Privacy Policy

1.0 Introduction

These are the terms of use for https://fridman.partners (Site). The Site is operated by Sela (we, us and our). We are an investment firm located at Northcliffe House, Young St, London W8 5EH, United Kingdom.

Your use of the Site will be subject to these terms and by using the Site you agree to be bound by them. The services we offer to clients are provided subject to our General Terms and Conditions.

Information that identifies or can be used to identify a living individual is known as “personal data.” All organizations processing personal data must do so fairly, lawfully and in accordance with applicable data protection laws, including the Data Protection Law. This includes the obligation for us to tell you how we will use your personal data. We treat all of our legal obligations seriously and take all steps necessary to ensure compliance when storing and processing your personal data.

By using or engaging our Site and accepting our services you acknowledge that you have read and understood this privacy policy We reserve the right to change this privacy policy from time to time by changing it on the Site and any substantive changes will be notified to you by e-mail. This privacy policy was last updated on 4th November 2022.

2.0 Personal Data We May Collect from You

We may collect and process the following personal data about you received directly from you or from your interactions with us for compliance with a legal obligation:

Contact details (such as your name, email address, postal address and telephone number) that you provide by completing forms on the Site, including if you register as a user of the Site, subscribe to any service, upload or submit any material via the Site, request any information;

Your date of birth, country of residence, employment status and source of investment funds.

Your financial circumstances (e.g. assets, liabilities, income and expenditure);

in connection with an account sign-in facility, your log-in and password details; details of any transactions made by you through the Site;

information from surveys that we may, from time to time, run on the Site for research purposes, if you choose to respond to or participate in them; technical information that may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and/or information about your visit to the Site, which may include the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.

A list of the personal data we collect from you when opening an account with us is set out at Appendix 1 to this privacy policy.

We collect your personal data from you in a number of different ways, including the following:

if you provide it when interacting and communicating with us (for example when registering for our services);

if you enter into an agreement for the provision of our services;

if you enter a competition or promotion;

if you make payments or modify your account details; and

when you visit our Site (for example by cookies, your IP address and other browser-generated information).

We record all service calls for quality and training purposes, to enable us to deal effectively with queries and complaints and, in the case of calls where clients place transactions or investment advice is communicated, in order to comply with our regulatory obligations.

You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services. This is because if you have chosen to open an account with us or commissioned investment advice, it is a statutory requirement for us to obtain, and a contractual requirement for you to provide, certain information so that we can verify your identity in order to meet our obligations under the Money Laundering Regulations 2007 and other applicable legislation for the purposes of crime prevention. You are obliged to provide this information in order for us to provide the service and, if you fail to provide it, we will be unable to provide the service in compliance with our legal obligations.

We do not collect, nor do we process “special categories of personal data”. Special category data is personal data which is more sensitive and would include: race; ethnic origin; politics; religion’ trade union membership; genetics; biometrics; health; sex life or sexual orientation for example.

3.0 Cookies and Other Technologies

When you interact with the Site, we try to make that experience simple and meaningful. Our cookies distinguish you from other users of our Site. This helps us provide you with a good experience when you browse our Site and allows us to improve our Site.

4.0 How Do We Use Your Personal Data?

We use your personal data as is necessary and required to do so by law, or on a contractual basis and in our legitimate interest (where such interests are not overridden by your interests or fundamental rights and freedoms) to the extent it is necessary for the proper operation of the Site, our services, our systems, to protect us/our clients, or for the enforcement of our Terms and Conditions.

We may also use your personal data collected from you for the following purposes:

processing applications made by you, managing your accounts, providing our services, contacting you and servicing our relationship with you;

administration and accounting, billing and auditing and other legal purposes;

to carry out checks on you, such as identification verification checks and anti-money laundering checks, for the purposes of meeting our obligations under the Money Laundering Regulations 2007 and any other applicable legislation, for the purposes of crime prevention;

security and payment verification;

dealing with any queries, complaints or problems reported by you;

audit the downloading of data from the Site;

enabling you to participate in our promotions and competitions;

enabling you to participate in the interactive features of the Site and ensuring content from our Site is presented in the most effective manner for you and your computer or device;

notifying you about changes to our service and/or the terms on which the services are provided;

generating statistics on our users, such as the popularity of certain of our services and about the “traffic” visiting our websites. Before doing this your personal data is anonymized and you are not personally identifiable; and

We may also use your personal data to provide you with information about our goods or services we feel may interest you only if you have given your consent to receiving marketing material from us at the point, we collected your information.

In order to monitor and analyze our business we, or a third party acting for us, may use information in your client and account records to assess client satisfaction and for market research. If you do not wish to be contacted to participate in client satisfaction or marketing surveys, you can opt out by asking us and our third parties to stop contacting you by writing to us or by opting out by SMS or email as specified in the relevant communication. This request will not affect the running of your existing account or the services you request from us, in respect of which we will still process your personal data.

Unless stated otherwise in this privacy policy, the legal basis for our use of your personal data will be that this information is processed for one or more of the legitimate interests described above and/or as is necessary for compliance with any legal obligation.

5.0 Our Promotional Updates and Communications

Where permitted in our legitimate interest where required by law (as applicable), we will use your personal information for marketing analysis.

With your prior consent we may also provide you with promotional update communications by email, secure message, phone or SMS about our products/services.

If you are an existing client, we will only contact you by e-mail, secure message via the website or SMS with information about goods and services similar to those which were the subject of a previous agreement with you and if you have not opted out of receiving such communications.

If you are a new client, we will contact you by email, secure message via the website and SMS only if you have consented to this.

If you do not want us to use your data in this way, you can record your preference when you initially provide us with your details, contact us in writing at any time to object to marketing or opt out to receiving marketing by SMS or email as specified in the relevant marketing communication at any time. Opting out from such communications will not prevent us from communicating with you as necessary to manage your account.

6.0 Who Is Your Personal Data Shared With?

You acknowledge that we may disclose your personal data to:

entities within our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent;

third parties which we use to carry out the checks that we need to carry out on you, such as identification verification and anti-money laundering;

the custodian for the purpose of managing your accounts and providing our services;

the SIPP provider for the purpose of managing your accounts and providing our services;

other selected third-party service providers that may be located in or outside the European Economic Area (EEA). These may include:

Organizations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes in supporting the services we offer through the site in particular those providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. These organizations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.

We may disclose your personal information to any of our affiliates, or to our agents or contractors who assist us in providing the services we offer through the Site, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analyzing data, providing IT and other support services or in other tasks, from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.

Analytics and search engine providers that assist us in the improvement and optimization of our site and subject to the cookie section of this policy (this will not identify you as an individual).

Payment processing providers who provide secure payment processing services. Note your payment card details are not shared with us by the provider.

Third parties to whom your personal data is disclosed to may only use it for the purposes set out in this privacy policy.

If we transfer your data to a service provider outside of the EEA, we ensure that appropriate controls are in place to protect your data in accordance with applicable data protection laws, such as:

the European Commission has made an official adequacy decision that the recipient country is a ‘safe’ country for the receipt of personal data; or

we have entered into a form of contract with the service provider which has been approved by the European Commission as providing adequate protection for personal data, or if the service provider is in the US, it has self-certified to the EU/US Privacy Shield Framework.

For a copy of the details of the transfers of, or access to, personal data outside of the EEA and the safeguards that we have in place when transferring, or allowing access to, your personal data outside of the European Economic Area, (and for a copy of the safeguards, where applicable) please contact us via email at dataprivacy@fridman.partners

We may disclose aggregate statistics about visitors to the Site and clients in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information. In the event that we undergo re-organization or are sold to a third party, you agree that any personal data we hold about you may be disclosed under appropriate confidentiality terms to our advisers and any prospective purchasers’ advisers, and will be transferred to that re-organized entity or the new owners.

We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site or the rights, property or personal safety of any person.

7.0 Automated Decisions

As part of our account-opening process we will carry out automated checks using your personal data, such as your name, postal address, date of birth, telephone numbers and employment status. These checks include identification verification checks and financial crime checks and involve our obtaining information from identity verification agencies and any records held by financial crime prevention agencies, the Electoral Register and providers of utility services.

We need to carry out these checks in order to meet our legal obligations under the Money Laundering Regulations 2007 and any other applicable legislation.

We will also carry out suitability checks regarding your choice of investment account. Parameters will include your financial circumstances and investment time horizon. These checks may indicate that an account is unsuitable for you. If our automated processes indicate that a portfolio may be unsuitable then you will be contacted by a member of the Client Service or Advisory team to discuss your your choices and allow you to provide further information which may result in the decision changing.

8.0 External links

The Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

9.0 Security and Safeguarding Your Personal Data

We place great importance on the security of all personal information associated with our users and clients. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk. You can also help to protect your personal data, by following the guidelines below:

choose a password that you will be able to remember but that would be hard for someone to guess. It is required to contain both upper- and lower-case letters, a number and a symbol. We recommend that you change it regularly and if you need to write it down, always keep it in a safe place;

make sure that no-one can see the details you are entering when you log-in;

if other people have access to your computer, remember to close your browser each time you log-off and end your session and, if possible, clear any history of the websites you have visited and that your browser may have saved or “cached”; and

never disclose your account details to anyone.

10.0 Data Retention and Storage of your Personal Data

We will only keep your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this privacy policy and for as long as we are required to keep it by law. We retain copies of our client contracts in order to enable us to deal with any legal issues along with the information provided to us for identification verification checks and anti-money laundering checks (as required by law) for 6 years after termination or expiry of our contract with you. Site usage data will be retained for a period of 3 years in order that we can monitor the performance of the Site.

Your personal information which we collect is sent to and stored on secure servers currently located in the Republic of Ireland and/or the Netherlands. Such storage is necessary in order to process the information. Personal information submitted may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above (see Information Sharing), which may be situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. The countries concerned may not have similar data protection laws to the EEA. Where we transfer your personal information, we will take all reasonable steps to ensure that your privacy rights continue to be protected. By using the Site, you agree to this storing, processing and/or transfer.

11.0 Your rights

You have the following rights (unless exemptions apply), which can be exercised by contacting our Data Protection Officer at dataprivacy@fridman.partners at any time.

The right:

to ask us not to process your personal data for marketing purposes;

to access personal information held about you and to obtain a copy of it;

to prevent any processing of a record of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;

to obtain the rectification or completion of records of personal data which are inaccurate or incomplete;

to restrict or object to the processing of your personal data and to request its erasure. We will not be able to erase personal data where we have a legal obligation to retain such data for example the results of identity verification checks;

in certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine-readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible; and

to lodge a complaint about the way in which your personal data is being shared with a supervisory authority.

Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time by contacting us at dataprivacy@fridman.partners

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority. The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

12.0 Contacting Us

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to dataprivacy@fridman.partners, between the hours of 9am to 5pm, Monday to Friday.

Appendix 1

• Address
• Phone number
• Email address
• Date of Birth
• Country of residence
• Employment status

All of the above are legally required.

This list is correct as of 4th November 2022 and may be subject to change.

Appendix 2

The following is a list of processors of personal information which we have engaged to provide services to clients:

Custodian – SEI International (Europe) Limited

Identity checks and Anti Money Laundering – Experian and Equifax

The above list is correct as of 4th November 2022 and may be subject to change.

Website terms of use

1.0 Introduction

These are the terms of use for https://fridman.partners (Site). The Site is operated by Sela (we, us and our). We are an investment firm, located at Northcliffe House, Young St, London W8 5EH, United Kingdom.

Your use of the Site will be subject to these terms and by using the Site you agree to be bound by them. The services we offer to clients are provided subject to our General Terms and Conditions.

We reserve the right to change these terms of use from time to time by changing them on the Site. These terms of use were last updated on 30th December 2021.

2.0 Access to the Site

The Site is intended for use only by persons who are at least 18 years of age. By using the Site, you confirm that you meet that requirement. It is your responsibility to ensure your equipment (computer, laptop, netbook, tablet or other mobile device) meets all the necessary technical specifications to enable you to access and use the Site and is compatible with the Site.

We may, from time to time, restrict access to certain features, parts or content of the Site, or the entire Site, to users who have registered with us. You must ensure that any registration details you provide are accurate. If you choose, or you are provided with, a log-on ID (such as a username and password or other identifier) as part of our security procedures, you must treat such information as confidential and must not reveal it to anyone else. You are responsible for all activities that occur under your log-on ID and must notify us immediately of any unauthorized use or other security breach of which you become aware. We reserve the right to disable any log-on ID, at any time, if in our opinion you have failed to comply with any of the provisions of these terms of use or if any details you provide for the purposes of registering as a user prove to be false.

We cannot guarantee the continuous, uninterrupted or error-free operability of the Site. There may be times when certain features, parts or content of the Site, or the entire Site, become unavailable (whether on a scheduled or unscheduled basis) or are modified, suspended or withdrawn by us, in our sole discretion, without notice to you. You agree that we will not be liable to you or to any third party for any unavailability, modification, suspension or withdrawal of the Site, or any features, parts or content of the Site.

3.0 What you are allowed to do

You may only use the Site for non-commercial use and only in accordance with these terms of use. You may retrieve and display content from the Site on a computer screen, print and copy individual pages and, subject to the next section, store such pages in electronic form. Additional terms may also apply to certain features, parts or content of the Site and, where they apply, will be displayed on-screen or accessible via a link.

4.0 What you are not allowed to do

Except to the extent expressly set out in these terms of use, you are not allowed to:

'scrape' content or store content of the Site on a server or other storage device connected to a network or create an electronic database by systematically downloading and storing all of the content of the Site;

remove or change any content of the Site or attempt to circumvent security or interfere with the proper working of the Site or the servers on which it is hosted; or

create links to the Site from any other website, without our prior written consent, although you may link from a website that is operated by you provided the link is not misleading or deceptive and fairly indicates its destination, you do not imply that we endorse you, your website, or any products or services you offer, you link to (and do not frame or replicate) the home page of the Site, and the linked website does not contain any content that is unlawful, threatening, abusive, defamatory, pornographic, obscene, vulgar, indecent, offensive or which infringes on the intellectual property rights or other rights of any third party.

You must only use the Site and anything available from the Site for lawful purposes (complying with all applicable laws and regulations), in a responsible manner, and not in a way that might damage our name or reputation or that of any of our affiliates.

5.0 Intellectual property rights

All intellectual property rights in any content of the Site (including text, graphics, software, photographs and other images, videos, sound, trademarks and logos) are owned by us or our licensors. Except as expressly set out here, nothing in these terms of use gives you any rights in respect of any intellectual property owned by us or our licensors and you acknowledge that you do not acquire any ownership rights by downloading content from the Site. In the event you print off, copy or store pages from the Site (only as permitted by these terms of use), you must ensure that any copyright, trade mark or other intellectual property right notices contained in the original content are reproduced.

6.0 Content

We may change the format and content of the Site from time to time. You agree that your use of the Site is on an 'as is' and 'as available' basis.

Whilst we try to make sure that all information contained on the Site (other than any user-generated content) is correct, it is not intended to amount to authority or advice on which reliance should be placed. You should check with us or the relevant information source before acting on any such information

Except to the extent that our General Terms and Conditions apply, we make or give no representation or warranty as to the accuracy, completeness, currency, correctness, reliability, integrity, quality, fitness for purpose or originality of any content of the Site and, to the fullest extent permitted by law, all implied warranties, conditions or other terms of any kind are hereby excluded and we accept no liability for any loss or damage of any kind incurred as a result of you or anyone else using the Site or relying on any of its content.

We cannot and do not guarantee that any content of the Site will be free from viruses and/or other code that may have contaminating or destructive elements. It is your responsibility to implement appropriate IT security safeguards (including anti-virus and other security checks) to satisfy your particular requirements as to the safety and reliability of content.

7.0 Your personal information

Use of your personal information submitted to or via the Site is governed by our Privacy and Cookies Policy.

8.0 External links

PlThe Site may, from time to time, include links to external sites. We include these to provide you with access to information, products or services that you may find useful or interesting. We are not responsible for the content of these sites or for anything provided by them and do not guarantee that they will be continuously available. The fact that we include links to such external sites does not imply any endorsement of our association with their operators or promoters.

9.0 General

Nothing in these terms of use shall limit or exclude our liability to you:

for fraudulent misrepresentation;

for breach of any term implied by the Consumer Rights Act 2015 and which, by law, may not be limited or excluded; or

for any other liability that, by law, may not be limited or excluded.

Subject to this, if you are a consumer and not a business user, in no event shall we be liable to you for any business losses, and if you are a business user, in no event shall we be liable to you for any indirect or consequential losses, or for any loss of profit, revenue, contracts, data, goodwill or other similar losses, and any liability we do have for losses you suffer is strictly limited to losses that were reasonably foreseeable. These terms of use shall be governed by English law, and you agree that any dispute between you and us regarding them or the Site will only be dealt with by the English courts, provided that, if you are a consumer and not a business user and live in a part of the United Kingdom other than England, the applicable law of that part of the United Kingdom will govern and any dispute will only be dealt with by the courts there. Nothing shall prevent us from bringing proceedings to protect our intellectual property rights before any competent court.

10.0 Contacting us

Please submit any questions you have about these terms of use or any problems concerning the Site by email to info@fridman.partners between the hours of 9am to 5pm, Monday to Friday.

Website cookies policy

1.0 Introduction

This is the cookies policy for www.fridman.partners (Site). The Site is operated by Sela (we, us and our). An investment firm located at Northcliffe House, Young St, London W8 5EH, United Kingdom. For the purposes of the Data Protection Act 1998, we are the data controller.

By using the Site, you consent to the collection and use of information in accordance with this privacy policy.

We reserve the right to change this cookies policy from time to time by changing it on the Site. This cookies policy was last updated on 4th November 2022.

2.0 Information We May Collect from You

When you visit the Site, we may, by means of cookies and/or other similar technologies, automatically collect additional information about you – such as the type of internet browser or mobile device you use, any website from which you have come to the Site, your IP address (the unique address which identifies your computer or mobile device on the internet) and/or the operating system of your computer or mobile device. See Cookies and Other Technologies for more information.

3.0 Cookies and Other Technologies

When you interact with the Site, we try to make that experience simple and meaningful. When you visit the Site, a web server sends a cookie or other similar technology to your computer or mobile device (as the case may be). Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website and which store and sometimes track information.

Several cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last for longer.

The cookies and/or other similar technologies we use collect information, such as the type of internet browser or mobile device you use, any website from which you have come to the Site, your IP address and/or the operating system of your computer or mobile device.

We use cookies and/or other similar technologies, either alone or in combination with each other to:

help secure your communication with the Site

help us diagnose problems that might occur during your use of the Site

remember who you are when are logged in to your account;

remember that you have visited us before. This means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get;

customize elements of the layout and/or content of the pages of the Site; and

collect anonymous statistical information about how you use the Site (including how long you spend on the Site) and where you have come to the Site from, so that we can improve the Site and learn which parts of the Site are most popular with users.

Some of the cookies used by the Site are set by us, and some are set by third parties who are delivering services on our behalf.

Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting https://www.aboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. Please note, however, that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site.

4.0 Contacting Us

Please submit any questions, concerns or comments you have about this cookie policy by email to dataprivacy@fridman.partners, between the hours of 9am to 5pm, Monday to Friday.