Disclosures
VAR Capital Limited – Stewardship Code AND Shareholder Rights Directive (SRD) Engagement Policy
Please click here for our Stewardship Code AND Shareholder Rights Directive (SRD) Engagement Policy
VAR Capital Limited – Complaints Policy
Please click here for our Complaints Policy
Website Disclaimer
The contents of this website are communicated by, and the property of, VAR Capital Limited (“VAR”) which is authorised and regulated in the UK by the Financial Conduct Authority (“FCA”) under reference 718558.
Products and Services
The information contained herein is current at the date of publication, but is subject to change without notice. VAR has expressed its own views and opinions on this website, and these may change without notice. This website is not directed at you if VAR is prohibited by any law of any jurisdiction from making the information on this site available to you and is not intended for any use that would be contrary to local law or regulation. None of the information contained on this website is intended to constitute any offer to sell or an invitation or solicitation of an offer to buy any product or service by VAR and must not be relied upon in connection with any investment decision. Products or services mentioned on this site are subject to legal and regulatory requirements in applicable jurisdictions and may not be available in all jurisdictions. Accordingly persons are required to inform themselves of and observe any such restrictions. Nothing in this website should be construed as investment, tax, legal or other advice.
Risk Warning
Past performance is not necessarily a guide to future performance. The value of investments and the income of any financial instruments mentioned in the website may fall as well as rise, and investors may get back less than the amount originally invested. Fluctuations in exchange rates may have a positive or an adverse effect on the value of foreign-currency denominated securities and financial instruments. Certain investments involve an above-average degree of risk and should be seen as long-term in nature. The investment products and services described in the website may have tax consequences. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. You acknowledge that levels and bases of taxation may change, and that VAR does not provides tax advice. You should consult your own tax advisor in order to understand the tax consequences of the products and services described in the website.
VAR Best Execution Policy
Please click here for VAR’s Best Execution Policy.
Privacy and Data Protection
All information or data sent to VAR via this site, by email or in any other way connected with consulting this site will be handled in accordance with statutory and regulatory requirements. As a visitor to, or person using, this site, you hereby agree VAR and its relevant associated entities may record, retain and process any personal data that relates to you for the following purposes: the management of VAR clients, including new business prospects, management of the contractual relationship, the prevention of irregularities, generating statistics and tests and for marketing purposes for relevant financial products and services. VAR may ask you to provide your name and personal contact details if you wish to access tools and models via this site. Access to personal data gathered via this site is restricted to those persons who require this data in order to carry out their duties. You also agree that this data may be passed on to all entities associated with VAR for the same purposes or to other persons in order to comply with any statutory obligation or in the event of legal interests. VAR abides by the General Data Protection Regulation (“GDPR”). VAR will generally be a data controller in respect of your relationship with VAR. VAR may process your personal data ourselves or through others acting as data processors on our behalf. VAR may share your personal VAR data with a third party where this is required by law or where we have another legitimate interest in doing so. VAR may transfer your data to non-EEA countries, should we do so, unless an exemption applies, we will seek to put in place appropriate safeguards, such as the EU-approved standard contractual clauses to ensure that your personal data is treated in a manner that is consistent with and respects the EU and UK laws on data protection.
Copyright
The copyright and all other rights in all of the material on this website are owned by VAR or the material is included with the permission of the rights owner. The information contained in this website is intended solely for the use of the person who has accessed this information and may not be reproduced, distributed or published to any other person. You may copy material on this website for your own private or domestic use only. All other copying is prohibited.
Links to other websites
On this website you may be offered automatic links to other non-VAR websites. These links are provided only as convenience. VAR does not accept any responsibility for the content of those websites or your use or inability to use such websites, the owners of which do not necessarily have any link, commercial or otherwise, with VAR. The inclusion of any link does not imply affiliation, sponsorship, endorsement, verification or monitoring or approval by VAR of any information contained in any non-VAR website. You should also be aware that the terms and conditions of such website and the website’s statement relating to the collection and use of your personal information may be different from those applicable to your use of this website.
Disclaimer
It is the responsibility of the individual user to consider his or her legal and regulatory position in the relevant jurisdiction, the risks associated with trading such products and to ensure that the use of the content and the subsequent making of any investment does not contravene any such restrictions or applicable laws and regulations of any jurisdiction. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific security, index, report, opinion, advice or other content. This does not exclude or restrict any duty or liability that VAR has to its clients under the Financial Services and Markets Act 2000 (as amended from time to time) or any other regulatory system under the laws of applicable jurisdictions.
VAR, its subsidiaries, associated entities, directors, employees, representatives or suppliers will not be liable, on any grounds whatsoever, contractually or not, for any direct or indirect damage that may arise as the result of it being possible or impossible to gain access to this site, the accessing, visiting or use of this site and/or the information provided, the sending, or receiving of information via this site and/or the operation or non-operation of this site, except in the event of intentional or serious blame on its part. The information contained on this site, including any third party data is published in good faith and VAR believes that the information is accurate at the time of publication but no representation or warranty, express or implied, is made by VAR as to its accuracy or completeness and it should not be relied on as such.
VAR shall therefore have no liability, save for any liability that VAR may have under the UK Financial Services and Markets Act 2000, for any loss or damage arising out of the use or reliance on the information provided including without limitation, any loss of profit or any other damage, direct or consequential. Nor will VAR, its subsidiaries, associated entities, directors, employees, representatives or suppliers be, under any circumstances, liable for any corruption of data that may occur as the result of technical problems (e.g. transmission errors, technical failures, breakdowns, intervention of third parties, etc.) and/or for any damage or loss relating to software or hardware that is the result of any virus, defect or malfunction in relation to access or use of the site.
MIFIDPRU Public Disclosure 2024
Please click here for our MIFIDPRU Public Disclosure 2024
Conflicts of Interest Policy
Please click here for our “Conflicts of Interest Policy
any third party that accesses the Website and is not either (i) employed by VAR Capital Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to VAR Capital Limited and accessing the Website in connection with the provision of such services; and
Website
the website that you are currently using, www.varcapital.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
2. In this privacy policy, unless the context requires a different interpretation:
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. “including” is understood to mean “including without limitation”;
e. reference to any statutory provision includes any modification or amendment of it;
f. the headings and sub-headings do not form part of this privacy policy.
Scope of this privacy policy
3. This privacy policy applies only to the actions of VAR Capital Limited and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
4. For purposes of the applicable Data Protection Laws, VAR Capital Limited is the “data controller”. This means that VAR Capital Limited determines the purposes for which, and the manner in which, your Data is processed.
Data collected
5. We may collect the following Data, which includes personal Data, from you:
a. name;
b. contact Information such as email addresses and telephone numbers;
c. IP address (automatically collected);
d. web browser type and version (automatically collected);
e. operating system (automatically collected); in each case, in accordance with this privacy policy.
How we collect Data
6. We collect Data in the following ways:
a. data is given to us by you; and
b. data is collected automatically.
Data that is given to us by you
7. VAR Capital Limited will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
c. when you elect to receive marketing communications from us; `
d. when you write to us by e-mail and/or provide feedback;
e. when you visit our website;
f. through cookies;
in each case, in accordance with this privacy policy.
Data that is collected automatically
8. To the extent that you access the Website, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our use of Data
9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. internal record keeping;
b. improvement of our products / services;
c. transmission by email of marketing materials that may be of interest to you;
d. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customize or update the Website;
in each case, in accordance with this privacy policy.
10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
11. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft opt-in:
a. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
c. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below
12. We may use your Data to show you VAR Capital Limited adverts and other content on other websites. If you do not want us to use your data to show you VAR Capital Limited adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).
Who we share Data with
13. We may share your Data with the following groups of people for the following reasons:
a. third party service providers who provide services to us which require the processing of personal data – to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website runs smoothly;
b. relevant authorities – if we have a legal requirement to do so;
c. Companies that help us with Functional Analytics – to help us solve technical issues with the Website for instance;
d. Suppliers – to ensure smooth functionality of our website;
e. Google Analytics – provided we have your consent to store cookies;
f. Cloud Computing Power and Storage Providers;
in each case, in accordance with this privacy policy.
Keeping Data secure
14. We will use technical and organizational measures to safeguard your Data, for example:
a. access to your account is controlled by a password and a username that is unique to you.
b. we store your Data on secure servers.
15. Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us via this e-mail address: [email protected].
16. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Data retention
17. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
18. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
Your rights
19. You have the following rights in relation to your Data:
a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information, we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase – the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
e. Right to data portability – the right to request that we move, copy or transfer your Data.
f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
20. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: [email protected].
21. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
22. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Transfers outside the United Kingdom and European Economic Area
23. Data which we collect from you may be stored and processed in and transferred to countries outside of the UK and European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the UK or EEA or one of our service providers is situated in a country outside the UK or EEA.
24. We will only transfer Data outside the UK or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g., by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission.
25. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.
Links to other websites
26. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
Changes of business ownership and control
27.VAR Capital Limited may, from time to time, expand or reduce our business and this may involve the sale and/ or the transfer of control of all or part of VAR Capital Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
28. We may also disclose Data to a prospective purchaser of our business or any part of it.
29. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Cookies
30.This Website may place and access certain Cookies on your computer. VAR Capital Limited uses Cookies to improve your experience of using the Website. VAR Capital Limited has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
31. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
32. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling VAR Capital Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
33. This Website may place the following Cookies:
Type of Cookie
Purpose
Analytical/performance cookies
They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies
These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
34. You can find a list of Cookies that we use in the Cookies Schedule.
35. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser.
36. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalization settings.
37. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
38. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
General
39.You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
40.If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
41. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
42.This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Changes to this privacy policy
43. VAR Capital Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact VAR Capital Limited by email at [email protected].
Attribution
44. This privacy policy was created using a document from Rocket Lawyer.
27 January 2021
Cookies
Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.
Analytical/performance
We use the following analytical/performance cookies:
Description of Cookie
Purpose
Google Analytics (_ga)
This cookie is associated with Google Universal Analytics and is used to distinguish unique users. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.
Google Analytics (_gid)
This cookie stores and updates a unique value for each page visited.
Google Analytics (_gat)
Default Google Analytics cookie used to limit the collection of data on high traffic sites.
Functionality
We use the following functional cookies:
Description of Cookie
Purpose
Used to recognize you when you return to our website
This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting
We use the following targeting cookies:
Description of Cookie
Purpose
These cookies record your visit to our website, the pages you have visited and the links you have followed.
We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.