Privacy Policy

Privacy Policy
M & L Capital Management Ltd (MLCM) recognizes the importance of protecting your personal and financial information. This Policy including the Cookies Policy is designed to help you understand the information collection practices at MLCM. Contact information is included in this Policy and on the Website.

MLCM are committed to:
(a) protecting the personal data you provide to us;
(b) telling you how we use the information we gather about you; and
(c) ensuring that you know the circumstances under which we may disclose your personal data.

This Policy covers the privacy and data protection policies on the MLCM Website, and should be read in conjunction with any other applicable policies, terms, and conditions in place between you and MLCM.

Contact Us
If you have any questions about this Policy, or our privacy related practices, please contact us:

• through your usual contact.
• by email at
• by phone: +44 (0) 2075845733
• by post: Data Protection Officer, M & L Capital Management Ltd, 12a Princes Gate Mews, London SW7 2PS.

Data Protection and Privacy

Personal Data:
The personal data and other information you may submit to our Website is used to service your account, to improve our services to you and/or to provide you with information on MLCM products and services. The types of personal data that may be collected at our Websites include: name, address, email address and telephone number. We will not sell, share or rent your personal data to others in contravention of this Privacy Policy.

Your Rights
You may contact us to:

• request that we amend, rectify, delete or update the personal data we may hold about you;
• where possible (e.g., in relation to marketing or investment information) amend or update your choices around processing;
• request a copy of personal data held by us.

Where you would like to receive a copy of all personal data held, such request should be in writing (email or post), addressed to our Data Protection Officer at our London Office and should contain as much information as possible to facilitate our dealing with this request.

Removal of Personal Information Consent:
If you would like to have your personal information removed from the MLCM distribution list for factsheets, performance and investment updates please contact us in writing either via e-mail or by post to confirm the removal of your consent to MLCM holding information on you. This does not affect your rights as an investor in funds that MLCM portfolio manage.

Personal data consent removal, contact us:

• by email at
• by post: Data Protection Officer, M & L Capital Management Limited, 12a Princes Gate Mews, London SW7 2PS.

Information from telephone and email communications with MLCM:
If you communicate with MLCM by telephone or e-mail, MLCM may keep a record of that communication.

Aggregate Information:
We may record certain usage information, such as the number and frequency of visitors to our Websites. MLCM will not record individual data related to persons viewing the MLCM website for information purposes, such as websites that you access immediately before and after your visit to the MLCM Website, the Internet browser you are using and your IP address. MLCM may use data on an aggregate basis through, such as visitors from a country based on the IP address for example.

Compliance with Laws
personal data that you provide will be held and processed by us in accordance with applicable data protection law.
We will not provide any personal data to any other persons, except if we are required to make disclosures by any law, any government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding.

E-mail and Marketing
MLCM does not sell its customers’ personal data, nor will MLCM provide your personal data to third parties for their marketing purposes without your consent. MLCM will not send you e-mail messages without first receiving your permission, unless it relates to servicing your account or unless you have consented to receiving electronic delivery of fund documents as part of our investment service. It is our policy to include instructions for unsubscribing from these permission-based programs.  Please see the above section “Removal of Personal Information Consent” for further information on how to remove your personal data from MLCM.

Business Transfers
If the business, stock or assets of MLCM are acquired or merged with another business entity, we will share all or some of your information with this entity to continue to provide our agreed investment service to you. You will receive notice of such an event and the new business entity will inform you of any changes to the practices in this Privacy Policy. If the new business entity wishes to make additional use of your information, you may decline such use at such time.

Disclosure to Third Parties
The personal data you provide to us will only be disclosed to third parties if we have your permission, or as set out in this Privacy Policy. We may disclose details about the general use of our Websites to third parties – for example, to demonstrate patterns of use to business partners. Information we pass on for this purpose will not include any personal data by which you may be identified. We endeavour to prevent unauthorised disclosures of your personal data by third parties but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the information was passed to them with your authority or with the authority of anyone other than us or our group companies.

Third Party Websites
MLCM disclaims responsibility for the privacy policies and customer information practices of third party internet websites hyperlinked from our Website or this Privacy Policy.

MLCM recommend that you do not send us any personal data via non-secure methods of correspondence, including via public electronic communication channels, such as Internet e-mail, which are generally not secure.

Cookies Policy

What are cookies?
Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties which receive data obtained from that website.
When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalised web experience.

Why we may use cookies?
Cookies help us to provide customised services and information. We use cookies on the Website to tell us, in general terms, how and when pages in our Website are visited, what our users’ technology preferences are – such as what type of video player they use – and whether our Website is functioning properly. Depending on their purpose, some cookies will only operate for the length of a single browsing session, whilst others have a longer life span to ensure that they fulfil their longer-term purposes (as explained in more detail below). Please note that, however long the cookies’ active life may be, you can delete cookies (and therefore stop any further data collection by them) as further described below.

In broad terms, we may use cookies on our Websites for the following purposes:

Analytical purposes: Analytical cookies allow us to recognise, measure and track visitors to our Website and compile a record of this usage information. This helps us to improve and develop the way our Website work, for example, by determining whether site visitors can find information easily, or by identifying the aspects of websites that are of the most interest to them.

• Usage preferences: Some of the cookies on our Website are activated when visitors to our sites make a choice about their usage of the site. Our Website then stores the settings preferences of the user concerned. This allows us to tailor aspects of our sites to the individual user.

Terms and conditions: We use cookies on our Website to record when a site visitor has seen a policy, or provided consent, such as consent to the terms and conditions on our Website. This helps to improve the user’s experience of the site – for example, it avoids the user from repeatedly being asked to consent to the same terms.

Please note that third parties may use cookies. The kind of cookies and the consequent data processing carried out by such third parties are regulated by their privacy policy. Please see below.

Your cookie preferences
Cookies are necessary in order for you to be able to make full use of the MLCM Website. In addition, cookies may help MLCM to provide you with personalised features on the Website. If you chose to disable cookies, some of the MLCM Website’s functionality might be impaired.

Third party cookies
When you visit the MLCM Website, you may receive cookies that are set by third parties. These may include cookies for example set by Google, Twitter and/or Instagram. These cookies are used for the purposes described in the “Why we may use cookies?” section of this policy. We do not control the setting of these third party cookies, so we suggest you might wish to check the relevant third party websites for more information about their specific use of cookies and how to manage them.

Amending cookie preferences
If you wish to remove cookies set by the MLCM Website from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our sites will impair the functionality of the sites.

Managing Cookies in General
The website includes general information in relation to cookies and instructions for managing cookies on many browsers, or you may wish to consult the vendor documentation for your specific software or browser.

‘M&L Capital Management Limited (“MLCM”) is authorised and regulated by the Financial Conduct Authority under firm reference number 672181. MLCM is registered in England & Wales under number 04089418, with its registered address at 12a Princes Gate Mews, London, SW7 2PS.


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