Privacy Policy

This policy explains the manner in which Yaro Capital Ltd. collects, utilises and maintains non-public personal information relating to investors based in the EU or the European Economic Area (“EEA”) or UK, as required under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and Data Protection Act 2018. 

Use, and Reasons for Use, of Personal Data

Yaro Capital Ltd. collects personal information relating to investors in the fund including but not limited to investors’ names, contact details, financial and other personal information. Personal data will only be used by the Yaro Capital Ltd. (or its affiliates, agents, employees, delegates or sub-contractors) for the purposes for which it has been collected. Information may be provided inter alia in writing, in person, by telephone, electronically or otherwise.

Your personal data may be processed by Yaro Capital Ltd. (or its affiliates, agents, employees, delegates or sub-contractors) to comply with Yaro Capital Ltd.’s (or its affiliates, agents, employees, delegates or sub-contractors) legal obligations or for purposes which are necessary for Yaro Capital Ltd.’s (or its affiliates, agents, employees, delegates or sub-contractors) legitimate interests indicated below.  Your personal information may also be used for the following purposes:

• to facilitate the opening and on-going management and administration of your account and shareholdings.  This includes without limitation, confirming and executing instructions, the processing of redemptions, transfers and additional subscription requests and the payment of distributions (if any) and other required actions in order to discharge current or future contractual or legal obligations such as updating and maintaining records and fee calculations;
• to comply with legal obligations relating to, but not limited to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons or entities who may be subject to economic or trade sanctions.  Yaro Capital Ltd. (or its affiliates, agents, employees, delegates or sub-contractors) may carry out, on an on-going basis, anti-money laundering checks and related actions considered necessary in accordance with Yaro Capital Ltd.’s (or its affiliates, agents, employees, delegates or sub-contractors) anti-money laundering procedures;
• for the purposes of: a) detection, prevention, investigation and prosecution of criminal activity, b) establishing and exercising legal rights or defending Yaro Capital Ltd. (or its affiliates, agents, employees, delegates or sub-contractors) themselves or through third parties in legal proceedings or in order to discharge any legal obligation imposed upon them;
• in order to comply with any legal obligation imposed upon, or to pursue legitimate interests of Yaro Capital Ltd. (or its affiliates, agents, employees, delegates or sub-contractors), such as disclosure to other third parties including, but not limited to, service providers of Yaro Capital Ltd. (or its affiliates, agents, employees, delegates or sub-contractors), auditors, regulatory authorities and technology providers; and
• to comply with legal obligations related to the reporting of tax-related information to the relevant tax authorities.

Disclosure of Personal Data to Third Parties

Yaro Capital Ltd. only uses data for the purposes for which it has been collected.  Personal information relating to investors or potential investors may be shared with affiliates, agents, employees, delegates or sub-contractors as permitted by law.  Yaro Capital Ltd. does not disclose non-public personal information about investors or potential investors to non-affiliated third parties, except as permitted or required by law.  Non-affiliated third parties with whom we share data are contractually restricted from using the data for any purpose except for which it has been collected.

Yaro Capital Ltd. (or its affiliates, agents, employees, delegates or sub-contractors) may share non-public personal information, without consent, with affiliated and non-affiliated parties in certain cases, inter alia:

• to comply with any legal obligation, including but not limited to a court order or regulatory inquiry;
• where we reasonably suspect criminal activity may have taken place, including but not limited to: fraud, unauthorized transactions (such as money laundering), or to defend against lawsuits, claims or other liabilities; and
• to process instructions requested by an investor, which may include transactions as well as other corporate actions listed above.  As a result of these transactions, data may be shared with service providers responsible for administration and operations.  Examples of these include, but are not limited to, administrators, accountants, attorneys, auditors, brokers and other professionals.

Transfers of Personal Data Outside the European Economic Area

Yaro Capital Ltd.’s servers which are used for storing and processing investor information including personal data are located in the UK and EEA.  Yaro Capital Ltd. has service providers located in the UK and EEA who will have access to your personal information which have an equivalent level of protection.

Collecting Investor Information Legally

Yaro Capital Ltd. is permitted to legally collect and process your personal information based on the following legal basis:

• where You have given your consent for Yaro Capital Ltd. to do so as explained at the end of this Privacy Policy;
• it can be reasonably expected to be in our legitimate interests to process your personal data for limited purposes in order to maintain, expand and develop our business;
• your personal information is necessary for Yaro Capital Ltd. to fulfil our contractual obligations to you by virtue of you being an investor; and/or
• it is necessary to comply with any applicable regulatory, judicial or legal obligation.

Retention of Personal Data

Yaro Capital Ltd. (or its affiliates, agents, employees, delegates or sub-contractors) will retain your personal information for as long as is required in order to discharge their contractual obligations.  Information may also be retained in order to perform investigations in relation to services provided as well as to comply with legal obligations and exercise their legal rights.

Your Rights in Respect of Personal Data

You have the right to:

• be informed about the personal information Yaro Capital Ltd. collects from you and uses, which is outlined in this Privacy Policy;
• verify that your personal information is being collected and used by Yaro Capital Ltd. and to access the personal information held by Yaro Capital Ltd.;
• correct or amend your personal information if it is inaccurate or incomplete at any time;
• request deletion or removal of any personal information Yaro Capital Ltd. holds about you at any time, subject to Yaro Capital Ltd.’s legal obligations;
• block Yaro Capital Ltd. from collecting and using your personal information. Yaro Capital Ltd. can continue to store such personal information but cannot further collect or use it in any way;
• move, copy or transfer your personal information easily from Yaro Capital Ltd. to another place notified by you to Yaro Capital Ltd.  This shall be done in a safe and secure way without hindrance to the usability of your personal information; and
• object to Yaro Capital Ltd. collecting or using your personal information for the purposes of direct marketing.

To make any requests as listed above, please contact ir@yarocap.com.

Requests relating to your rights above will be confirmed by Yaro Capital Ltd. within one month of receipt of your request.

Withdrawal of Your Consent

You can request that Yaro Capital Ltd. stop collecting and using your personal information at any time by emailing ir@yarocap.com.  However, we may be legally required to retain and/or continue processing some or all of your personal data, notwithstanding your withdrawal of consent.

Contact Us

For questions regarding this Privacy Policy, please contact ir@yarocap.com.