PRIVACY POLICY

 

Daedalus Partners LLP and its affiliate companies including Talos Private Investor Network Limited (Daedalus) are committed to respecting and protecting your privacy.

This policy sets out the basis on which any personal data we collect, or currently hold, about you will be processed and used by us. We would advise you to read the policy carefully.

The Data Controller for the purposes of the Data Protection Act 1988 is Daedalus Partners LLP, 59 Grosvenor Street, London, W1K 3HZ. Contact can also be made via email to
info@daedalus-partners.com.

 

1. Information we may collect

 

•  Information you may provide on application forms for investment products, including address, tax and financial information required to make all appropriate tax and legal filings and make distributions to you.

•  Information that you provide when filling in forms on our website or investor portal. This may include your email address physical address, telephone number and other contact details.

•  As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyse trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

 

2. How we use this data

 

•  To provide you with information, products or services that you request from us or which we feel may be of interest to you.

•  To ensure our ongoing reporting and regulatory commitments to you are met.

•  To notify you of any changes to our business or our service.

•  To invite you to events that we feel would be of interest to you.

•  To analyse browsing trends, administer our website site, track website users’ movements around the site and to gather demographic information about our user base as a whole. We do not link data obtained through web analytics to personally identifiable information.

•  To ensure that content from our website is presented in the most effective manner for you and for your computer.

 

3. Storage of your data

 

Information which you submit to us either via our website or otherwise is sent to a computer located in the United Kingdom. Information submitted by you may be transferred to, stored and processed by our service providers and other reputable third party organisations, which may be situated outside the European Economic Area. In addition, if you use our services while you are outside the EEA your information may be transferred outside the EEA in order to provide you with those services, and by submitting your information to us you consent to such usage.

Your data will be held at least until all legal and regulatory requirements regarding storage of records have been fulfilled by Daedalus. In some cases involving the collection and processing of financial data may require a retention period of up to 7 years.

 

4. Disclosure of your data

 

We may disclose your personal information to any member of our group, which means our subsidiaries and affiliates, including Talos Private Investor Network Limited.

 

We may disclose your personal information to third parties in limited circumstances, such as:

 

•  In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

•  If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

•  If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

5. Your Rights

 

You have the right to:

 

•  Ask us not to process your data for marketing purposes.

•  Correct, amend, and/or delete your data by making a request in writing to Daedalus, subject to that request not breaching a legal requirement for Daedalus to hold data.

•  Request details of all data held by us about you.

•  Withdraw consent to process your data.

•  Complain directly to Daedalus about the way we process your data.

•  Complain directly to the relevant data protection authority about the way we process your data.

 

6. Changes to our policy

 

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

 

7. Questions

 

If you have any questions relating to this policy, please email info@daedalus-partners.com.

 

Dated: 17 May 2018

 

 

LEGAL

 

Daedalus Partners LLP is a limited liability partnership registered in England and Wales with registration number OC365551. Its registered office is at 4th Floor, 59 Grosvenor Street, London,
W1K 3HZ. A list of members of the LLP is available upon request.

 

Daedalus Partners LLP, is authorised and regulated by the Financial Conduct Authority (Register number 564221), see http://www.fca.org.uk/register for registration details.

 

Information on this site is for general information only and is not intended to provide legal or other professional advice. You should not place any reliance on any such information. Although we do our best to ensure that information on this website is accurate and up to date, we make no representation or warranty of any kind about the accuracy, completeness or suitability for any purpose of any such information. We may make changes to the material on this website at any time without notice.

 

All intellectual property content on this site is either owned by or licensed to Daedalus Partners LLP. You will infringe our copyright or other rights if you reproduce any part of this website other than for your personal use without our prior written approval.

 

Our site may contain links to and from other third party websites, and if you use these links you leave our site. We do not control these third party websites and are not responsible for their contents. Use of any such websites is entirely at your own risk.

 

You may submit information or other data to use either through this website or by direct contact with us. We may also collect data from you in other ways (e.g. by use of cookies). Some of the data we collect may be personal data; we shall treat all personal data collected by us in accordance with all applicable UK data protection laws.

 

Daedalus Partners LLP (‘The Partnership’)

PILLAR 3 DISCLOSURE

 

As at 31st March 2016

 

The Capital Requirements Directive (‘the Directive’) of the European Union establishes a revised regulatory capital framework across Europe governing the amount and nature of capital credit institutions and investment Partnerships must maintain. In the United Kingdom, the Directive has been implemented by the Financial Conduct Authority (‘FCA’) in its regulations through the General Prudential Sourcebook (‘GENPRU’) and the Prudential Sourcebook for Banks, Building Societies and Investment Partnerships (‘BIPRU’).

 

Frequency of Disclosure

 

It is the intention of the Company to update its Pillar 3 on an annual basis (after the previous year’s annual accounts have been audited and finalised, unless circumstances warrant a more frequent updated. Disclosures will be published as soon as practicable following any revisions. The Company makes its Pillar 3 disclosure via its company website.

 

The FCA framework consists of three ‘Pillars’:

 

Pillar 1 sets out the minimum capital amount that meets the Partnership’s credit, market and operational risk;

 

Pillar 2 requires the Partnership to assess whether its Pillar 1 capital is adequate to meet its risks and is subject to annual review by the FCA; and

 

Pillar 3 requires disclosure of specified information about the underlying risk management controls and capital position.

 

The rules in BIPRU 11 set out the provision for Pillar 3 disclosure. This document is designed to meet our Pillar 3 obligations.

 

We are permitted to omit required disclosures if we believe that the information is immaterial such that omission would be likely to change or influence the decision of a reader relying on that information.

 

In addition, we may omit required disclosures where we believe that the information is regarded as proprietary or confidential. In our view, proprietary information is that which, if it were shared, would undermine our competitive position. Information is considered to be confidential where there are obligations binding us to confidentiality with our customers, suppliers and counterparties.

 

We have made no omissions on the grounds that it is immaterial, proprietary or confidential

 

Scope and application of the requirements

 

Daedalus Partners LLP (“the Partnership”) is authorised and regulated by the Financial Conduct Authority and as such is subject to minimum regulatory capital requirements. The Partnership is categorised as a limited licence firm by the FCA for capital purposes. It is an investment management firm and as such has no trading book exposures.

 

The Partnership is not a financial holding company as defined by FCA regulations and so is not required to prepare consolidated reporting for prudential purposes.

 

Risk management

 

The Partnership is governed by its Members who determine its business strategy and risk appetite. They are also responsible for establishing and maintaining the Partnership’s governance arrangements along with designing and implementing a risk management framework that recognises the risks that the business faces.

 

The Members determine how the risk our business faces may be mitigated and assess on an ongoing basis the arrangements to manage those risks. The Members meet on a regular basis and discuss current projections for profitability, cash flow, regulatory capital management, and business planning and risk management.

 

The Members manage the Partnership’s risks business though a framework of policy and procedures having regard to relevant laws, standards, principles and rules (including FCA principles and rules) with the aim to operate a defined and transparent risk management framework. These policies and procedures are updated as required.

 

The Members have identified that business, operational, and credit risks are the main areas of risk to which the Partnership is exposed. Annually the Members formally review their risks, controls and other risk mitigation arrangements and assess their effectiveness. Where the Members identify material risks they consider the financial impact of these risks as part of our business planning and capital management and conclude whether the amount of regulatory capital is adequate.

 

Regulatory capital

 

The Partnership is a Limited Liability Partnership and its capital arrangements are established in its Partnership deed. Its capital contains only members’ capital contributions.

 

Our Partnership is small with a simple operational infrastructure. Its market risk is limited to foreign exchange risk on its accounts receivable in foreign currency, and credit risk from management and performance fees receivable from the funds under its management. The Partnership follows the standardised approach to market risk and the simplified standard approach to credit risk.

 

The Partnership is subject to the Fixed Overhead Requirement (‘FOR’).

 

The Partnership is a limited licence firm and as such its capital requirements are the greater of:

 

•     Its base capital requirement of €50,000; or

•     The sum of its market and credit risk requirements; or

•     Its Fixed Overhead Requirement

 

We have not identified credit risk exposure classes or the minimum capital requirements for market risk as we believe that they are immaterial in the context of our business.

 

The FOR is calculated as an amount that is equal to one quarter of the firm's relevant fixed expenditure calculated in accordance with GENPRU 2.1.54 R.

 

The most recent audited report and accounts shows a FOR of £58,974, which is greater than the base capital requirement of €50,000.

 

As market and credit risks are considered immaterial then we believe that our FOR of £58,974 adequately defines our capital requirements and is well within the level of capital held by the Partnership.

 

We consider this amount to be sufficient regulatory capital to support the business and have not identified any areas which give rise to a requirement to hold additional risk based capital.

 

Cookie Statement

 

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