Legal Notices
TRADEMARKS
The following marks and stylized logo are all registered trademarks of Avington International.
The following mark is a registered trademark of Avingstone Trademarks International.
The following circular logo device is a registered trademark Avington International and is used under license by Avingstone.
Avingstone Limited, Avington International and Avington Financial Limited are part of the Avington Group.
Avington Financial Limited is authorised and regulated by the Financial Conduct Authority UK.
WEBSITE USAGE POLICY
Welcome to our website. If you continue to browse and use this website you agree to comply with and be bound by the following terms and conditions of use, which together with our privacy policy govern our relationship with you in relation to this website.
The term Avingstone or 'us' or 'we' refers to the Avingstone Group of Companies (Avingstone) the owner of the website is Avingstone Limited whose registered office is: Michelin House, 81 Fulham Road, London, SW3 6RD, United Kingdom.
Avingstone Limited company registration number is 08549661 - Registered in England & Wales. The term 'you' refers to the user or viewer of our website.
The materials in this website are provided free of charge for general information purposes only. Avingstone will not treat users of this site as its clients by virtue of them accessing it. Nothing on this website 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.
The use of this website is subject to the following terms of use:
The content of the pages of this website is for your general information and use only. It is subject to change without notice.
Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website.
Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
From time to time this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s). Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
You may not create a link to this website from another website or document without Avingstone's prior written consent.
Your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Scotland and Wales.
It is your responsibility to be informed of and to observe all applicable laws and regulations of any relevant jurisdiction and to satisfy yourself that your use of this information and any subsequent engagement with Avingstone Limited is permissible under the applicable laws, rules and regulations of any applicable government, governmental agency or regulatory organisation where you reside. Nothing on this site shall constitute an offer or a solicitation of an offer to buy or sell any products or service.
If you wish to contact us regarding corporate matters please use this address:
AVINGSTONE LIMITED
MICHELIN HOUSE
81 FULHAM ROAD
LONDON
UNITED KINGDOM
SW3 6RD
Company No. 08549661
COOKIES
This website uses cookies 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 users’ browsing actions and patterns, and does not identify any individual.
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 site.
Cookies contain information that is transferred to your computer’s 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 – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page. https://tools.google.com/dlpage/gaoptout
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.
PRIVACY POLICY
Avingstone does not use cookies to collect personal data on users other than that stated per the cookies section. However as a result of seeing this website and contacting the firm you may be asked to provide personal data. This privacy policy sets out how Avingstone uses and protects any information that you give to the firm.
Avingstone is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified then you can be assured that it will only be used in accordance with this privacy statement.
Avingstone may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 1st October 2015.
GDPR PRIVACY NOTICE
1. Information:
The information contained in this privacy policy statement is intended to provide you with details of how we may collect and process the personal data you may provide us from time to time and the circumstances giving rise to the request and receiving of data.
Avingstone Limited (“Avingstone”) acts as a data controller and processor. Avingstone is referred to as the “firm”, “we”, “us” or “our” in this privacy policy statement.
Contact Details
Avingstone Limited, Company registration number: 08549661
Contact details for the purpose of this privacy policy statement and the person responsible for data protection and privacy for the firm is:
Email: cbunte@avingstone.com
The firm’s ICO registration number is: CSN3573730
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.
Please see our cookie policy for your information on how this site uses cookies.
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 cbunte@avingstone.com if you need details about the specific legal ground we are relying on to process your personal data.
Marketing communications
You will receive marketing communications from us if you have:
(i) requested information from us or have a contractual agreement with us; or
(ii) 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; cbunte@avingstone.com
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.
International Transfers:
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 cbunte@avingstone.com 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 cbunte@avingstone.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 cbunte@avingstone.com 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).
Accurate Data:
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 cbunte@avingstone.com with any required updates or amendments.
WHAT WE COLLECT
We may collect the following information:
Name
Contact information including email address
IP number, domain and geo-location from the computer you use to access the website
Demographic information such as postcode, preferences and interests
Other information relevant to customer surveys and/or offers
WHAT WE DO WITH THE INFORMATION WE GATHER
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
Internal record keeping
We may use the information to improve our products and services.
We may periodically send promotional email about new products, special offers or other information which we think you may find interesting using the email address which you have provided but giving you the right to opt-out of such communications
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests
SECURITY
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
CONTROLLING YOUR PERSONAL INFORMATION
You may choose to restrict the collection or use of your personal information or to change your mind about receiving marketing information by writing to or emailing us at :
AVINGSTONE LIMITED
MICHELIN HOUSE
81 FULHAM ROAD
LONDON
UNITED KINGDOM
SW3 6RD
adminstrator@avfin.co.uk
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to:
AVINGSTONE LIMITED
MICHELIN HOUSE
81 FULHAM ROAD
LONDON
UNITED KINGDOM
SW3 6RD
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.