Regulatory Framework And Disclaimer
Henley Investment Management Ltd is authorised and regulated by the Financial Conduct Authority (FRN 943587). Registered in England and Wales (company number 06246854) – registered office: First Floor, 50 Grosvenor Hill, London W1K 3QT. Other companies in the Henley group are not authorised or regulated by the FCA. The information on this website about investments is derived from sources considered reliable but no warranty, expressed or implied, by Henley, its partners or employees is given as to its accuracy or completeness. No reliance should be placed on this information in any decision to acquire or dispose of shares in any investment referred to herein. This website provides information about Henley’s business and corporate activities. Nothing on it is an offer, invitation or inducement to invest, or investment advice. Information about specific funds is available only to persons who have completed our investor categorisation process. Where links have been provided to other websites, this has been done solely for our users’ convenience, without giving any express or implied guarantee, endorsement or recommendation by Henley. Henley has no responsibility for the content of such websites and cannot accept any liability in this respect. Use of these links implies acceptance of this condition. Whilst we seek to keep this website up-to-date, the information displayed is subject to change without notice.
NO PRIVATE CUSTOMERS.
Data Privacy Policy
Henley (including other companies within our group) (“we” or “us”) is committed to protecting and respecting your privacy.
We collect, store and use information in accordance with the General Data Protection Regulation (the “GDPR”) and all other relevant legislation and regulations.
This policy sets out details of how we process data in relation to you. Some of the data we process will be personal data, which relates to and identifies you. Other data will be anonymous data. Please read this policy carefully to understand how we process both sorts of data.
For the purposes of the GDPR, we are the data controller of any personal data we process about you.
All changes to this policy will be posted here. You should visit this page regularly to stay up to date.
Information We Hold About You
We may collect and process the following data about you:
Information you provide when you fill in forms on our website at www.henleyinvestments.com/investor-registration (“our site”), including information you provide when you register as a user, details you provide during the negotiations of a product or service(through call, email, post or on our website); copies of correspondence you send to us (including by post, email or through our site); your responses to surveys or questionnaires we ask you to complete; details of any transactions you carry out on or through our site; details of your visits to our site (including traffic data and data in relation to the resources you access); and information that we collect about your computer, including its IP address.
Lawful Basis
The majority of our processing of personal data is on the basis that it is necessary for the purposes of our legitimate interests. When you provide your personal details to us we use your information for our legitimate business interests to carry out our work and provide you with the latest information about our investment opportunities. Before doing this we have carried out a balancing test in order to carefully consider and balance any potential impact on you and your rights.
Where processing does not fall under legitimate interests we will store your data with the consent provided by you. Where you have actively given consent to us to process your information we will process the information for as long as necessary or until you withdraw your consent with us to process your data.
Where you have entered into an investment with us and we need to manage payments, fees and charges for you we will process this information under contractual basis and under the necessary legal obligation we are held to.
How We Use Your Information
We use information held about you to:
Ensure the content of our site is presented in the best way for you and your computer; provide you with information about opportunities or services that you request or which we consider may be of interest to you (subject to the following section of this policy); perform our obligations under contracts between you and us; allow you to use the various features of our site; protect your account and limiting access to your account; and allow third parties to contact you about goods or services you might be interested in (subject to the following section of this policy).
Information we send you:
Where you have registered with us and we have confirmed you fall within a category of investor to whom such material may lawfully be sent, we may send you information about our investment opportunities. You can opt out at any time.
You can opt out by directly or contacting subscriptions@henleyinvestments.com
Statistical Information
We may aggregate information about you with information about other users of our site to create statistical data about users. This is anonymised statistical data that does not identify you and we may distribute any such aggregate information to third parties we work with.
Sharing Your Personal Information
We will only share personal information that we hold about you to third parties:
Who are companies within our group of companies; who provide services to us in connection with our site; to whom we sell or intend to sell any of our business or assets; or if we are legally obliged to disclose the information.
Data Retention
We will only retain personal data that we hold on you for as long as it is necessary for us to process the information. This length of time will depend on the purposes we hold the data for.
To determine the length of processing we consider the nature of the data, the sensitivity of the data, the potential risk/impact to you as the data subject and the purposes for which we are processing your data.
Please note that we are required to retain some information for up to seven years in order to comply with legal and regulatory requirements.
Data Security
We have in place appropriate security measures on all systems where your data is held to prevent your data from being, accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your data only to those employees and appropriate third parties who have a legitimate business need to know.
We have in place appropriate procedures to deal with any data breaches to our systems and will notify you and all applicable regulators of a breach where we are legally required to do so.
Your Data Rights
1) Right to information
This right obliges us to inform you about what personal data we process and the rationale for such processing.
2) Right to access
This right entitles you to confirmation as to whether or not we are processing your personal data, and, where that is the case, with access to the personal data, as well as further specified information about the processing (such as the purposes for it, to whom the data have been or will be disclosed, and the right to lodge a complaint with the Information Commissioner’s Office).
3) Right to rectification
This right provides you with the ability to ask for modifications to your personal data in case you believe that this personal data is not up to date or accurate.
4) Right to object
This right provides you with the ability to object to the processing of their personal data. Henley will stop processing personal data we hold on you, unless there are overriding reasons which mean it is necessary that we process this data.
5) Right to be forgotten
Also known as right to erasure, this right provides you with the ability to ask for the deletion of your data. This is not an absolute right, and there may be overriding reasons which mean that it is necessary to continue to hold the data.
6) Right to data portability
This right provides you with the ability to ask for transfer of personal data you have provided to us. As part of such request, you may ask for your personal data to be provided back to you or transferred to another controller. When doing so, Henley will provide your personal data in a machine-readable electronic format.
Cookies
Cookies are small files placed on your device when you visit our site. We use cookies to recognise you and your preferences, improve the performance of our site and to create statistical data.
Cookies generally fall into one of the following categories:
Strictly necessary cookies which are cookies that are essential to allow you to use a website and its features; performance cookies which collect information about how visitors use a website to create aggregated, anonymous information that does not identify the visitor; functionality cookies which allow the website to remember you and provide a more personalised service; and targeting or advertising cookies which are used to deliver adverts relevant to you.
Our site uses the following types of cookies: strictly necessary cookies, performance cookies and functionality cookies.
Our Investor Portal uses Reporting Cookies and Functional Cookies.
Some of our cookies remain on your device between your browsing sessions.
You can disable our cookies by changing the settings on your browser but doing so might mean you are unable to use certain features of our site.
Where We Store Your Data
We store your data on our CRM system Salesforce, we apply all appropriate security measure to this system to ensure your data is protected.
Data we collect from you may be transferred to and stored in destinations outside the European Economic Area (“EEA”) and may be processed by staff operating outside the EEA. Non-EEA countries may not offer the same level of data protection as the United Kingdom. However we will take reasonable steps to ensure that any of your data transferred outside the EEA will be treated securely and in accordance with this privacy policy. Salesforce’s data processing addendum incorporates binding corporate rules, the EU-U.S. Privacy Shield, and the European Commission’s standard contractual clauses. The processing addendum means that Salesforce has provided adequate safeguards.
We will take all steps reasonably necessary to keep your data secure. You should be aware that transmission of information via the internet is not entirely secure and we cannot guarantee the security of any data you transmit to our site via the internet.
Contacting Us
If you have any questions or comments on this policy, you can contact us at info@henleyim.com
If you would like to opt out of any or all processing, you can contact us at subscriptions@henleyim.com
Turnstile Privacy Addendum
Last updated: JUNE 18, 2025
1. Introduction
Turnstile, developed by Cloudflare, Inc. (Cloudflare), is a pro-privacy website security tool that processes minimal Signals (as defined below) solely to protect web properties against malicious activity by distinguishing human users from bots and blocking bot traffic.
Cloudflare does not control whether a website chooses to use Turnstile; instead, we make Turnstile available to any website that is looking for a way to detect and block bot traffic.
2. Scope of this addendum
This Turnstile Addendum is supplemental to Cloudflare’s main Privacy Policy. It provides additional information specific to your use and interaction with Turnstile. This Addendum also applies to the personal data processed using Cloudflare’s Challenge Platform, and any reference to “Turnstile” in this addendum applies equally to the Challenge Platform.
The Cloudflare Privacy Policy continues to apply to your use and interaction with Turnstile, except where this Turnstile Addendum provides more specific information. In those cases, the more specific information will apply instead.
3. Information we collect
Cloudflare Turnstile processes a variety of client-side signals (“Signals”) such as client IP address, TLS Fingerprint, User-Agent Header and Sitekey and associated origin. Cloudflare does not have the ability to directly identify any individuals from any of the Signals Turnstile collects, including IP addresses.
4. How we use information we collect
(i) Bot detection and blocking
Turnstile is a tool to protect web properties by distinguishing human users from bots and blocking any detected bot traffic that could otherwise harm the safety and security of that property.
It does so by evaluating the Signals listed above specific to both the website visitor and the website visited. The purpose of collecting these Signals is not to identify, profile or target any individuals but solely to detect and block bots. The Signals collected by Turnstile are strictly necessary for this purpose (i.e. detecting and blocking bots to enable visitors to enjoy a safe and secure experience when visiting websites that have implemented Turnstile).
Cloudflare is a data processor of Signals that we process to provide the Turnstile service to our customers, that is, securing our customers’ websites. This means that we process Signals for this purpose on behalf of, and pursuant to instructions issued by, our website operator customers (who are the data controllers of any data processed for this purpose). If you have questions, or wish to exercise any data protection rights, regarding Cloudflare’s processing of Turnstile data to provide our service, please contact the relevant website operator.
(ii) Improving Turnstile’s bot detection capabilities
Cloudflare also processes the Signals described in this Privacy Notice to improve Turnstile. This is necessary to refine and improve our bot detection algorithms in order to respond to evolving bot threats, and to maintain the security of the web properties that website visitors choose to visit.
Cloudflare is a data controller of Signals that we process to improve Turnstile’s bot detection capabilities. This Turnstile Privacy Notice (in conjunction with Cloudflare’s main Privacy Policy) governs our processing of Signals for this purpose.
5. Notice to EU & UK residents
To the extent that the data described in the Turnstile Privacy Notice qualifies as personal data, then:
When processing this personal data as a processor to protect our customers’ websites, our customers, as controllers, determine the lawful basis of this processing, and we process this data under their instruction and on their behalf; and
When processing this personal data as a controller, we rely on our legitimate interests in improving the effectiveness of Turnstile’s bot detection capabilities to process this Turnstile data.
6. Cookies
The Signals collected by Turnstile are strictly necessary for the purpose of detecting and blocking bots to enable visitors to enjoy a safe and secure experience when visiting websites that have implemented Turnstile.
For more information about the cookies used by Cloudflare, please check our Cookie Policy and our Turnstile Developer Docs.
Contact for privacy concerns
If you have questions or concerns about this Turnstile Privacy Notice or your personal data processed through Turnstile, please contact Cloudflare’s Data Protection Officer at dpo@cloudflare.com.