TERMS OF USE

This web site is provided by Millennium Global Investments Ltd. ("Millennium Global"). 

The use of this website (the “Website”) is subject to acceptance of these Terms of Use.

This website is only open to persons who are Professional Clients (as defined under the rules of the Financial Conduct Authority of the United Kingdom) and any materials or information provided on this website are "FOR PROFESSIONAL CLIENTS ONLY". If you are not a Professional Client, you should not continue to view the information on this web site.

THE SERVICES DISCUSSED ON THIS WEBSITE ARE NOT AVAILABLE TO RESIDENTS OF THE FOLLOWING COUNTRIES: ARGENTINA, BAHRAIN, SINGAPORE, HONG KONG, KOREA, KUWAIT, SAUDI ARABIA, AND SINGAPORE. RESIDENTS OF THESE COUNTRIES ARE ADVISED TO DISCONTINUE VIEWING THIS WEBSITE.

AFTER YOU HAVE READ AND UNDERSTOOD THESE TERMS OF USE AND AGREE TO BE BOUND BY ITS TERMS AND CONDITIONS, PLEASE CLICK THE BUTTON BELOW TO ENTER.

BY ACCESSING, VISITING OR USING THIS WEBSITE, YOU, PERSONALLY AND ON BEHALF OF THE LEGAL ENTITY WHICH YOU ARE REPRESENTING, AS AGENT, POTENTIAL INVESTOR OR AN EMPLOYEE, WHEN ACTING IN SUCH CAPACITY, AGREE TO BE BOUND BY THE FOLLOWING TERMS AND CONDITIONS AND ALL APPLICABLE LAWS.  THESE TERMS OF USE ARE SUBJECT TO CHANGE WITHOUT NOTICE.  YOU ARE RESPONSIBLE FOR PERIODICALLY REVIEWING THE MOST CURRENT VERSION ON THIS WEBSITE.  YOUR CONTINUED USE OF THIS WEBSITE WILL BE DEEMED YOUR CONCLUSIVE ACCEPTANCE OF THE UPDATED TERMS OF USE.  IF YOU DO NOT AGREE WITH THESE TERMS OF USE, PLEASE DO NOT ACCESS, VISIT OR MAKE ANY USE OF THIS WEBSITE OR OF THE INFORMATION PROVIDED THEREIN.

Millennium Global Investments Limited ("Millennium") a company incorporated in England and Wales serves as the investment manager ("Investment Manager") of Separately Managed Accounts ("SMAs"). Millennium does not endorse and is not responsible for (a) the accuracy or reliability of any opinion, advice or statement made through the site by any party other than Millennium, (b) any content provided on linked sites (c) the capabilities or reliability of any product or service obtained from a linked site.

Important Disclosures

Although the information, material and content provided on this Website is believed to be reliable when posted, there is no guarantee that it is accurate, complete or current at all times and this Website could include technical or other inaccuracies.  This Website is provided to you on an "as is" basis, without warranties or representations of any kind.  Millennium and our affiliates, licensors, service providers and suppliers disclaim all statutory, express and implied warranties, representations and conditions of any kind to the extent permitted by law, including, without limitation, with respect to title, non-infringement, security, reliability, accuracy, timeliness, completeness, satisfactory quality and  merchantability. 

Your access and use of this Website is at your own risk.  To the fullest extent permitted by law, Millennium, our affiliates, licensors, service providers and suppliers or any of their respective officers, directors, shareholders, employees, subsidiaries, affiliates, agents or  representatives shall not be liable, at law, in equity or otherwise, for any direct, indirect, incidental of any kind whatsoever, special, consequential, punitive or other damages of any kind whatsoever, whether in contract, tort or otherwise, arising out of or in connection with this Website or a linked site and its use by you or your inability to use this Website or a linked site.

No information contained in this web site, any part of this web site, or associated documents (together the “Information”), may be redistributed in whole or in part, stored in a retrieval system, modified, linked into, republished, uploaded, transmitted in any form or by any means electronic or mechanical, or by photocopying, recording or otherwise without the express prior written permission of Millennium Global. 

The information on this Website is for informational purposes only.  Millennium and each of our affiliates, licensors, service providers and suppliers assume no liability for any errors or omissions, inaccurate, delayed or incomplete information, nor for any actions taken in reliance thereon.  Millennium does not endorse and is not responsible for (a) the accuracy or reliability of any opinion, advice or statement made through the Website by any party, (b) any content provided on linked sites, or (c) the capabilities or reliability of any product or service obtained from a linked site.

It is the responsibility of the User to evaluate the accuracy, completeness or usefulness of any opinion, advice or other content available through the Website.  Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific opinion, advice, product, service or other content.

No Investment Advice or Offers

Nothing in this Website constitutes investment advice, an invitation or recommendation to invest or otherwise deal in shares or other securities in any company, or an endorsement, sponsorship or recommendation as to the suitability of any product or security.  In addition, investor relation materials to the Website content are not offers to sell or solicitation of an offer to buy any security.  If you are considering an investment, you should make your own, independent assessment and obtain appropriate professional advice.

Forward Looking Information

Certain information on this Website contains certain forward-looking statements within the meaning of certain securities laws, including the “safe harbour” provisions of the Securities Act (Ontario) and other provincial securities law in Canada.  These forward-looking statements are subject to risks and uncertainties and speak only as of the date in which they are made.  The words "believe", "expect", "hypothetical", "anticipate", "optimistic", "intend", "aim", "will" or similar expressions are intended to identify forward-looking statements, which speak only as of the date on which they are made.  Millennium does not assume responsibility for the accuracy and completeness of any forward-looking statements to reflect subsequent events or circumstances and undertakes no obligation to update publicly or revise any forward-looking statements.

Your Authority to Use this Website

By using this Website, you are representing that you have the power and authority to accept these Terms of Use and to enter into this agreement with us, that you are capable of assuming, and do assume, any risks related to the use of this Website and its content, and that you understand and accept the terms, conditions and risks relating to their use.  If you are dissatisfied with this Website or its contents, your sole and exclusive remedy is to stop using it.

If you breach any of these Terms of Use, you may no longer use this Website.  Millennium may, in our sole discretion, cancel or terminate your right to use this Website, or any part of this Website at any time without notice.  Millennium is not liable to any party for any damages arising from such a termination.  We reserve the right to seek all remedies available at law and in equity for violations of these Terms of Use.

No Warranties

All content, products and services on this site are provided to you "as is" without warranty of any kind either express or implied including, but not limited to, the title, non-infringement, security or accuracy.

Other than is requested under the applicable law, under no circumstances will Millennium or its data or content provider be liable for any loss or damage caused by a user's reliance or information obtained through the site or a linked site, or user's reliance on any product or service obtained from a linked site. It is the responsibility of the USER to evaluate the accuracy, completeness or usefulness of any opinion, advice or other content available through the site. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific opinion, advice, product, service or other content

Indemnification

To the maximum extent permitted by applicable law, you agree to defend, indemnify and hold Millennium, our affiliates, licensors, service providers and suppliers and each of their respective officers, directors, shareholders, employees, subsidiaries, affiliates, agents or  representatives, from and against any claims, actions or demands, including without limitation reasonable legal and accounting fees, alleging or resulting from your use of the content or material contained on the Website or your breach of these Terms of Use.  Millennium shall provide notice to you promptly of any such claim, suit or proceeding and may assist you, in its sole discretion and at your expense, in defending any such claim, suit or proceeding.

Rights Granted and Restrictions on Use

The information on this Website is protected by copyright, trade-mark law, patent law and any other applicable laws.  The copyright in all content on this Website, unless otherwise indicated, is owned by Millennium or our affiliates, all rights reserved.  You may display on your computer, download and print the contents of this Website for personal or educational, non-commercial purposes, provided that you attribute ownership of such content to Millennium.  All copies that you make must retain all copyright and other notices that are on this Website.  Except as provided in the previous sentence, you may not use, distribute, sell, modify, transmit, revise, reverse engineer, republish, post or create derivative works (where applicable) of the trade-marks, trade names, logos, information, software or other material or content on this Website (referred to collectively as the “content” of this Website) without Millennium’s prior written permission.  You acknowledge and agree that this Website and its content are the property of Millennium, our affiliates or their respective service providers, suppliers or licensors and you will not acquire any rights or licenses in any trade-marks, patents, copyright or other intellectual property on this Website or in its content.

Privacy Policy

Millennium’s policies with respect to the collection, retention, use and sharing of information are set forth in our PRIVACY POLICY , which is incorporated herein by reference for all purposes.  Please review our Privacy Policy in order to understand our practices.  By accepting these Terms of Use, you are deemed as also consenting to Millennium’s Privacy Policy. 

Other Countries

This Website may be accessed from countries around the world and may contain references to products, services and programs that are not available in those countries, have not been announced in those countries, or access to which is not permitted in such countries.  These references do not imply that the company intends to announce such products, services or programs in such countries.  Millennium makes no representation that the content on this Website is appropriate or available for use in other locations, and accessing this Website from territories where its content is illegal is prohibited.  Those who choose to access this Website from other locations do so, on their own initiative and their own risk and are responsible for compliance with local laws.

Miscellaneous /Jurisdiction/Governing Law

These Terms of Use supersede any other agreement, whether oral or in writing, and render any other agreement regarding the terms of use of the Website null and void.  If any provision of these Terms of Use shall be declared unlawful, void or for any reason, unenforceable, then that provision shall be deemed severable from the Terms of Use and shall not affect the validity and enforceability of any remaining provisions.

User Disclosure

By clicking on the button below and proceeding further to view this website, the User understands and acknowledges that they are making a request to Millennium to provide the User with further information and materials. The materials to be provided at the request of the User are presented only for general information purposes; they are exclusively directed to the User/addressee in response to their request, only for personal use and it is expressly forbidden to copy and/or to distribute it.

If applicable, by registering or requesting access to this website, the User declares and acknowledges that, to the best of their knowledge, they are not subject to any restriction/limitation or other impediment to enter into an investment management agreement with Millennium under the applicable laws and regulations of their jurisdiction/country nor are they under any administrative or judicial investigation.

No information contained in this web site, any part of this web site, or associated documents (together the “Information”), may be redistributed in whole or in part, stored in a retrieval system, modified, linked into, republished, uploaded, transmitted in any form or by any means electronic or mechanical, or by photocopying, recording or otherwise without the express prior written permission of the website owner. 

Users of this Website agree to submit to the laws of the United Kingdom and the exclusive personal jurisdiction and venue of the courts of the United Kingdom with respect to any and all matters arising in connection with these Terms of Use.

Jurisdiction Specific Disclaimers

-       Australia:

In addition to the website terms of Use and Privacy Policy, the following disclaimer shall apply specifically to Australian Users accessing/viewing this website:

"Millennium Global Investments Limited ("Millennium") does not hold an Australian financial services licence ("AFSL"). Millennium provides financial services to wholesale clients in Australia in reliance on ASIC Class Order 03/1099, as amended from time to time. Millennium is regulated by the Financial Conduct Authority of the United Kingdom ("UK").  UK laws differ from Australian laws.

By accessing this website you acknowledge and agree that you are a wholesale client (as defined in section 761G of the Corporations Act 2001 (Cth)) and acknowledge that Millennium does not hold an AFSL.

If accessed from Australia, this website and its contents is only intended for wholesale clients (as defined in section 761G of the Corporations Act 2001 (Cth)).  The information on and accessed via this website is provided solely as a convenience to you for general information purposes only and is not, and is not intended to be, financial product advice.  The information on and accessed via this website has been prepared without taking account of your objectives, financial situation or needs.  Before acting on any information on and accessed via this website, consider the appropriateness of the information having regard to your objectives, financial situation and needs.  You should obtain professional financial, legal and tax advice before making any investment decision.  Nothing on or accessed via this website is, or is intended to be, an offer or solicitation of a financial product or service or a recommendation by any person to invest in a financial product or use a financial service.  Millennium does not guarantee that the contents of or any information accessed via this website is accurate, complete or up-to-date.  Millennium will not be responsible or liable, directly or indirectly, in any way for any loss or damage of any kind incurred as a result of, or in connection with, your use of, or reliance on, or arising from decisions based on, any of the information on or accessed via this website.

Foreign exchange products involve significant risks and are not suitable for all investors.  Certain financial products and services referred to on this website may not be available to Australian persons.  Millennium has not, and is not required to, prepare a Product Disclosure Statement under Australian law for any financial product referred to on this website.  Investment returns on Millennium products are not guaranteed.  Past performance of any product described on this website is not a reliable indication of future performance.

-       Brazil:

This website is owned and operated by Millennium Global Investments Ltd (“Millennium”), which is registered and operates in the United Kingdom. Millennium does not make any representation that the information on this website is appropriate for your use nor that access to the content of this website from your jurisdiction or elsewhere may not be deemed illegal or prohibited. Persons who choose to use this website from Brazil or other jurisdictions do so on their own initiative and are responsible for establishing the legality, useability and correctness of this website and the compliance with local laws, to the extent local laws may be applicable. 

The information contained in this website should not be understood as an analysis of any securities, promotional material, solicitation of purchase or sale, offering or recommendation of any financial asset or investment.  The products and/or services referred to in the website are not regulated and were not registered with any regulator other than the Financial Conduct Authority of the United Kingdom, nor are they registered with the Brazilian Securities Commission (Comissão de Valores Mobiliários - “CVM”) and, therefore, are not in compliance with certain requirements and proceedings usually observed in public offers of securities registered with such regulators.

The information contained in this website does not take into account your particular investment objectives, financial situation or investment needs. You should assess whether the information contained in this website is appropriate to your particular investment objectives, financial situation and investment needs. You should do this before making an investment decision. You can either make this assessment yourself or seek the assistance of any adviser.

Any investment decision should be made based solely upon your appropriate due diligence, as well as regulatory and tax advice.

Millennium is the owner of the copyright material in this website unless otherwise specified. The information contained herein shall not be copied without Millennium’s express authorization.

By using this website you acknowledge that you have read these terms and conditions above, together with any other terms and conditions or other statements, notices or disclaimers contained on this website. By using this website you agree to be bound by such terms and conditions. You acknowledge that you are accessing this website following your own initiative and that you are not responding to any form of prior solicitation or request from Millennium, its agents or representatives.

-       Chile:

The contracts offered herein do not represent a security under Chilean Securities Market Law No. 18,045, as amended and restated, and supplemental rules enacted thereunder (“Law 18,045”) and accordingly, they are not registered in the Foreign Securities Registry maintained by the Chilean Securities and Insurance Commission pursuant to Law 18,045.

- Mexico:

IMPORTANT NOTICE TO MEXICAN NATIONALS AND OTHER RESIDENTS

PLEASE READ THE FOLLOWING INFORMATION CAREFULLY BEFORE ACCESSING OR MAKING ANY OTHER USE OF THE FEATURES OF OR SERVICES RENDERED BY OR THROUGH THIS WEBSITE. IN ACCESSING THE WEBSITE, YOU AGREE TO BE BOUND BY THE FOLLOWING TERMS AND CONDITIONS AND ACKNOWLEDGE RECEIPT OF THE INFORMATION PROVIDED BELOW.

• By entering this website, you expressly agree and acknowledge that:

• You are an “institutional investor” or a “qualified investor” as defined in the Mexican Securities Market Law (Ley del Mercado de Valores) and the secondary regulation issued by the Mexican National Banking and Securities Commission.

• No product or service described in this website (i) constitutes a “security”, as defined in the Mexican Securities Market Law; (ii) are being offered within Mexican territory to any person; and (iii) are not suitable for circulation in the securities markets recognized by the Mexican Securities Market Law (Ley del Mercado de Valores).

• The execution, settlement and clearance of any transaction through this website will take place and become effective outside of Mexican territory.

• Any services rendered or performed through this website do not constitute investment advisory services within Mexican territory. Millennium expressly urges you to consult your own legal, tax and other advisors.

• Millennium is not a licensed Mexican financial entity. Neither the Mexican Banking and Securities Commission nor any other Mexican authority has approved or disapproved the information contained in this website, or the adequacy or veracity of the information contained herein.

• The information displayed in this website contains estimates and subjective analysis and value judgments. No representation or warranty, express or implied, is made regarding the adequacy, accuracy or reliability of the information, opinions, estimates and projections contained herein or that all assumptions relating to such estimates or projections have been considered or stated or that such projections will or may materialize. Millennium disclaims any and all liability relating to such information, including, without limitation, any express or implied representation or warranty for statements contained in, and omissions relating to, such information. 

-       New Zealand:

By accessing and viewing this website, the User or User Entity represents and warrants that its/their principal business is the investment of money or, in the course of and for the purposes of its/their business, habitually invests money.

User or User Entity understands and acknowledges that Millennium’s products and/or services are only offered in New Zealand to persons whose principal business is the investment of money or who, in the course of and for the purposes of the person’s business, habitually invest money.

-       Qatar:

This document is provided on an exclusive basis to the specifically intended recipient thereof, upon that person’s request and initiative, and for the recipient’s personal use only.

Nothing in this website constitutes, is intended to constitute, shall be treated as constituting or shall be deemed to constitute, any offer or sale of securities in the state of Qatar or in the Qatar Financial Centre or the inward marketing of a fund or an attempt to do business, as a bank, an investment company or otherwise in the State of Qatar or in the Qatar Financial Centre. This website and the documents and information presented therein have not been approved, registered or licensed by the Qatar Central Bank, the Qatar Financial Centre Regulatory Authority, the Qatar Financial Markets Authority or any other regulator in the State of Qatar.  Recourse against the website and those involved with it, may be limited or difficult and may have to be pursued in a jurisdiction outside Qatar and the Qatar Financial Centre.

Any distribution or re-distribution of this document by the User to third parties in Qatar or the Qatar Financial Centre or anywhere else, is unauthorised, strictly prohibited and shall be at the liability of such User.

-            United Arab Emirates:

“The information contained on this website does not constitute an offer, sale, public promotion, advertisement or delivery of any investment or financial product that has been made in the United Arab Emirates (UAE) or in accordance with any of the laws of the UAE. It is not intended to be a public offer and it is not intended to lead to the conclusion of any contract of whatsoever nature within the territory of the UAE in accordance with UAE laws (including laws of the Dubai International Financial Centre). The laws and jurisdiction governing any contractual arrangement with Millennium would be that contained in our investment management agreement or other account management services agreement signed between Millennium and the client.

Millennium is not subject to or incorporated under the laws of the UAE nor is it subject to regulation by any UAE regulatory authority including the UAE Central Bank, the UAE Securities and Commodities Authority, or the Dubai Financial Services Authority. Millennium is a company registered in England and Wales with the Registrar at the Companies House under registration number 02964847, regulated by the UK Financial Conduct Authority with Firm Registration Number 171039.

-       United Kingdom:

This web site is provided by Millennium Global Investments Limited and Millennium Assets Management Limited. Any financial promotions and managed account services on this web site are intended for Professional Clients only, as defined under the rules of the Financial Conduct Authority.  Millennium Global Investments Limited, an English company, acts as the investment manager of Millennium’s managed accounts services and products Millennium Global Investments Limited is authorised and regulated  by the Financial Conduct Authority and registered as an investment adviser with the Securities and Exchange Commission and  invests in and actively engages in transactions in instruments with significant risk characteristics.  Registration with the SEC does not imply a certain level of skill or training. 

This web site is subject to international copyright laws and other intellectual property rights, with all rights reserved.  No information contained in this web site, any part of this web site, or associated documents (together the “Information”), may be redistributed in whole or in part, stored in a retrieval system, modified, linked into, republished, uploaded, transmitted in any form or by any means electronic or mechanical, or by photocopying, recording or otherwise without the express prior written permission of Millennium. 

The Information may not be used for the purpose of an offer or solicitation in any jurisdiction or in any circumstances in which such offer or solicitation is unlawful or not authorised, and should not be published in hard copy, electronic form, via the web or in any other medium accessible to the public.  The Information is confidential and is not intended to influence you in making any investment decisions and should not be considered as advice or a recommendation to invest.  Any Information in this web site may not be suitable for all investors and investors must make their own investment decisions using their own independent advisors and relevant offering material.  Any investment decisions must be based upon an investor's specific financial situation and investment objectives.  Income from or the price or value of any financial instruments may rise or fall. Past performance is not necessarily indicative of future results. 

Millennium Global assumes no responsibility or liability for the correctness, accuracy, timeliness or completeness of the Information, for any viruses contained in, or attached to, this website or for any loss, damage or lost opportunities resulting from the use of the Information.  Any views, opinions or assumptions may be subject to change without notice.

Millennium Global Investments Ltd. Registered office address: Cassini House, 57-59 St James's Street, London SW1A 1LD, UK. Tel: +44 (0) 20 7663 8900.  Registered Number: 02964847

Authorised and regulated by the Financial Conduct Authority.  FCA registration number: 171039.

-       United States of America:

No Offer or Solicitation

This website and any materials accompanying it do not constitute an offer to sell or a solicitation to buy any securities, and may not be relied upon in connection with any offer or sale of securities. 

Risks of Investment

Please note that alternative investments can involve significant risk.  An investment that the Investment Manager makes on behalf of any SMA may be speculative and entails substantial risks, including the fact that such an investment could be illiquid and be subject to significant restrictions on transferability.  Past performance does not guarantee future results or profitability. 

Financial instruments and investment opportunities that the Investment Manager may enter into on behalf of SMAs discussed or referenced herein may not be suitable for all persons, and potential investors must make an independent assessment of the appropriateness of any agreement in light of their own objectives and circumstances, including the possible risk and benefits of entering into such an agreement.

An investor in an SMA could lose all or a substantial amount of his or her investment.  Returns generated from an investment in an SMA may not adequately compensate investors for the business and financial risks assumed.  While each SMA is subject to market risks common to other types of investments, including market volatility, Millennium may employ certain trading techniques, such as the use of leverage and other speculative investment practices that may increase the risk of investment loss.  The products and strategies in which the Investment Manager expects to cause the SMAs to invest may involve above-average risk. 

Net of Fees

All investment performance data contained on this website is net of all fees and expenses, unless otherwise specified.

No Duty to Update

Unless otherwise indicated, the information contained on this website is current as of the date of the website's launch.  Such information is believed to be reliable and has been obtained from sources believed to be reliable, but no representation or warranty is made, expressed or implied, with respect to the fairness, correctness, accuracy, reasonableness or completeness of the information and opinions contained herein.  Additionally, there is no obligation to update, modify or amend this website or to otherwise notify a reader in the event that any matter stated herein, or any opinion, projection, forecast or estimate set forth herein, changes or subsequently becomes inaccurate.  

The Compliance Officer
Millennium Global Investments Ltd.
Cassini House
57-59 St James's Street
London SW1A 1LD, United Kingdom
Email:    DL-Compliance@millenniumglobal.com

Privacy Policy

MILLENNIUM GLOBAL INVESTMENTS LTD

Millennium Global Investments Limited (“Millennium”, “we, “us”, and “our”) is committed to protecting the privacy, security and confidentiality of your Personal Information (as defined below) by ensuring that your information is treated with care and is not used or disclosed in ways to which you have not consented. This notice describes the Privacy Policy (“Policy”) of Millennium regarding how we collect, use and disclose Personal Information that is received about our prospective, current or former clients/investors. It applies to any Personal Information that is collected by Millennium, whether it is collected over the telephone, in writing, or electronically.

Millennium will never disclose, sell or lease to any third party any Personal Information that you provide to us, including through this website (the “Website”), without your permission, other than as described in this Policy, or unless we are required to do so by law.

BY PROVIDING US WITH YOUR PERSONAL INFORMATION AND USING THIS WEBSITE, YOU ACCEPT THIS POLICY AND CONSENT TO ITS TERMS, AS WELL AS ANY OTHER TERMS THAT ARE DESCRIBED TO YOU WHEN YOUR PERSONAL INFORMATION IS COLLECTED.  PLEASE BE SURE TO READ OUR ENTIRE POLICY BEFORE SUBMITTING INFORMATION TO OUR WEBSITE.  THIS POLICY MAY BE AMENDED OR UPDATED AT OUR DISCRETION FROM TIME TO TIME.  PLEASE CHECK THE WEBSITE FROM TIME TO TIME FOR SUCH AMENDMENTS.  BY CONTINUING TO ACCESS AND USE THE WEBSITE, YOU ACCEPT AND CONSENT TO THE TERMS OF THE THEN CURRENT POLICY, AS AMENDED. IF YOU DO NOT CONSENT TO THIS POLICY, PLEASE DO NOT USE THE WEBSITE OR OTHERWISE PROVIDE YOUR PERSONAL INFORMATION TO US.

What Personal Information Do We Collect?

“Personal Information” is personally identifiable information about you that may be obtained from discussions with you and documents you may deliver to Millennium, and may include your name, address, telephone number, social security number or tax identification number, assets, net worth, income, bank account information and occupation.

Publicly available information, such as business contact information or a public directory listing of your name, address, telephone number or information that is aggregated and not associated with a specific individual, including demographic information and statistics, is not considered Personal Information.

We may also collect your IP address when you use the Website and we may keep track of your dealings with us, including details of your visits to our Website and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data.

We may also receive Personal Information from our business partners and other third parties, provided that such third parties confirm to us that they have obtained your consent or we have obtained your consent in this regard. 

What Non-Personal Information Do We Collect?

We process the information gathered through the use of cookies and web beacons to better understand Users’ interests to aim to improve User satisfaction and to deliver information which may be of interest to the User.

We collect certain information which is recorded by the standard operation of our Internet servers on an anonymous basis, such as the operating system and type of browser you are using, the sections of the Website you visit, and the Website pages read and images viewed.

This non-identifiable information is used on an aggregate basis and in a non-personally identifiable form, including: (i) for Website and system administration purposes, (ii) to improve the Website, (iii) to conduct internal reviews of the number of visitors to the Website; (iv) to help us better understand visitors’ use of our Website; (v) to respond to specific requests from our visitors; and (vi) to protect the security or integrity of our Website when necessary.

Telephone Recording:

As a regulated entity, Millennium records telephone calls for business purposes including but not limited to the following:

•           To comply with regulatory record-keeping requirements;

•           To seek to ensure the prevention and detection of crime;

• To comply with contractual obligations with trading agreements; and
• For monitoring compliance with regulatory/self-regulatory and audit requirements. 

In doing so, Millennium will seek to be guided by the requirements of the Data Protection Act as well as Millennium’s Data Protection Policy.

Cookies

When you view the Website, we may place a “cookie” on the hard drive of your computer which allows the Website to remember who you are. Cookies provide additional functionality to the websites to better match users’ interests and preferences.  With most Internet browsers, you can erase Cookies from your computer hard drive, block the creation of Cookies, or receive a warning before a Cookie is stored, although doing so may affect your use of the Website and your ability to access certain features of the Website. Please refer to your browser instructions or the help section of your browser to learn more about these functions.

Other Technologies

Our Website may use web beacons or other technologies.  When you access certain of our web pages, a non-identifiable notice of that visit is generated which may be processed by us.  These technologies usually work in conjunction with cookies.  If you do not want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies.  If you turn off cookies, web beacons will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.

For What Purposes Do We Collect, Use and Disclose Your Personal Information?

Millennium collects Personal Information primarily to:

• provide investment management services;
• communicate information about its products and services;
• process subscriptions in its private investment vehicles;
• respond to your communications and requests;
• meet legal, regulatory, audit, security and financial requirements;
• maintain business records for reasonable periods of time;
• achieve any other purpose we may indicate to you from time to time.

Millennium permits only authorised individuals, who have been advised as to the proper handling of Personal Information, and who need to access this information to perform services, to have access to this information. These authorised individuals are required to maintain and protect the confidentiality of Personal Information.

In order to service your account and process transactions for your account, Millennium may provide Personal Information to its affiliates and to non-affiliated third party financial service providers that assist Millennium in servicing your account and have a need for such information, such as a broker-dealer or administrator. In addition, Millennium may share Personal Information with non-affiliated third party non-financial service providers, in order to process or service client transactions or products.  Unaffiliated third parties in this instance may include service providers such as word processors and printers. Any such contract entered into by Millennium will include provisions designed to ensure that the third party will uphold and maintain Millennium privacy standards when handling Personal Information.  Millennium may also disclose Personal Information to regulatory authorities as required or permitted by applicable law.

We may be involved in the sale or transfer of some or all of our businesses. As part of that sale or transfer transaction, we may disclose your Personal Information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of your Personal Information in a manner that is consistent with this Policy.

Millennium does not otherwise provide information about you to outside firms, organisations or individuals except at your request or to our attorneys, accountants and auditors and as permitted by law.

Except as described in this Privacy Policy, Millennium will not use Personal Information for any other purpose unless Millennium describes in advance how such Personal Information will be used and you are given an opportunity to decline approval of such use of your Personal Information.

Millennium will continue to adhere to this Privacy Policy with respect to the information we have in our possession relating to both existing and former clients.

Security and Retention of Personal Information

We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held.  We use physical, electronic, procedural, organizational and technological measures to protect Personal Information, such as locked filing cabinets, firewalls, encryption, and employee education.

We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law.  We use secure means of disposing of Personal Information.

Links to Third Party Websites

Our Website may contain links that take you to other third party websites. These third party websites are not governed by this Policy but by other privacy policies that may differ somewhat from our Policy. This Policy does not extend to the collection of Personal Information by these third parties and Millennium does not assume any responsibility for the privacy practices, policies or actions of third parties. We encourage you to review the privacy policies of each website visited before using these websites or disclosing any Personal Information to third parties.

Processing Of Personal Information

Your personal information may be processed and stored outside of your jurisdiction.  Under the laws of these other jurisdictions, in certain circumstances foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your personal information without notice to you.  By submitting your Personal Information, you agree to this transfer, storing or processing.

How To Correct Your Personal Information

Millennium wants to make sure that the information that we have collected about you is accurate, complete and current.  However, we will not routinely update this information unless it is necessary for us to do so to fulfil the purposes for which we collected the information.

Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed.

Access to Personal Information / Contact Information

We are accountable for all Personal Information in our custody and control and have designated a Privacy Officer who is ultimately accountable for the handling of all Personal Information in our custody and/or control, and for ensuring that the principles described in this Policy are being complied with.

If you have any questions about the accuracy of information that we have collected about you, you can have access to that information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such information.  You may write or email our Privacy Officer at the address below to request access to Personal Information that we have about you or to obtain further information about our privacy policies or practices:

The Compliance Officer
Millennium Global Investments Ltd.
Cassini House
57-59 St James's Street
London SW1A 1LD, United Kingdom
Email:    DL-Compliance@millenniumglobal.com