Please note that the terms set out below may be altered or updated. You should read the terms in full each time prior to accepting them.
The following pages provide information about Sulla Tempus 1 SP, a segregated portfolio of Sulla Investments SPC (“the Fund”) which is an alternative investment fund and accordingly the distribution of such information is restricted by law. To the extent anything contained in this website is deemed to be a financial promotion in the UK, it has been approved by Sulla Management Limited, which is authorised and regulated by the FCA and it is only intended for persons who are eligible under COBS 4.12.4R of the FCA Rules which includes non-retail clients, high net worth investors and sophisticated investors. By accepting these terms you confirm that you fall into one of those categories in COBS 4.12.4R.
The content of this web site and investment in the Fund is likely to be restricted in other jurisdictions as well. In particular neither the Fund nor its investment adviser, Sulla Investments Limited (“Sulla”) have been registered with any US regulatory authority and the Fund and/or Sulla may need to take additional steps before allowing US Persons to invest in the Fund. Furthermore the Fund does not have any marketing passports under AIFMD to any EEA jurisdiction outside the UK and accordingly any investment by European investors could only be accepted at the initiative of the investor.
Potential Investors should be aware that any investment in the Fund can only be made on the basis of the Confidential Private Placement Memorandum (“PPM”) which is available from Sulla. Prospective investors should carefully read the PPM and in particular the risk warnings contained therein before considering an investment in the Fund. The information provided on this website shall not form the basis of any contract, commitment or investment decision nor does it constitute investment advice.
Please remember that past performance is not necessarily a guide to future returns and that to the extent that past performance has been simulated it may not be a fair representation of the actual performance that would have been achieved by the strategy.
The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy.
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website comply's to all UK national laws and requirements for user privacy.
Cookies are small files saved to the user's computer’s hard drive that track, save and store information about the user's interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
Other cookies may be stored to your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
Contact & Communication
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Act 1998. Every effort has been made to ensure a safe and secure form to email submission process but advise users using such form to email processes that they do so at their own risk.
This website and its owners use any information submitted to provide you with further information about the products / services they offer or to assist you in answering any questions or queries you may have submitted. This includes using your details to subscribe you to any email newsletter program the website operates but only if this was made clear to you and your express permission was granted when submitting any form to email process. Or whereby you the consumer have previously purchased from or enquired about purchasing from the company a product or service that the email newsletter relates to. This is by no means an entire list of your user rights in regard to receiving email marketing material. Your details are not passed on to any third parties.
Email Newsletter (‘Services’)
This website operates an email newsletter program, used to inform subscribers about products and services supplied by this website. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.
Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003. All personal details relating to subscriptions are held securely and in accordance with the Data Protection Act 1998. No personal details are passed on to third parties nor shared with companies / people outside of the company that operates this website. Under the Data Protection Act 1998 you may request a copy of personal information held about you by this website's email newsletter program. A small fee will be payable. If you would like a copy of the information held on you please write to the business address at the bottom of this policy.
Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is by no far a comprehensive list].
This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.
Our Use of Your Personal Information
We will use your Personal Information to process your subscription or requests for information. We may also use such Personal Information to offer additional information to you about us, our products and/or services, personalize the types of information you receive from us, evaluate how our Sites are being used and the audience our Sites are reaching, identify market trends and market interests that help us improve the products and services that we offer, and develop and improve the content and operation of our Sites to better serve the needs of our customers.
(1) Online Orders When you purchase a subscription from us, we will request certain Personal Information, including credit card information. Individuals who do not have a Visa, MasterCard or American Express credit card are not permitted to make purchases with us online.
(2) Sharing Information with Other Companies We may share your Personal Information (but never your credit card or password information) with our affiliates or with third parties who provide services to us and agree to keep your Personal Information confidential.
(3) Mailing and Email Addresses We will use your mailing and email addresses to send you the publications you have subscribed to. We may also contact you with questions about your subscription or service, or to remind you of your password, if necessary. If you submit an inquiry via email about one of your subscriptions, for security reasons we may ask you to provide additional information so we can verify your identity.
We may send you information and special offers on our other products. We may also, on occasion, use your mailing or email address to send you information or special offers from select companies that offer products, services or information we believe may be of interest to you. Though we hope you gain value from the email messages you receive, you can choose to opt out of receiving further messages by following the instructions provided at the bottom of each email.
You may, at any time, request to not have your mail and email information used for information and offers from us or other companies by contacting us at customer support – firstname.lastname@example.org
We will only disclose your Personal Information to our employees, affiliates, agents, contractors, or other third parties who have a need to know such information for the uses listed above. Except as provided above, we will not disclose Personal Information to any other third parties.
Personal Information may also be aggregated with such information from other visitors to the Sites such that the information no longer personally identifies you. We may use the aggregated information for the general purpose of evaluating our market and/or business trends, our customer demographics, interests and behaviour, our past and future product or service offerings and/or pricing, or other aspects of our business. We may share such aggregated information with our business partners, vendors, distributors or other collaborators, for these same purposes. We may also sell or license such aggregate information to one or more third parties for use in a similar manner.
We also retain the right to release your Personal Information when required by law or when we, in good faith, believe that we must release the information in order to: (1) satisfy a legal order or comply with legal process; (2) defend our rights or those of our affiliates or business partners; or (3) protect the personal safety of our employees, agents, affiliates, business partners, customers, or site users. We also retain the right to transfer your Personal Information in the context of the sale of all or part of our business.
Although we take the security of your Personal Information very seriously and are constantly improving our efforts to protect it, no electronic communication over the Internet can be guaranteed to be completely secured. Though we take great care to protect your personal information, we cannot guarantee the security of any information that you submit to us, and you do so at your own risk.
Although this website only looks to include quality, safe and relevant external links users should always adopt a policy of caution before clicking any external web links mentioned throughout this website.
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Adverts and Sponsored Links
This website may contain sponsored links and adverts. These will typically be served through our advertising partners, to whom may have detailed privacy policies relating directly to the adverts they serve.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Shortened Links in Social Media
This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls [web addresses] (this is an example: http://bit.ly/zyVUBo ).
Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.