1.1. Thriving Investments Limited (We, Us Our, Thriving Investments, The Company) is registered in England and Wales under number; 09571485 authorised and regulated by the Financial Conduct Authority under Firm Reference Number (FRN); 775636. The information on this website is directed at persons in the United Kingdom (“UK”) and not otherwise. The availability of any funds mentioned on this website in any jurisdiction other than the UK is subject to local restrictions and National Competent Authority (NCA) approval. Except as specifically set out below the funds mentioned on this website have not been registered or approved for distribution under the laws of any jurisdiction other than the UK.
1.2. If you are accessing this website from a jurisdiction other than the UK you are required to inform yourself of and observe any applicable local restrictions. If you choose to access the website and you do so from a country other than the UK you do so at your own risk and Thriving Investments will not be liable for any breach of local law or regulation that you commit as a result of doing so.
2.1. The information on this site is issued by The Company. It has expressed its own views and opinions on this website, and these may change without notice. This website does not constitute an offer or solicitation to sell units in any fund or investment service referred to herein or otherwise any product or service provided by Thriving Investments entities and must not be relied upon in connection with any investment decision.
2.2. The content of this Website is intended for institutional investors only unless specifically indicated otherwise. Any applications to invest in any fund referred to on this web site must only be made on the basis of the relevant offer document relating to the specific investment. Products or services mentioned on this site are subject to legal and regulatory requirements in applicable 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.
3. Accuracy of Information
3.1. This website may make reference to past performance, past performance is not a reliable indicator of future performance. Indications of past performance quoted herein will not necessarily be repeated in the future and may be before charges which will have the effect of reducing illustrated 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. No representation is being made that any investment will or is likely to achieve profits or losses similar to those achieved in the past or that significant losses will be avoided.
3.2. No investment is suitable in all cases and if you have any doubts as to an investment’s suitability then you should contact your financial advisor. All material herein was compiled from sources considered reliable. However, there is no expressed or implied warranty as to the accuracy or completeness of this material. Readers are solely responsible for how they use the information. Any mention herein of any risks may not be, and should not be considered to be a comprehensive disclosure or description of such risks.
3.3. The information contained on this site (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by The Company to be reliable, but is not guaranteed as to its accuracy or completeness. Such information is provided without obligation on the part of The Company and any associated companies and on the understanding that any person who acts upon it or changes his investment position in reliance on it does so entirely at their own risk. Information posted on this site is current only as at the date it is first published and may no longer be true or complete when viewed by you. All information contained on this site may be changed or amended without prior notice although The Company does not undertake to update this site regularly.
4. Limitation of Liability
4.1. No representation, warranty or undertaking is given as to the accuracy or completeness of the information contained on this site by The Company or any of its associated companies and no liability is accepted for the accuracy or completeness of such information. In no event will The Company or any of its associated companies be liable to any person for any direct, indirect, special or consequential damages arising out of any use of the information contained on this site, or on any other hyper-linked site, including, without limitation, any lost profits, business interruption, loss of programmes or data on your equipment, or otherwise, even if The Company is expressly advised of the possibility or likelihood of such damages. This does not exclude or restrict any duty or liability that The Company has to its customers under the regulatory system of the United Kingdom.
4.2. You should be aware that the Internet is not a completely reliable transmission medium. Neither The Company nor any of its associated companies accept any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to any direct, indirect or consequential damage, arising out of the use of the products or services referred to herein except where that liability may not be excluded or limited by law. This does not exclude or restrict any duty or liability that The Company has to its customers under the regulatory system in the United Kingdom.
4.3. This site may link to third party websites or may have information prepared or provided by third parties which may not have been verified by us. Except where prohibited by law, neither the Company nor any of its associated companies makes any representation as to the accuracy or completeness of such websites or information, any use made of such websites or information is at your own risk. Neither The Company nor any of its associated companies accepts any liability arising out of the information contained on any linked website or information on this site provided by a third party. The use of such sites and information is at your own risk. Any Third Party websites will have their own terms and privacy policies you should read them carefully before using those sites. The presence of any advert on this Website is not an endorsement of goods, services business or website advertised.
5. Material Interests
5.1. The Company, its associated companies and their directors, officers and/or employees may have holdings in the funds referred to on this site and may otherwise be interested in transactions in those funds.
6.1. Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by The Company, its licensors or relevant third party content providers. A single copy of webpages published on this website may be made for personal and/or non-commercial reference, any copy of such webpages shall retain all copyright and other proprietary notices contained therein. Such information may not otherwise be reproduced, distributed or transmitted to any other person or incorporated in any way into another database, document or other materials. Nothing on this site should be considered as granting any licence or right under any trademark of The Company or any third party. If you wish to link to content on this site, you are required to request permission from the site administrator by contacting [please inset website administrator contact details]
7.2. Company is part of a Group of different legal entities, this privacy notice is issued on behalf of the Thriving Investments Limited. If another Group entity is responsible for processing your data. We will let you know which entity will be the controller for your data when you avail of a service with us. Thriving Investments Limited is the controller and responsible for this website.
7.3. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the following details;
Full name of legal entity: Thriving Investments Limited
Name DPO: FAO Data Protection Officer
Postal address: 305 Gray's Inn Road, London, WC1X 8QR.
7.4. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data; may include first name, maiden name, last name, username or similar identifier, title and gender.
Contact Data; may include billing address, delivery address, email address and telephone numbers.
Technical Data; includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data; includes your username and password, your interests, preferences and any correspondence.
Usage Data; includes information about how you use our website and which products and services you prefer.
Information may be deleted from our records on request by emailing us at firstname.lastname@example.org.
7.5. Any information provided may be passed on to official third parties in order to comply with legal requirements, the legal process, and/or to obtain legal advice. Information may also be passed on to third parties to prevent and/or to detect fraud, reduce credit risk and/or protect the copyright and proprietary interests of The Company.
7.7. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
7.8. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
8. Data protection
8.1. For the purposes of the General Data Protection Regulation (GDPR) the Company is a “Data Controller” as it relates any “Personal Data”. When you visit this website and in the course of our providing services to you, we may collect Personal Data about you when you are asked to provide such data (e.g. name, e-mail address and mailing address) or when you e-mail, phone, or otherwise contact us.
8.2. Personal Data collected via this website or otherwise may be processed by us or an appropriate third party for the purpose of website administration, responding to queries, updating our records and databases, improving the personalisation, maintaining contact data about you or your company and/or for regulatory purposes. We will not share your personal data with others for marketing purposes.
8.3. We may appoint third parties (a processor) to host, maintain, manage, or to provide other services in relation to the website as a result of which your personal data may be accessed and used by these as necessary to fulfil their hosting, maintenance, and other related functions. GDPR gives you the right to control what personal information we hold about you and encrypt. A request for personal information can be made any form, including through email, phone call or in writing. We will provide you with a Subject Access Request (SAR) Form or we may request that you provide us with sufficient information so we may provide you with personal information.
8.4. You may be able to update some of the data we hold about you or your company yourself. If you are acting on behalf of a third party or supply us with information regarding a third party (such as your employer or a client company), you undertake that you are an authorised representative or agent of such third party and that you have obtained all necessary consents from such third party to the collection, processing, use and disclosure by us of their personal data.
8.5. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see Section 9 for further details].
8.6. Data may be disclosed to staff within The Company specifically to process your enquiries or act in accordance with regulation or otherwise to administer the website, as well as to those staff involved in the provision of services and products which may be of interest to you.
8.7. Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA.
8.8. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
8.9. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
9.1. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
9.2. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as an investor
Performance of a contract with you
To manage our relationship with you which will include:
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website experience.
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
10.1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
10.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
“Session based” cookie: This is essential for parts of the website to operate and has already been set. It is used to maintain the state of a user’s actions so as not to constantly request the same information from them within a ‘session’.
“Permanent” cookie. This is a permanent cookie which can remember that you have accepted our terms and conditions and/or the use of so you are not asked to log in again for future visits. The website requires that you explicitly give your consent before this cookie is set.
“Analytics” cookie. This, in combination with the session cookie, is used to collect information about how you use our site, such as where you have come to the site from and which website pages you have visited. We use the information to help us improve the website.
11.2 The website uses cookie notification pop-up to record your cookie settings. This pop-up uses a cookie and is required for the website to function as intended.
11.3. You can enable or disable cookies by modifying the settings in your browser; however, you may not be able to use all of the features of the website if cookies are disabled. You can find out how to disable/enable cookies at: www.allaboutcookies.org.
11.4. The Company uses reasonable physical, electronic, and procedural measures to safeguard information against loss, theft, unauthorised use, disclosure, or modification. This website when delivered over the internet may however flow over networks without appropriate security measures and as result it is possible it may be accessed and used by unauthorised persons.
11.6. If you have any questions in relation to the information concerning privacy and personal data above, if your personal data changes or if you no longer wish to receive our service, please let us know and we will correct, update or remove your details. This can be done by contacting email@example.com.