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Terms of Service
Terms of Service
1. About these Terms
These terms of service (the “Terms”) govern your access to and use of the website located at www.fcmaspv.com and any sub-domains operated by FCMA Consultancy Ltd (the “Website”), together with any client portal, secure document area, or other authenticated service made available to you through the Website (the “Investor Portal”). The Website and the Investor Portal are referred to together as the “Services”.
By accessing the Website or by registering for or using the Investor Portal, you confirm that you have read, understood and agreed to be bound by these Terms, our Privacy Policy and our Cookies Notice. If you do not agree to these Terms, you must not access or use the Services.
These Terms are supplemented, in the case of holders of FCMA Notes, by the contractual documents executed at the point of subscription, including the Subscription Agreement, Term Sheet and any related offering or compliance documents (the “Subscription Documents”). In the event of any conflict between these Terms and the Subscription Documents, the Subscription Documents shall prevail in respect of the rights and obligations relating to the FCMA Notes.
2. About us
The Website is operated by FCMA Consultancy Ltd, a private limited company registered in England and Wales (company number 17047272), whose registered office is at 128 City Road, London, EC1V 2NX, United Kingdom (“FCMA Consultancy”, “we”, “us” or “our”).
FCMA Consultancy is the operator of this Website. The fixed-coupon investment programme described on the Website (the “FCMA SPV — Fixed Coupon Programme”) is issued by FCMA SPV Ltd, a separate special purpose vehicle (the “Issuer”). References on the Website to the “FCMA Notes”, the “Programme” or the “Product” are to instruments issued by the Issuer pursuant to the relevant Subscription Documents.
Information about the regulatory status of FCMA Consultancy and the Issuer is set out at the end of these Terms and on the legal information page of the Website. You should not treat anything on the Website as a representation that an investment in the FCMA Notes has been authorised, approved or endorsed by any regulator unless and until that is expressly confirmed in the relevant Subscription Documents.
3. Intended audience and eligibility
The Website and the Programme are made available only to persons who are eligible to receive financial promotions of this kind under the law of their country of residence and, in particular under the law of the United Kingdom, only to persons who fall within one or more of the following categories:
- certified high net worth individuals within the meaning of Article 48 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (the “FPO”);
- certified sophisticated investors within the meaning of Article 50 of the FPO;
- self-certified sophisticated investors within the meaning of Article 50A of the FPO;
- investment professionals within the meaning of Article 19 of the FPO; or
- any other person to whom communications may lawfully be made.
The Programme is not intended for, and will not be made available to, retail clients (as that term is used in the rules of the Financial Conduct Authority) or to members of the general public. By using the Services you confirm that you fall within one or more of the categories described above and that any investment in the Programme would be consistent with your investment experience, objectives and financial position. We may at any time require you to evidence your status before granting or continuing to grant access to the Investor Portal or to the Subscription Documents.
The Services are not directed at, and the Programme is not available to, any person located in, or resident or incorporated in, any jurisdiction where the marketing or sale of the FCMA Notes would be unlawful or would require us to comply with any registration, qualification or other regulatory requirement that we have not satisfied. Without limitation, the Services are not directed at any “U.S. Person” as defined in Regulation S under the U.S. Securities Act of 1933, as amended.
4. No financial advice and no offer
The information made available on the Website is provided for general information purposes only. It does not constitute, and must not be relied upon as, investment, legal, tax, accounting or other professional advice, nor a personal recommendation to subscribe for any FCMA Notes or to take any other course of action. You should obtain independent professional advice before making any investment decision.
Nothing on the Website constitutes an offer to sell, a solicitation of an offer to buy, or a recommendation in respect of any security or financial product. Any subscription for FCMA Notes will only be capable of being made on the basis of, and subject to, the Subscription Documents. References on the Website to fixed coupon rates, scheduled payouts, tenors and similar terms describe the contractual mechanics of the Programme; they are not, and must not be construed as, guarantees, projections or forecasts of any return.
5. Permitted use of the Website
We grant you a limited, revocable, non-exclusive, non-transferable licence to access and view the Website in accordance with these Terms, solely for your own personal or internal business use in connection with assessing or maintaining an investment in the Programme. You must not access or use the Website for any other purpose.
You agree that you will not, and will not permit any third party to:
- access or use any part of the Website by any automated means (including scraping, harvesting or data-mining), other than via search-engine indexing of publicly accessible pages with our prior written consent;
- frame, mirror, republish or otherwise reproduce any part of the Website on any other site, application or service;
- attempt to gain unauthorised access to, interfere with, damage or disrupt the Website, the Investor Portal, the servers on which they are stored or any database, network or hardware connected to them;
- introduce or attempt to introduce any virus, trojan, worm, logic bomb or other material which is malicious or technologically harmful;
- use the Website in any way that breaches any applicable law or regulation, or which infringes the rights of any other person;
- forward, share or otherwise make available any material obtained from the Investor Portal to any person who is not entitled to receive it, including any retail client or any person who has not been verified by us as eligible.
We reserve the right to investigate any actual or suspected breach of this section and, where appropriate, to report it to the relevant law-enforcement, supervisory or other competent authority.
6. The Investor Portal
Access to the Investor Portal is restricted to persons whom we have verified as eligible investors and to whom we have issued credentials. You may only register for and use the Investor Portal if you have been invited to do so by us or by a person authorised to act on our behalf.
When you register for the Investor Portal you agree to provide accurate, complete and current information, to keep that information up-to-date, and to comply with any verification, identity, source-of-funds and ongoing due-diligence requirements that we apply from time to time. We may decline to grant or maintain Investor Portal access at our discretion, including where we are unable to satisfy ourselves as to your identity, your eligibility or our regulatory obligations.
You are responsible for keeping your Investor Portal credentials confidential, for enabling and maintaining the multi-factor authentication that we require, and for all activity that takes place under your account. You must notify us immediately at the contact details set out in section 19 if you suspect any unauthorised use of your account or any other breach of security. We may suspend or terminate your access to the Investor Portal at any time, with or without notice, where we reasonably consider it necessary to protect the security of the Services, the integrity of the Programme, or our compliance with any legal or regulatory obligation.
The Investor Portal is provided as a record-keeping and communications facility. It is not, and must not be relied upon as, a settlement, payment-initiation or trading system. Any figures presented through the Investor Portal are entered manually by us or our appointed operators and may be subject to subsequent correction, reconciliation or restatement. Authoritative records of your investment, your contractual entitlements and any payments made or scheduled are set out in the Subscription Documents and the records maintained by the Issuer and its agents.
7. Information, accuracy and no warranty
We take reasonable care to ensure that the information published on the Website is accurate and up-to-date at the time of publication. However, the Website is general in nature and may not reflect changes in market conditions, regulation, the Programme or our internal policies. The Website is provided on an “as is” and “as available” basis. To the fullest extent permitted by law, we make no representations or warranties of any kind, whether express or implied, including any warranty of accuracy, completeness, suitability for a particular purpose, non-infringement or freedom from defect or interruption.
You should not place reliance on any information on the Website without independently verifying it, and you accept that any reliance you place on such information is at your own risk. Where any information on the Website is inconsistent with the Subscription Documents, the Subscription Documents will prevail.
8. Intellectual property
All content on the Website, including text, graphics, logos, icons, photographs, audio and video clips, data compilations, page layouts, underlying code, software and the selection and arrangement of such content (the “Site Content”) is owned by or licensed to FCMA Consultancy and is protected by copyright, trade mark, database right and other intellectual property rights and laws around the world.
You are permitted to view, download for caching purposes only, and print extracts of the Site Content for your own personal use or your internal business use, subject to these Terms. You must not modify any content, use it for any commercial purpose, or remove any copyright, trade-mark or other proprietary notice. You must not adapt, translate, reverse-engineer, decompile or create derivative works from the Site Content. The names “FCMA”, “FCMA SPV”, “FCMA Consultancy”, the FCMA chevron device and any related branding are trade marks of, or used under licence by, FCMA Consultancy and may not be used without our prior written consent.
9. Third-party links and content
The Website may contain links to third-party websites, services or resources that are not under our control. Such links are provided for convenience only and do not constitute any endorsement by us of those websites, services or resources or of any person responsible for them. We accept no responsibility for the availability, content, security or privacy practices of any third-party site or service.
10. Privacy and cookies
Our use of personal data collected through the Website and the Investor Portal is described in our Privacy Policy and Cookies Notice, which form part of these Terms. By using the Services you acknowledge that you have read, and consent where consent is required to, our Privacy Policy and Cookies Notice.
11. Risk warning
The FCMA SPV — Fixed Coupon Programme is a fixed-return investment product. Returns are contractually fixed at the rate and on the schedule agreed in the Subscription Documents; they are not speculative and they are not, and must not be described as, guaranteed beyond the contractual obligations of the Issuer. The Programme is suitable only for investors who can bear the loss of all or part of the capital invested. The price and value of investments and the income derived from them can fall as well as rise, and you may not get back the full amount of your subscription.
The Programme is not covered by the UK Financial Services Compensation Scheme or any equivalent investor-protection scheme. Before subscribing for any FCMA Notes you should read the Subscription Documents in full, including the risk factors set out in them, and seek independent professional advice.
12. Disclaimer of warranties
Without limitation to section 7, and to the fullest extent permitted by law, we exclude all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity in respect of the Services. We do not warrant that the Services will be uninterrupted, timely, secure or free from error, or that any defects will be corrected.
13. Limitation of liability
Nothing in these Terms shall limit or exclude our liability for: (a) death or personal injury caused by our negligence; (b) fraud or fraudulent misrepresentation; or (c) any other liability that cannot lawfully be limited or excluded under English law.
Subject to the preceding paragraph, we shall not be liable to you, whether in contract, tort (including negligence), breach of statutory duty or otherwise, arising under or in connection with the Services or these Terms, for: (i) any loss of profits, sales, business, revenue, anticipated savings, agreements or contracts, opportunity, goodwill, reputation or data; or (ii) any indirect, special, incidental, consequential or punitive loss or damage. Our total aggregate liability to you for all losses arising under or in connection with the Services or these Terms, whether in contract, tort (including negligence), breach of statutory duty or otherwise, shall not exceed one hundred US dollars ($100).
The limitations in this section apply only to your use of the Services and do not affect any rights or remedies you may have under the Subscription Documents in respect of any FCMA Notes that you hold. Your remedies in respect of the FCMA Notes themselves are governed exclusively by the Subscription Documents.
14. Your indemnity
You agree to indemnify us, our affiliates and our respective directors, officers, employees and agents on demand against all liabilities, losses, damages, costs and expenses (including reasonable legal fees) arising out of or in connection with: (a) your breach of these Terms; (b) your misuse of the Services; or (c) your infringement of any law or of the rights of any third party in connection with your use of the Services.
15. Suspension and termination
We may, at our discretion, suspend, restrict or terminate your access to all or any part of the Services at any time, with or without notice, including where we reasonably believe that you have breached these Terms, that your continued access poses a security or compliance risk, or that we are required to do so by law, regulation or order of a court or competent authority.
Termination of your access to the Services does not affect any rights or obligations that have accrued up to the date of termination, nor any provision of these Terms which is expressed or by its nature intended to survive termination, including sections 7 to 14, 16, 18 and 20 to 22.
16. Changes to the Services and to these Terms
We may modify, suspend or discontinue any part of the Services at any time, with or without notice. We may also amend these Terms from time to time, for example to reflect changes in our practices, in the law or in regulatory guidance. Where the changes are material, we will give you reasonable notice of them, including through a notice on the Website or through the Investor Portal. Your continued use of the Services after the effective date of the change constitutes your acceptance of the updated Terms. The version in force at any time is the version published on the Website at that time.
17. Force majeure
We shall not be liable for any failure to perform, or delay in performing, any of our obligations under these Terms which is caused by an event outside our reasonable control, including acts of God, war, civil unrest, terrorism, pandemic, fire, flood, storm, strike, industrial dispute, failure or compromise of telecommunications or internet networks, the act of any government or competent authority, or the failure of any third party on whom we are dependent.
18. General
Entire agreement: These Terms, together with the Privacy Policy, the Cookies Notice and any document expressly referred to in them, set out the entire agreement between you and us in respect of your use of the Services and supersede any previous agreement or understanding between us in relation to that subject matter.
Severability: If any provision of these Terms is found by any court or other competent authority to be invalid, illegal or unenforceable, that provision shall be deemed deleted and the remaining provisions shall continue in full force and effect.
No waiver: A failure or delay by us to exercise any right or remedy under these Terms shall not constitute a waiver of that right or remedy or of any other right or remedy.
Assignment: You may not assign or transfer any of your rights or obligations under these Terms without our prior written consent. We may assign or transfer our rights and obligations under these Terms, in whole or in part, on notice to you.
Third-party rights: A person who is not a party to these Terms has no right under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of these Terms, save that the Issuer may enforce the provisions of these Terms which expressly confer a benefit on it.
Notices: Any notice given by us to you under these Terms may be given by email to the address you have provided to us, by post to the address most recently notified to us, or by a notice posted on the Website or through the Investor Portal. Any notice given by you to us must be sent to the contact details in section 19.
19. Contact and complaints
Questions or complaints about the Services or these Terms should be addressed to:
FCMA Consultancy Ltd
128 City Road, London, EC1V 2NX, United Kingdom
Email: enquiries@fcmaspv.com
We will acknowledge any complaint within five (5) business days of receipt and will respond substantively as soon as reasonably practicable, in accordance with our complaints-handling procedure (which is available on request).
20. Governing law and jurisdiction
These Terms, and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with them or their subject matter or formation, shall be governed by and construed in accordance with the law of England and Wales.
You and we each irrevocably agree that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms or their subject matter or formation, save that we retain the right to bring proceedings in any other competent jurisdiction in order to protect our rights, including in any jurisdiction in which you are resident, domiciled or hold assets.
21. Regulatory information
FCMA Consultancy Ltd is a private limited company registered in England and Wales (company number 17047272). Information about the regulatory permissions held by FCMA Consultancy and the Issuer, and the basis on which the Programme is offered, is available on request and is set out in the Subscription Documents. [Insert final regulatory authorisation wording, including the name and registration number of the authorised firm, prior to publication.]
This Website is a financial promotion and is communicated, or approved for communication, only in accordance with the Financial Services and Markets Act 2000 and the FPO. It is directed only at the categories of person identified in section 3.
© 2026 FCMA Consultancy Ltd. All rights reserved.
Privacy Policy
Privacy Policy
1. About this Privacy Policy
This Privacy Policy explains how FCMA Consultancy Ltd (“FCMA Consultancy”, “we”, “us” or “our”) collects, uses, shares and protects personal data in connection with the website at www.fcmaspv.com and any sub-domains (the “Website”) and any client portal, secure document area, or other authenticated service made available through the Website (the “Investor Portal”). The Website and the Investor Portal are referred to together as the “Services”.
FCMA Consultancy is the controller of personal data processed in connection with the Services. We comply with the United Kingdom General Data Protection Regulation, the Data Protection Act 2018 (together, the “UK GDPR”), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”) and, where applicable, the EU General Data Protection Regulation (Regulation (EU) 2016/679) (the “EU GDPR”).
Where we process personal data in connection with subscriptions for, or holdings of, FCMA Notes issued under the FCMA SPV — Fixed Coupon Programme, our separate Investor Privacy Notice also applies. In the event of any inconsistency between this Privacy Policy and the Investor Privacy Notice in respect of personal data processed for those purposes, the Investor Privacy Notice will prevail.
2. Controller and contact details
| Controller | FCMA Consultancy Ltd |
|---|---|
| Company number | 17047272 |
| Registered office | 128 City Road, London, EC1V 2NX, United Kingdom |
| Privacy enquiries | enquiries@fcmaspv.com |
| Data Protection Lead | [Insert name and title prior to publication] |
| Postal address for written enquiries | The Data Protection Lead, FCMA Consultancy Ltd, 128 City Road, London, EC1V 2NX, United Kingdom |
We have not appointed an EU representative under Article 27 of the EU GDPR. If we begin to offer the Services, or to monitor the behaviour of data subjects, in the European Economic Area (the “EEA”) on a basis that requires us to appoint a representative, we will update this Privacy Policy accordingly.
3. Scope of this Policy
This Privacy Policy applies to personal data we process about:
- visitors to the Website, including persons who complete enquiry, contact, request-information or schedule-a-call forms;
- prospective investors who interact with us in connection with the FCMA SPV — Fixed Coupon Programme;
- users of the Investor Portal, including holders of FCMA Notes and the individuals authorised to operate accounts on their behalf;
- representatives, beneficial owners and authorised signatories of any corporate or institutional investor;
- other individuals who correspond with us in connection with the Services, including professional advisers and counterparties.
4. Personal data we collect
We collect and process the following categories of personal data:
4.1 Information you provide to us
- Identity data: name, date of birth, nationality, photographic identification.
- Contact data: postal address, email address, telephone number.
- Professional data: job title, employer, professional qualifications, business address.
- Investor-classification data: information used to certify your status as a high net worth, sophisticated or professional investor, including any self-certification statements you sign.
- Financial data: bank-account details, source-of-funds and source-of-wealth evidence, tax-residency status, tax-identification numbers, expected subscription amount.
- KYC and AML data: identity-verification documents, residential-address evidence, sanctions and politically-exposed-person screening results, beneficial-ownership information for entity investors.
- Account data: Investor Portal login identifier, password (held in hashed form), security-question answers, multi-factor-authentication credentials and recovery information.
- Communications data: correspondence with us by email, post, telephone, web form, chat or messaging, including any call recordings (where notified) and meeting notes.
- Marketing-preference data: your preferences in respect of receiving marketing communications and the channels through which you have agreed to receive them.
4.2 Information we collect automatically
- Technical data: internet-protocol (IP) address, login data, browser type and version, device identifier, operating system, time-zone setting, location and approximate geolocation derived from your IP address.
- Usage data: information about how you use the Website and the Investor Portal, including pages visited, click-paths, referring and exit pages, dates and times of visits, and session duration.
- Cookie and similar-technology data: information stored on or retrieved from your device using cookies, web beacons, local storage and similar technologies, as further described in section 12.
4.3 Information we receive from third parties
- Identity-verification and screening providers (such as SumSub) that perform identity, address, sanctions, adverse-media and politically-exposed-person checks on our instructions.
- Banks, payment-service providers and correspondent banks that confirm receipt of subscription monies or process scheduled coupon payouts.
- Professional advisers, introducers and intermediaries who refer you to us, where they have your authority to do so.
- Public, regulatory and commercial sources, including the Companies House register, sanctions and watch-list databases, and credit-reference and fraud-prevention agencies, where we use them to verify information you have given us or to comply with our legal obligations.
5. Purposes and legal bases for processing
We use personal data only where we have a lawful basis to do so. The following table summarises the principal purposes for which we process personal data and the lawful bases on which we rely.
| Purpose | Categories of data | Lawful basis |
|---|---|---|
| Operating the Website and Investor Portal, including authentication and security | Account, technical, usage | Performance of a contract; legitimate interests (operating a secure online service) |
| Verifying eligibility (HNW / sophisticated / professional status) and onboarding investors | Identity, contact, professional, investor-classification, KYC and AML | Performance of a contract; legal obligation; legitimate interests |
| Performing the Subscription Documents and administering the FCMA Notes | Identity, contact, financial, account | Performance of a contract |
| Complying with anti-money-laundering, counter-terrorism-financing, sanctions, tax (CRS / FATCA), companies-law and other regulatory obligations | Identity, KYC and AML, financial, communications | Legal obligation; legitimate interests |
| Preventing, detecting and investigating fraud, financial crime and breaches of these Services | All categories | Legal obligation; legitimate interests |
| Responding to enquiries, providing investor services and managing complaints | Identity, contact, communications | Legitimate interests; performance of a contract |
| Sending marketing communications about the Programme and related services to existing investors and to prospective investors who have requested information | Identity, contact, marketing-preference | Consent; legitimate interests (soft opt-in for existing investors, where permitted) |
| Improving the Website and the Investor Portal, monitoring performance and analysing usage | Technical, usage, cookie data | Legitimate interests; consent (for non-essential cookies) |
| Establishing, exercising or defending legal claims | All categories | Legitimate interests; legal obligation |
Where we rely on legitimate interests as a lawful basis, we have carried out an assessment to ensure that those interests are not overridden by your rights and freedoms. You have the right to object to processing carried out on this basis at any time, as set out in section 11.
We do not routinely process special-category personal data (such as data revealing health, racial or ethnic origin, religious or philosophical beliefs, or trade-union membership) or data relating to criminal convictions or offences. Where we do process such data, for example because it is contained in identity documents you have provided or where required by law for sanctions and politically-exposed-person screening, we rely on the conditions set out in Articles 9 and 10 of the UK GDPR (and the corresponding provisions of the EU GDPR) and Schedule 1 to the Data Protection Act 2018, including substantial public interest in the prevention of fraud and money laundering.
6. Marketing communications
We will send you marketing communications about the FCMA SPV — Fixed Coupon Programme and related services only where you have given us your consent or where we are permitted to do so under the “soft opt-in” provisions of PECR. You may withdraw your consent or opt out of marketing at any time by clicking the unsubscribe link in any marketing email, by adjusting your preferences in the Investor Portal, or by contacting us using the details in section 14. Withdrawing consent does not affect the lawfulness of any processing carried out before the withdrawal.
We will not pass your contact details to any third party for that party's own marketing purposes.
7. Recipients of personal data
We share personal data only with parties who need it for the purposes described in section 5. Recipients include:
- FCMA SPV Ltd (the Issuer of the FCMA Notes) and its appointed agents, in connection with the issuance and administration of the Programme;
- UCAT Services Limited, the Security Trustee, in connection with its role under the Security Trust Deed;
- SumSub and other identity-verification, sanctions-screening and fraud-prevention providers engaged by us;
- our hosting, e-mail, customer-relationship-management, document-storage, analytics, security-monitoring and other IT-service providers, who process personal data on our behalf as processors under written agreements that meet the requirements of Article 28 of the UK GDPR;
- professional advisers, including external lawyers, accountants, tax advisers, auditors and consultants, where they need access to perform their services to us;
- banks, payment-service providers and correspondent banks processing subscriptions and coupon payouts;
- competent authorities, including HM Revenue & Customs, the National Crime Agency, the Information Commissioner's Office and any other regulator, court or law-enforcement agency, where required by law;
- any successor to all or part of our business, or to a prospective successor in connection with a corporate or financing transaction, subject to appropriate confidentiality protections.
8. International transfers
Some of the recipients listed in section 7 are located outside the United Kingdom and the EEA, including in jurisdictions in which our IT and screening providers operate. Where we transfer personal data to a country that is not subject to a finding of adequacy by the United Kingdom Government or the European Commission (as applicable), we put in place appropriate safeguards in accordance with Article 46 of the UK GDPR and the EU GDPR, including:
- the United Kingdom International Data Transfer Agreement (the “IDTA”) issued under section 119A of the Data Protection Act 2018;
- the European Commission's Standard Contractual Clauses, where appropriate together with the United Kingdom International Data Transfer Addendum to those clauses;
- any successor mechanism approved by the United Kingdom Government or the European Commission from time to time.
We carry out transfer-risk assessments where required and apply additional technical, organisational and contractual measures where necessary to ensure that the level of protection guaranteed by the UK GDPR and the EU GDPR is not undermined. Copies of the relevant safeguards are available on request to the contact in section 14.
9. Retention
We retain personal data only for as long as is necessary for the purposes for which it was collected, including to satisfy any legal, accounting, tax or reporting requirements. The principal retention periods we apply are as follows:
| Category | Indicative retention period |
|---|---|
| Investor Portal account data | Duration of the account, plus 7 years following closure |
| KYC, AML, sanctions and source-of-funds records | At least 5 years following the end of the business relationship, in accordance with the Money Laundering Regulations 2017 (longer if required by law or to defend legal claims) |
| Subscription, payment and tax records | At least 7 years following the year in which the relevant transaction occurred |
| Marketing-preference data | For as long as you remain subscribed, plus a reasonable period to evidence consent or withdrawal |
| Website analytics and cookie data | As described in our Cookies Notice — typically up to 26 months |
| Enquiries that do not lead to a relationship | Up to 24 months from last meaningful contact |
At the end of the applicable retention period, personal data is securely deleted or irreversibly anonymised, save where its further retention is required by law, regulation or legal proceedings.
10. Security
We have implemented appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. Those measures include encryption in transit and at rest where appropriate, role-based access controls, mandatory multi-factor authentication for the Investor Portal, vendor due diligence, security-monitoring, regular review of our policies, and staff training.
No method of transmission over the internet, and no method of electronic storage, is completely secure. We cannot guarantee absolute security, but we will notify you and the Information Commissioner's Office (or other competent supervisory authority) of any personal-data breach in the manner and within the timescales required by applicable data-protection law.
11. Your rights
Subject to applicable law, you have the following rights in respect of your personal data:
- Access — to request a copy of the personal data we hold about you and information about how we process it.
- Rectification — to request correction of inaccurate or incomplete personal data.
- Erasure — to request deletion of personal data in defined circumstances, for example where it is no longer needed for the purposes for which it was collected.
- Restriction — to request that we restrict our processing of your personal data in defined circumstances.
- Objection — to object to processing carried out on the basis of legitimate interests, and to object at any time to processing for direct-marketing purposes.
- Portability — to receive personal data you have provided to us in a structured, commonly used and machine-readable format, and to have it transmitted to another controller, where the processing is based on consent or on a contract and is carried out by automated means.
- Withdrawal of consent — to withdraw any consent previously given, without affecting the lawfulness of processing carried out before the withdrawal.
- Automated decision-making — not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you, save where permitted by law. We do not carry out such automated decision-making in connection with the Services.
To exercise any of these rights, please contact us using the details in section 14. We may need to verify your identity before responding. We will respond within the timescales required by applicable data-protection law (generally one month, extendable by up to a further two months for complex requests).
You also have the right to lodge a complaint with a supervisory authority. In the United Kingdom this is the Information Commissioner's Office (www.ico.org.uk). If you are based in the EEA, you may complain to the supervisory authority in your country of habitual residence, place of work, or place of the alleged infringement.
12. Cookies and similar technologies
Cookies are small text files placed on your device when you visit a website. We use cookies and similar technologies for the following purposes:
- Strictly necessary cookies — required to operate the Website and the Investor Portal, including for authentication, session management, security and load balancing. These cookies are set on the basis of our legitimate interests and do not require consent under PECR.
- Performance and analytics cookies — used to understand how the Website is used and to improve it. These cookies are set only with your consent.
- Functionality cookies — used to remember choices you make, such as language and display preferences. These cookies are set only with your consent.
We do not use advertising cookies. A separate Cookies Notice is published on the Website and gives further information about each cookie we use, the duration for which it is stored and the third party (if any) that sets it. You may grant, refuse or withdraw consent at any time using the cookie-management tool on the Website, and you may also block or delete cookies using your browser settings; doing so may, however, affect the functionality of the Services.
13. Children
The Services are intended only for adults who satisfy the eligibility requirements set out in our Terms of Service. We do not knowingly collect personal data from children under the age of 18. If you believe that we hold personal data of a child, please contact us using the details in section 14 and we will take steps to delete it.
14. Contact and complaints
If you have any questions about this Privacy Policy or about how we process your personal data, or if you wish to exercise any of your rights, please contact us at:
The Data Protection Lead
FCMA Consultancy Ltd
128 City Road, London, EC1V 2NX, United Kingdom
Email: enquiries@fcmaspv.com
We aim to acknowledge any privacy enquiry or complaint within five (5) business days of receipt and to provide a substantive response as soon as reasonably practicable. If you are not satisfied with our response, you have the right to refer the matter to the Information Commissioner's Office (in the United Kingdom) or to another competent supervisory authority, as described in section 11.
15. Changes to this Privacy Policy
We may amend this Privacy Policy from time to time, for example to reflect changes in our practices, in the Services, in the law or in regulatory guidance. The date at the top of this Privacy Policy indicates when it was last updated. Where the changes are material, we will give you prominent notice of them on the Website or, where appropriate, by direct communication. Your continued use of the Services after the effective date of any change constitutes your acceptance of the updated Privacy Policy.
© 2026 FCMA Consultancy Ltd. All rights reserved.
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