1. Introduction
This Privacy Policy explains how Ashbourne Capital Holdings, its affiliates and related entities (together, "Ashbourne Capital", "we", "us", or "our") handle information in connection with your visit to this website at ashbournecap.com (the "Site"). By accessing the Site, you acknowledge that you have read and understood this Policy.
Ashbourne Capital is a specialist hedge fund and alternative investment research firm. The due diligence, manager research, and analysis referenced on the Site are conducted solely for our own internal purposes. We do not offer products or services to members of the public or retail investors, and the Site is not intended to generate or process enquiries from external or prospective clients.
2. Scope of This Policy
This Policy applies only to your use of the Site. It does not apply to any personal data that Ashbourne Capital or its affiliates may collect or process outside the context of the Site, including in connection with any separate business relationship, engagement, or communication, which (if applicable) would be governed by separate arrangements agreed between the relevant parties.
3. Information We Collect
The Site does not contain a contact form, sign-up form, newsletter subscription, login, or any other mechanism that actively requests your name, email address, or other personal details. We do not ask you to create an account, and we do not knowingly collect, store, or process personal data through the Site, save as described in Section 4 below.
4. Investor Notice Preference (Local Storage)
Before accessing the substantive content of the Site, you are asked to confirm that you satisfy one of the categories of investor described in our entry notice. If you tick the box marked "Please check this box to remember my choice" and select Confirm, a small piece of data is saved in your own browser's local storage — not a cookie, and not a file transmitted to or held on our servers — recording that this confirmation was made.
- This preference is stored exclusively on your own device, for a maximum of 30 days from the date of confirmation.
- It is never transmitted to, or made accessible to, Ashbourne Capital, our affiliates, or any third party. It exists solely within your browser so that you are not required to reconfirm your status on every visit.
- It does not identify you. It records only that a confirmation took place and the date it will expire — no name, email address, IP address, or other identifying information is attached to it.
- You may delete this record at any time via your browser's site data or privacy settings, or by using the "click here" reset link shown on the restricted-access screen if you select Decline.
In short: Ashbourne Capital does not use cookies, pixels, or similar technologies for advertising, analytics, or tracking on this Site. The single item of local storage described above is strictly functional, is never transmitted to us, and exists only to remember your entry-notice confirmation on your own device.
5. Server and Hosting Information
As with substantially all websites, the infrastructure used to host the Site may automatically generate limited technical information when a request is made to load a page, such as IP address, browser and device type, referring page, and the date and time of the request. This information is generated and retained by our hosting and infrastructure providers for routine operational, security, and diagnostic purposes — for example, to detect and mitigate malicious activity, prevent abuse, and maintain the availability of the Site. Ashbourne Capital does not use this information to identify, profile, or market to individual visitors, and does not combine it with any other data source to do so.
6. Cookies and Similar Technologies
The Site does not currently deploy cookies, web beacons, tracking pixels, or third-party analytics or advertising technologies of any kind. Should this change in the future — for example, if analytics tools are introduced — this Policy will be updated in advance, and, where required by applicable law, your consent will be sought before any such technology is activated.
7. How Information Is Used and Disclosed
Because Ashbourne Capital does not collect or hold personal data through the Site, we do not use, sell, rent, license, or otherwise disclose visitor data to any third party, including our affiliates, for marketing or any other purpose. The technical server-level information described in Section 5 is held by our infrastructure providers and used exclusively for the operation, security, and integrity of the Site, and may be disclosed only where required by applicable law, regulation, or a valid legal process.
We do not sell personal information, and we do not engage in any practice that would constitute a "sale" or "sharing" of personal information under applicable data protection or privacy legislation.
8. International Access
The Site may be accessed from a number of jurisdictions. As no personal data is collected or transmitted to us through the Site (other than the client-side local storage record described in Section 4, which never leaves your device), no cross-border transfer of personal data by Ashbourne Capital arises from your use of the Site.
9. Children's Privacy
The Site is directed exclusively at professional, institutional, and other eligible investors as described in our entry notice, and is not directed at, or intended for use by, children. We do not knowingly collect personal data from any individual under the age of 18.
10. Data Retention
The entry-notice preference described in Section 4 automatically expires no later than 30 days after it is set, and can be deleted by you at any time. Ashbourne Capital does not separately retain, and has no ability to access, any record of your visit to, or use of, the Site.
11. Your Rights
Depending on your location, you may have rights under applicable data protection law — for example, the UK GDPR, the EU GDPR, or equivalent legislation elsewhere — including rights to access, rectify, or request erasure of personal data held about you, and to lodge a complaint with your local supervisory authority. Because Ashbourne Capital does not hold personal data server-side in connection with the Site, these rights will generally have no practical application to your use of the Site; to the extent you wish to exercise any right in relation to the local storage record described in Section 4, you may do so directly and immediately by clearing it from your own browser.
12. Security
While no method of electronic storage or transmission is completely secure, Ashbourne Capital's hosting and infrastructure providers maintain reasonable administrative, technical, and physical safeguards designed to protect the Site and the limited technical information described in Section 5 from unauthorised access, use, or disclosure.
13. Changes to This Policy
We may amend this Privacy Policy from time to time to reflect changes in the way the Site operates or in applicable law. The date at the top of this document indicates when it was last revised, and any changes will take effect from the date of publication on the Site.
14. Accuracy of This Policy
Ashbourne Capital has taken reasonable care in the preparation of this Privacy Policy. However, we do not warrant that it is complete or free from error or omission. To the fullest extent permitted by applicable law, Ashbourne Capital shall not be liable for any loss or damage arising from any inaccuracy, error, or omission in this Policy, save that nothing in this Section shall exclude or limit our liability for fraud, wilful misconduct, or any other liability which cannot lawfully be excluded or limited. Any such error or omission will be corrected as soon as reasonably practicable once identified.
15. Governing Law
This Privacy Policy, and any dispute or claim arising out of or in connection with it, shall be governed by, and construed in accordance with, the laws of the British Virgin Islands.
1. Acceptance of These Terms
These Terms and Conditions (these "Terms") constitute a binding agreement governing your access to and use of the website at ashbournecap.com (the "Site"), operated by Ashbourne Capital Holdings, together with its affiliates and related entities ("Ashbourne Capital", "we", "us", or "our"). By accessing the Site, including by confirming the entry notice presented on arrival, you acknowledge that you have read, understood, and agree to be bound by these Terms and by the representations set out in Section 3. If you do not agree to these Terms, you must not access or continue to use the Site.
2. About Ashbourne Capital
Ashbourne Capital is a specialist hedge fund and alternative investment research firm. The due diligence, manager research, and analysis referenced on the Site are conducted solely for our own internal purposes. We do not manage assets on behalf of external or public clients through the Site, and the Site does not offer, and is not a channel for, any client-facing service, product, subscription, or engagement of any kind.
Ashbourne Capital is not registered as, and does not hold itself out to be, an investment adviser, broker-dealer, fund manager, or other regulated financial services provider on the basis of the activities described on the Site, and nothing on the Site should be construed as indicating otherwise.
3. Eligibility and Restricted Access
The Site is directed and intended to be accessed only by persons who satisfy one or more of the following criteria (each, an "Eligible Person"):
- a professional client or an eligible counterparty, as defined under the Markets in Financial Instruments Directive (Directive 2014/65/EC), as amended or updated ("MiFID"), or the equivalent classification under the law of your jurisdiction;
- a financial advisor or financial intermediary acting on behalf of a professional client or eligible counterparty; or
- an institutional investor, qualified purchaser, or accredited investor, as such terms are defined under applicable law in your jurisdiction.
By confirming the entry notice, you represent, warrant, and undertake to Ashbourne Capital that: (i) you are an Eligible Person; (ii) you are accessing the Site for your own professional purposes and not on behalf of, or for onward distribution to, any member of the public or retail investor; and (iii) you will not rely on, and will not hold Ashbourne Capital liable in connection with, any content on the Site if the representations in this Section 3 are inaccurate. Ashbourne Capital reserves the right to restrict, suspend, or terminate your access to the Site at any time, without notice, if we reasonably believe these representations to be untrue.
4. No Offer, Solicitation, or Investment Advice
Nothing on the Site constitutes, or should be construed as, an offer to sell, or a solicitation of an offer to buy, any securities, fund interests, or other financial instruments, nor is it a recommendation, invitation, or inducement to engage in any investment activity or transaction of any kind. Content on the Site reflects our internal research and analysis as at the date presented, is subject to change without notice, and must not be relied upon as investment, legal, tax, or other professional advice. You should seek independent professional advice before making any investment or other decision.
5. No Warranty
The Site and all content made available on it are provided on an "as is" and "as available" basis, without warranty of any kind, whether express or implied, including any implied warranties of accuracy, completeness, merchantability, fitness for a particular purpose, or non-infringement. Ashbourne Capital does not warrant that the Site will be uninterrupted, error-free, or free from viruses or other harmful components, and content may be amended, updated, or withdrawn at any time without notice. Past performance of any manager, fund, or strategy referred to on the Site is not indicative of, and should not be relied upon as an indicator of, future results.
6. Limitation of Liability
To the fullest extent permitted by applicable law, Ashbourne Capital, together with its officers, employees, and affiliates, shall have no liability whatsoever, whether in contract, tort (including negligence), or otherwise, for any loss or damage — direct, indirect, incidental, special, or consequential, including loss of profits, revenue, data, or goodwill — arising out of or in connection with your access to, use of, or inability to use the Site, or any reliance placed on its content, even where Ashbourne Capital has been advised of the possibility of such loss.
7. Indemnity
You agree to indemnify and hold harmless Ashbourne Capital, its officers, employees, and affiliates from and against any and all claims, liabilities, losses, damages, costs, and expenses (including reasonable legal fees) arising out of or in connection with your breach of these Terms, your misuse of the Site, or any inaccuracy in the representations made by you under Section 3.
8. Intellectual Property
All content on the Site, including text, graphics, logos, imagery, data compilations, and the design and layout of the Site, is the property of Ashbourne Capital or its licensors and is protected by applicable copyright, trademark, and other intellectual property laws, unless otherwise stated. No licence is granted to you other than the right to view the Site for your own personal, non-commercial reference. You may not copy, reproduce, republish, distribute, transmit, or otherwise exploit any content from the Site, in whole or in part, without our prior written consent.
9. Acceptable Use
You agree not to: (a) access or attempt to access any part of the Site by any means other than through the interface provided; (b) interfere with or disrupt the operation of the Site, including by introducing malicious code; (c) use any automated means, including bots, scrapers, or crawlers, to access or extract content from the Site without our prior written consent; or (d) misrepresent your identity or eligibility in order to gain access to the Site.
10. Third-Party Content and Links
The Site may from time to time reference third parties or contain links to third-party websites. Ashbourne Capital does not control, and accepts no responsibility or liability for, the content, accuracy, or availability of any third-party website, and the inclusion of any such reference or link does not constitute or imply endorsement, sponsorship, or recommendation by Ashbourne Capital.
11. Changes to the Site or These Terms
We may update, amend, suspend, or discontinue any part of the Site, or these Terms, at any time and without notice and without liability to you. The version of these Terms published on the Site at the time of your visit governs that visit. Continued use of the Site following any change constitutes your acceptance of the Terms as amended.
12. Severability
If any provision of these Terms is held by a court or other competent authority to be invalid, illegal, or unenforceable, that provision shall be deemed modified to the minimum extent necessary to make it valid, legal, and enforceable, and the remaining provisions shall continue in full force and effect.
13. No Waiver
No failure or delay by Ashbourne Capital in exercising any right or remedy under these Terms shall operate as a waiver of that right or remedy, nor shall any single or partial exercise of any right or remedy preclude any further exercise of it.
14. Entire Agreement
These Terms, together with our Privacy Policy and the entry notice, constitute the entire agreement between you and Ashbourne Capital in relation to your access to and use of the Site, and supersede all prior or contemporaneous understandings, agreements, or representations, whether written or oral, relating to that subject matter.
15. Accuracy of These Terms
Ashbourne Capital has taken reasonable care in the preparation of these Terms and the accompanying Privacy Policy. However, we do not warrant that either document is complete or free from error or omission. To the fullest extent permitted by applicable law, Ashbourne Capital shall not be liable for any loss or damage arising from any inaccuracy, error, or omission in these Terms or the Privacy Policy, whether arising from drafting, transcription, or any other cause, save that nothing in this Section shall exclude or limit our liability for fraud, wilful misconduct, or any other liability which cannot lawfully be excluded or limited. Any such error or omission will be corrected as soon as reasonably practicable once identified, and shall not affect the validity or enforceability of the remainder of these Terms.
16. Governing Law and Jurisdiction
These Terms, and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with them, their subject matter, or their formation, shall be governed by, and construed in accordance with, the laws of the British Virgin Islands. The courts of the British Virgin Islands shall have exclusive jurisdiction to settle any such dispute or claim.