DISCLAIMER

Please read this page before proceeding

 

www.aaro.capital (“our site”) is a website operated by Aaro Capital Limited ("we" and/or "us"). We are registered in England and Wales registration number 11419585 and have our registered office at 5th Floor 14-16 Dowgate Hill, London, United Kingdom, EC4R 2SU. Our contact e-mail address is info@aaro.capital. We are not authorised and regulated by the Malta Financial Services Authority (“MFSA”).

 

The material contained on our site is directed at Professional Clients (as defined in Annex II of the MiFID II Directive (2014/65/EU)) situated in either the United Kingdom, Germany, Switzerland or Singapore. If you are unsure of whether you are a Professional Client you MUST NOT ACCESS OUR SITE. The material contained on our site is being provided for informational purposes only and does not constitute investment advice and is not an offer or solicitation for investment.

 

Our site contains information about cryptoassets. Cryptoassets are at a developmental stage and anyone thinking about investing into these types of assets should be cautious and take appropriate advice in relation to the risks associated with these assets including (without limitation) volatility, total capital loss, and lack of regulation over certain market participants.

 

Any information in relation to the Aaro Distributed Ledger Technology Multifund (“Aaro DLT Multifund”, "Multifund, "Fund") has been approved by the fund’s Investment Manager, FMG (Malta) Limited https://www.fmgfunds.com/  (“Investment Manager”), a firm authorised and regulated by the MFSA with C 44040. Aaro is not related to nor has any control or management function over the Aaro DLT Multifund. Ankush Jain and Peter Habermacher are appointed by AK Jensen Limited, the Sub-Investment Manager-, a firm authorised and regulated by the UK Financial Conduct Authority -with FRN 439744, to perform the day to day portfolio management of the Aaro DLT Multifund under the authority, and on behalf, of the Sub-Investment Manager.

 

The fund managers have not offered or placed and will not offer or place or sell, directly or indirectly, units/shares to retail investors in Germany, i.e. investors which do not qualify as semiprofessional or professional investors as defined in sec. 1 (19) no. 32 and 33 German Investment Code (Kapitalanlagegesetzbuch – KAGB) and have not distributed and will not distribute or cause to be distributed to such retail investors in Germany, this website or any other offering material relating to the units/shares of the Aaro DLT Multifund. Such offers, placements, sales and distributions have been and will be made in Germany only to semi-professional and professional clients within the meaning of sec. 1 (19) no. 32 [and 33] German Investment Code (Kapitalanlagegesetzbuch – KAGB).

 

The representative in Switzerland is ARM Swiss Representatives SA, Route de Cité-Ouest 2, 1196 Gland, Switzerland. The paying agent in Switzerland is Helvetische Bank AG. The Prospectus, the Articles of Association and annual financial statements can be obtained free of charge from the representative in Switzerland. The place of performance and jurisdiction is the registered office of the representative in Switzerland with regards to the Shares distributed in and from Switzerland.

 

The distribution of Investor Shares in Switzerland will be exclusively made to, and directed at, qualified investors („Qualified Investors“), as defined in the Swiss Collective Investment Schemes Act of 23 June 2006, as amended („CISA“) and its implementing ordinance (the „Swiss Distribution Rules“). Accordingly, the Fund has not been and will not be registered with the Swiss Financial Market Supervisory Authority (FINMA).

 

The Fund which is the subject of this Offering Supplement and the Offering Memorandum is not authorised or recognised by the Monetary Authority of Singapore (MAS) under the Securities and Futures Act  (Chapter 289 of Singapore), as modified or amended from time to time (SFA) and units in the Fund are not allowed to be offered to the retail public in Singapore. However, the Fund has been notified to the MAS as a restricted scheme for the purposes  of  Section  305  of  the  SFA.  This  Offering  Supplement  and  the  Offering Memorandum are not a prospectus as defined in the Securities and Futures Act (Chapter 289 of Singapore) (SFA). Accordingly, statutory liability under the SFA in relation to the content of prospectuses would not apply. You should consider carefully whether the investment is suitable for you. This Offering Supplement and the Offering Memorandum have  not  been  registered  as  a  prospectus  with  the  MAS.  Accordingly,  this  Offering Supplement  and  the  Offering  Memorandum  and  any  other  document  or  material  in connection with the offer or sale, or invitation for subscription or purchase, of Investor Shares may not be circulated or distributed, nor may Investor Shares be offered or sold, or be made the subject of an invitation for subscription or purchase, whether directly or indirectly, to persons in Singapore other than (i) to an institutional investor (as defined in Section 4A of the SFA) pursuant to Section 304 of the SFA, (ii) to a relevant person including accredited investor (as defined in Section 305(5) of the SFA) pursuant to Section 305(1), or any person pursuant to Section 305(2), and in accordance with the conditions specified in Section 305 of the SFA, or (iii) otherwise pursuant to, and in accordance with the conditions of, any other applicable provision of the SFA.  Where Investor Shares are subscribed or purchased under Section 305 by a relevant person which is:  (a) a corporation (which is not an accredited investor (as defined in Section 4A of the SFA)) the sole business of which is to hold investments and the entire share capital of which is owned by one or more individuals, each of whom is an accredited investor; or (b) a trust (where the trustee is  not  an  accredited  investor)  whose  sole  purpose  is  to  hold  investments  and  each beneficiary of the trust is an individual who is an accredited investor,  securities of that corporation or the beneficiaries’ rights and interest (howsoever described) in that trust shall not be transferred within six months after that corporation or that trust has acquired Investor Shares pursuant to an offer made under Section 305 except:  (1) to an institutional investor or to a relevant person or to any person arising from an offer referred to in Section 305(2) or Section 305A(3)(i)(B) of the SFA;  (2) where no consideration is or will be given for the transfer; or  (3) where the transfer is by operation of law; or (4) pursuant to 304A(2) or 305A(5) of the SFA or Regulation 36 or 36A of the Securities and Futures (Offers of Investments)(Collective Investment Schemes) Regulations 2005.

 

All persons accessing our site do so on an unsolicited basis and on their own initiative. The information contained on our site may be restricted in certain jurisdictions. It is the responsibility of persons accessing our site to inform themselves of, and act in accordance with, the legal and regulatory requirements in their jurisdiction of citizenship, residence or domicile. We and our partners disclaim all responsibility if persons access our site, or the information on it, contrary to such legal and regulatory requirements. 

 

Any figures contained on our site, unless explicitly stated otherwise, refer to the past. Past performance is not a reliable indicator of future results. While we have used reasonable efforts to ensure that the information on this site is accurate, errors and omissions may exist and the contents of this site are subject to change without notice.


By entering out site you are confirming that you are a Professional Client, falling into one of the categories below:
 

1. One of the following entities required to be authorised or regulated to operate in the financial markets:

  1. a credit institution;
  2. an investment firm;
  3. any other authorised or regulated financial institution;
  4. an insurance company;
  5. a collective investment scheme or the management company of such a scheme;
  6. a pension fund or the management company of a pension fund;
  7. a commodity or commodity derivatives dealer;
  8. a local;
  9. any other institutional investor;

2. A large undertaking meeting two of the following size requirements on a company basis:

  1. balance sheet total of EUR 20,000,000;
  2. net turnover of EUR 40,000,000;
  3. own funds of EUR 2,000,000

3. You wish to elect to be treated as a Professional Client and you satisfy at least two of the following requirements*:

  1. you have carried out transactions, in significant size, in relation to investment funds, at an average frequency of 10 per quarter over the previous four quarters,
  2. the size of your financial instrument portfolio, defined as including cash deposits and financial instruments, exceeds EUR 500 000,
  3. you either work or have worked in the financial sector for at least one year in a professional position, which requires knowledge of the investments into investment funds.

* A client electing to be treated as a professional client may lose various protections afforded to retail clients and may not have access to the Financial Ombudsman Scheme.                                                                             

This website uses cookies. By continuing to use this website you are giving consent to cookies being used and also agree to the Website's Terms of Use and Privacy Policy. For more information, please see our Cookie Policy, Terms of Use and Privacy Policy.

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Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognise 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 recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use and the purposes for which we use them in below:

  • ASPXFORMSAUTH - This is a session cookie that is utilised for post login. The cookie is generated at the time of log in for ensuring the site user remains logged in as they browse the site pages as well auditing activity and security controls. The cookie is deleted as the user closes the browser, when the user explicitly logs out, or visits any page after 20 minutes of inactivity and are logged out automatically, whichever is first.
  • ASP.NET_SessionId - This is a session cookie to maintain the state of the session for the user while they are browsing the site from page to page. This cookie is also deleted once the browser session is closed entirely.
  • disc_accepted - This cookie is created when a user accepts the popup disclaimer on every page and indicates such for subsequent page visits. The cookie expires at the end of the browser session.
  • returnUrl - This is a session cookie that is used for post-login. This cookie is generated during the first step of log in (before showing disclaimer or forced password update) and is removed when the user closes the browser, presses agree (if no forced password) or presses “OK” after updating their password/security question.  

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

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PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THIS SITE

These terms tell you the rules for using our website www.aaro.capital (our site).

 

Who we are and how to contact us

www.aaro.capital is a site operated by Aaro Capital Limited ("We" or “Aaro”). We are a company registered in England and Wales with company number 11419585 and whose registered office is at 5th Floor 14-16 Dowgate Hill, London, England, EC4R 2SU.

To contact us, please email info@aaro.capital.

 

By using our site you accept these terms

By using our site, you confirm that you accept these terms of use and that you agree to comply with them.

If you do not agree to these terms, you must not use our site.

 

There are other terms that may apply to you

These terms of use refer to the following additional terms, which also apply to your use of our site:

  • Our Privacy Policy.

 

We may make changes to these terms

We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time.

 

We may make changes to our site

We may update and change our site from time to time.

 

We may suspend or withdraw our site

Our site is made available free of charge.

We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.

You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.

 

How you may use material on our site

We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it.  Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from our site for your personal use and you may draw the attention of others within your organisation to content posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged.

You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

 

Do not rely on information on this site

The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site.

Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up to date.

 

We are not responsible for websites we link to

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.

We have no control over the contents of those sites or resources.

 

Our responsibility for loss or damage suffered by you

  • We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.
  • We exclude all implied conditions, warranties, representations or other terms that may apply to our site or any content on it.
  • We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:
  • use of, or inability to use, our site; or
  • use of or reliance on any content displayed on our site.
  • In particular, we will not be liable for:
  • loss of profits, sales, business, or revenue;
  • business interruption;
  • loss of anticipated savings;
  • loss of business opportunity, goodwill or reputation; or
  • any indirect or consequential loss or damage.

 

How we may use your personal information

If we collect any personal information from you, we will only use your personal information as set out in our Privacy Policy.

 

We are not responsible for viruses and you must not introduce them

We do not guarantee that our site will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer programmes and platform to access our site. You should use your own virus protection software.

You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

 

Rules about linking to our site

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.

You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

You must not establish a link to our site in any website that is not owned by you.

Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page.

We reserve the right to withdraw linking permission without notice.

If you wish to link to or make any use of content on our site other than that set out above, please contact info@aaro.capital.    

 

Which country's laws apply to any disputes?

These terms of use, their subject matter and their formation, are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

If you are a business, these terms of use, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

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INTRODUCTION

Welcome to the Aaro Capital Limited (Aaro) privacy notice.

Aaro respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how AARO collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

AARO is the controller and responsible for your personal data (collectively referred to as “AARO”, "we", "us" or "our" in this privacy notice).

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes name or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes address, email address, telephone numbers and place and type of business.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
  • Automated technologies or interactions. 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.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties such as Google Analytics.

 

4. How we use your personal data

We will only use your personal data when the law allows us to. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity and Contact Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Purposes for which we will use your personal data

We have set out below 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.

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 below.

  • To register your interest as a new customer
    • Type of data: Identity, Contact
    • Lawful basis for processing including basis of legitimate interest: Information leading to creation and performance of a contract with you
  • To manage our relationship with you which will include: (a) Notifying you about any changes to our terms or privacy policy; (b) Asking you to leave a review or take a survey
    • Type of data: Identity, Contact
    • Lawful basis for processing including basis of legitimate interest: (a) Information leading to creation and performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

5. International transfers

We may transfer your personal data outside the European Economic Area (EEA) but only where we have established adequate security and data protection measures in accordance with the Data Protection Act 2018.

 

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

7. Data retention

How long will you use my personal data for?

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.

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.

 

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the following rights:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising your rights:

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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