse.
9. YOUR RIGHTS
Subject to applicable law, you may request access to, correction or deletion of your personal data, object to or restrict its processing, and, where processing is based on consent, withdraw that consent. Some rights may be limited where we are legally required to keep data. To exercise your rights, contact info@foderocapital.com. You may also complain to the Office of the Information Commissioner in the British Virgin Islands or, where GDPR applies, to the data protection authority in your country of residence.
10. COOKIES
This website does not use cookies for analytics, advertising or tracking. The investor portal uses only strictly necessary cookies, such as session cookies that keep you logged in securely; these do not require consent and are deleted when you log out or close your browser. If we introduce other cookies in the future, we will update this policy and ask for your consent where required.
11. CHANGES
We may update this policy from time to time. The current version is always available on this website.
