Important legal information,
disclaimers, terms, conditions and references to regulatory matters relating to
this website. The information contained on this website is issued by the
Avington Group of Companies of which Avington Financial Limited is authorised
and regulated by the Financial Conduct Authority ('FCA'). Further information
about the regulated firm and the FCA can be found at www.fca.org.uk
This website may contain links to other websites. These links
are included to provide useful or additional information. We are not
responsible for the accuracy or content of these websites nor should their
inclusion be construed as an endorsement of such websites or the information
contained on them. We have not reviewed these websites and are not responsible
for their availability, content their use of your personal data or your use of
those sites. We recommend that you read the policies used by these websites and
check how they protect your personal data and whether they are trustworthy.
By using this website you confirm that you have read, understood
and accepted these conditions Avington may change these conditions. Your access
to this website is governed by the version of these conditions then-in-force.
All disputes relating to these conditions or your use of the website are
governed by the laws of England and Wales.
INTELLECTUAL PROPERTY RIGHTS
We or our licensors are the owners of the intellectual property
rights that appear in the content of this Website, including any and all UK
registered and unregistered trademarks, logos, get ups and copyrights used on
this Website. The domain name is registered on behalf of Avington. You acknowledge
that Avington Intellectual Property cannot be used without the prior written
consent of Avington. Under no circumstances whatsoever should any of the
information on this website be copied, reproduced or otherwise redistributed
without our express prior consent in writing.
The Avington Group of
companies receive very little identifying information from visitors to our web
site. Information that is received is collected to allow us to respond to
queries for further information, such as to distribute requested reference
materials, for advertising and marketing purposes and to respond to career
The identifying information
we collect may consist of basic contact information (such as your name, job
title, company address, email address and telephone and fax numbers). Other
information may be submitted if you respond to an on-line job application, as
requested by that application form.
You can also submit emails to
addresses given on the web site. Any messages will contain your screen name and
email address together with any additional information you may wish to include
in the message. Information collected may be disclosed to firms within the
Avington Group of companies where it is necessary to meet the purpose for which
you have submitted the information. Otherwise, the data collected is not shared
with third parties for secondary or unrelated purposes unless otherwise
disclosed at the point of collection.
Through your use of this web
site you give us your explicit consent to collect, use and disclose data on
your identity and patterns of usage of this web site for the purposes outlined
Please note that data that is
transported over an open network, such as the Internet or e-mail, may be
accessible to anybody. We cannot guarantee the confidentiality of any
communication or material transmitted via such open networks. When disclosing
any personal information via an open network, you should remain mindful of the
fact that it is potentially accessible to others, and consequently, can be
collected and used by others without your consent.
GDRP Privacy Notice
Avington Financial Limited, Company registration number: 05572801
The firm’s ICO registration number is: ZA317922
2. The personal Data we may collect about you:
Where we collect data that identifies an individual this is classed as “personal data”. Personal data may include (but is not limited to) a name, date of birth, contact address and telephone number.
The types of personal data we may request are:
- Full name and title including any previous names;
- Photographic proof of identity (typically passports or photo driving licences);
- Proof of address (utility bill);
- Marital status;
- Contact information such as postal address, residential address, email address and telephone numbers;
- Tax information (Unique tax reference number and national insurance number);
- Information regarding your investment experience, wealth, source of funds and bank details;
- Information regarding your knowledge of investment and types of transactions undertaken;
- Employment history and salary details;
- Marketing preferences which include the type of, and how you wish to receive, information; and
- Information we learn from you such as requests, transactions, services provided or offered, any advice or recommendations made, a log of meetings, telephone recordings (where permitted and required for regulatory purposes) complaints and dissatisfaction notes, as well as email exchanges.
The above list is not exhaustive and we may from time to time require additional information in order to satisfy our legal and regulatory obligations. Where additional information is required we will provide you with a reasonable explanation of why it is required, unless we are prevented from doing so by law.
The firm may use methods such as pseudonymisation, which is a process whereby the firm can replace identifying fields of data with other non-identifying data fields in order to anonymise the data from the individual therefore meaning the data is no longer personal. The firm may use this method where we are required to retain certain types of information for clients, such as number of females and males employed, jobs created and average salaries paid. This type of statistical data is often required for ESG (environmental, social and governance) investment purposes by clients to show value added investments made by the firm on behalf of its clients.
Use of this website
The type of data we collect when you visit our site may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site as well as the types of products and services and searches you conduct on our site.
Special Category Data
Special category data refers to any data which is sensitive and is subject to additional rules and requirements under the General Data Protection Regulations. Special category data may include information regarding: criminal convictions and offences, race, ethnicity, religious or philosophical beliefs, political opinions, sexual orientation, trade union membership and information about your health, genetic and biometric data.
As a general rule we do not collect any special category data about you. However, we are required to request information relating to criminal convictions as part of our recruitment process for staff and contractors undertaking regulated activities and, as such, we require consent from the individual for this. If we are required by law to request any special category data from you, aside from the reasons mentioned above we will provide you with a reasonable explanation as to the nature and purpose for this request and obtain your consent. We would not be able to proceed without your consent unless there was a lawful reason for doing so.
How do we collect your personal data?
Typically, where we are required to obtain your personal data we will request it from you. However, we may also from time to time receive your personal data through intermediaries where you have authorised the sharing of your personal data with us. Intermediaries may include accountants, solicitors, independent financial advisors, tax advisors and wealth managers who may be working on your behalf. Personal data may be provided to us via post, in person, email or via a specially created secure data room / platform. The data collection may be facilitated by way of completing an application form or questionnaire or by responding to information requests from us. We may also receive information from publicly available resources.
Why do we collect your personal data?
We only collect your personal data where we believe we have a legitimate business interest with you or we have a lawful purpose or requirement to do so. These reasons may include but may not be limited to circumstances where you:
- are a shareholder in one of the companies to whom we have an administration and / or management agreement with;
- are a Limited Partner or an investor in one of the funds to which we are appointed manager / operator, or any other such investment schemes under our management;
- are actively receiving investment services or products from us under a contractual arrangement or engagement;
- consent to receiving communications from us;
- have a contractual agreement with us;
- request resources or marketing be sent to you; or
- give us feedback or some other form or legitimate business interest with you
How and why do we use your personal data:
Typically, we only use your data to be able to perform our duties under contracts we may have with you or where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at
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 email us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data.
You will receive marketing communications from us if you have:
- requested information from us or have a contractual agreement with us; or
- if you provided us with your details and have positively consented to us sending you marketing communications;
and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purpose, you should be advised that consent is not infinitive and you can opt-out from receiving marketing communication from us at any time by emailing; firstname.lastname@example.org
Where you opt out of receiving our marketing communications, this will not apply to communication we make with you in relation to a legitimate business interest or lawful purposes, such as the performance of a contract we may have with you.
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.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal grounds for this.
We may process your personal data without your knowledge or consent only where this is required and permitted by law.
Sharing and Disclosure of your personal data:
We may share your personal data with the parties set out below for legitimate business interests and lawful purposes, these may include, but are not limited to:
- Other companies in our group who provide IT and system administration services and undertake leadership reporting. Service providers who provide IT and system administration services;
- Professional advisers including lawyers, bankers, auditors, tax advisors and insurers who provide consultancy, banking, legal, insurance, tax and accounting services;
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances, which may include, but is not limited to, The Financial Conduct Authority;
- Fraud prevention agencies;
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We do not normally share or transfer your data outside of the European Economic Area (“EEA”), as countries outside of the EEA do not always offer the same levels of protection to your personal data. European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. However, with your consent the Company may transfer personal information outside the EEA to certain countries on the basis that the country, territory or organisation is designated as having an adequate level of protection, on the basis that the organisation receiving the information has provided adequate safeguards by way of binding corporate rules, standard data protection clauses, or of compliance with an approved code of conduct.
Please email chume@avfin if you like further information regarding international transfers or the ICO (information commissioner’s office) https://ico.org.uk/for-organisations/guide-to-data-protection/principle-8-international/
The Security of your Data
We have put in place adequate, proportionate and appropriate security measures as is required of an authorised firm 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 such data. 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 data breaches in accordance with the GDPR and we will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention periods:
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, regulatory. 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.
By law we must keep basic information about our customers (including contact, identity, financial and transaction data) for six years for tax purposes and for at least five years after a client ceases to be a client under the UK Money Laundering Regulations 2017.
In some circumstances, we may pseudonymise your personal data for statistical purposes in which case we may use this information indefinitely without further notice to you.
GDPR personal rights:
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data (subject access request);
- Request correction of your personal data;
- Request erasure of your personal data;
- Object to processing of your personal data;
- Request restriction of processing your personal data;
- Request transfer of your personal data; and
- Right to withdraw consent
For further information visit or if you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of your 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. In order to respond to a subject access request, we will need to confirm your identity as a security measure to safeguard you from your personal data from being disclosed to non-authorised third parties. Please provide us with as much information as possible to enable us to comply with your request within an acceptable time-frame. We are required to respond to subject access requests where practically possible within 30 days and if this is not possible we will provide you with a reasonable explanation as to why this cannot be achieved.
Complaints and queries:
If you are not happy with any aspect of how we collect and use your data, please contact firstname.lastname@example.org and we will do our best to resolve your issue. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We will make all reasonable efforts to ensure the data we hold on you is accurate and up to date and to correct any inaccuracies that we become aware of. Please help us to comply with our obligations by letting us know of any changes in relation to the data we hold about you as It is very important that the information we hold about you is accurate and up to date. Please email email@example.com with any required updates or amendments.
The materials in this web
site are provided free of charge for general information purposes only.
Avington Group of companies will not treat users of this Site as its clients by
virtue of them accessing it. Nothing on this web site should be construed as an
invitation, offer or recommendation to buy or sell investments, shares or
securities or to form the basis of a contract to be relied upon in any way.
Avington Financial Limited does not provide investment advice to retail
investors and if you are in any doubt about the information on this website you
should consult your own accountant, solicitor, stockbroker, independent
financial adviser or other professional adviser.
If you do need advice on any
specific problem, or would like further information on any information
contained in this site, then please do not hesitate to contact us.
Whilst we seek to keep this
website up-to-date, the information displayed is subject to change without
Avington provides no
guarantees, representations or warranties regarding the accuracy timeliness,
performance, completeness or suitability of any information on this website. No
third party liability is accepted by Avington, its directors and employees or
its affiliates and their directors in respect of errors and omissions other
than under the duties and liabilities of the Financial Services and Markets Act
The information contained on
this Site may relate to the products and services of a person or entity that is
located in a jurisdiction other than that in which you are located. Accordingly
the rules for the protection of private customers that apply in the
jurisdiction in which you are located may not apply in relation to such products
This Site is not directed at,
or intended for distribution to or use by, any person or entity who is a citizen or resident of or located in any
jurisdiction where such distribution, publication, availability or use would be
contrary to applicable law or regulation or which would subject us to any
registration or licensing requirement within such jurisdiction. Nothing on this
Site shall constitute an offer or a solicitation of an offer to buy or sell any
products or service.
The content of the web pages
should be construed under and governed by the laws of England and Wales and the
courts of this jurisdiction will have exclusive jurisdiction in respect of any
dispute that may arise, except where such content is expressed to be governed
by the laws of another jurisdiction. If for any reason a court of competent
jurisdiction finds any provision of the Important Information section
unenforceable, that provision shall be enforced to the maximum extent
permissible, and the remainder of the Important Information shall continue in
full force and effect. The Important Information section constitutes the entire
agreement between Avington and you with regard to this website and it
supersedes all prior or contemporaneous communications, agreements and
understandings between Avington and you with respect to the subject matter
Past performance is not
necessarily a guide to future performance. The value of investments and the
income of any financial instruments mentioned in the website may fall as well
as rise, and investors may get back less than the amount originally invested.
Fluctuations in exchange rates may have a positive or an adverse effect on the
value of foreign-currency denominated securities and financial instruments.
Certain investments, in particular hedge funds, venture capital funds and
emerging markets, involve an above-average degree of risk and should be seen as
long-term in nature. Derivative instruments and warrants involve a high degree of
risk. It may be difficult for an investor to deal in derivative investments or
to obtain reliable information about their value. In the case of Over the
Counter Derivatives, the investment may only be sold back to the original
counterparty from which it was purchased. A warrant involves a high degree of
gearing (leveraging) so that a small movement in the price of the security to
which the warrant relates may result in a disproportionately large fall or rise
in the price of the warrant.
The Avington Group of
Companies are committed to ensuring that Avington Financial Limited, its sister
companies subsidiaries, associates, staff and agents, comply with the
requirements of the Bribery Act 2010. It is committed to conducting its
business fairly honestly and openly, and has a zero tolerance towards bribery.
It has implemented a risk based approach to identify areas where it may be at
risk to bribery and has put in place systems and procedures to reduce this
risk. It will not deal with firmsí individuals or other entities that refuse to
give the same commitment. The firm has implemented a number of procedures which
are monitored for effectiveness on a regular basis which are intended to
prevent the firm its staff or agents being involved in bribery. These are
reviewed regularly to ensure they remain current and robust.
to monitor browsing preferences. We may collect information about your
computer, including your IP address, operating system and browser type, for
system administration and in order to create reports. This is statistical data
about our usersí browsing actions and patterns, and does not identify any
The only cookies in use on
our site are for Google Analytics. Google Analytics is a web analytics tool
that helps website owners understand how visitors engage with their website.
Google Analytics customers can view a variety of reports about how visitors
interact with their website so that they can improve it.
Like many services, Google
Analytics uses first-party cookies to track visitor interactions as in our
case, where they are used to collect information about how visitors use our
site. We then use the information to compile reports and to help us improve our
Cookies contain information
that is transferred to your computerís hard drive. These cookies are used to
store information, such as the time that the current visit occurred, whether
the visitor has been to the site before and what site referred the visitor to
the web page.
Google Analytics collects
information anonymously. It reports website trends without identifying
individual visitors. You can opt out of Google Analytics without affecting how
you visit our site Ė for more information on opting out of being tracked by Google
Analytics across all websites you use, visit this Google page.
NB. Cookies are small text
files that are stored on your computer when you browse certain websites. These
files contain data that can be accessed by a web server, letting it know if the
user has visited the site before. Cookies are harmless and do not store
sensitive information. They are often used to tailor a web page with settings
that are specific to the user, for instance; when a browser stores your
username and password.