Growing Wealth by Avoiding Fragility

Privacy Policy and Data Protection Notice

Emmoni Capital Limited (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.

Last updated: 28/08/2026

1. Who we are

This Privacy Policy explains how Emmoni Capital Limited (“Emmoni”, “we”, “us”) collects and processes personal data through emmonicapital.com (the “Site”) and in the course of our business. Emmoni is the data controller for the purposes of the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Acts 1988–2018.

Our contact details: Emmoni Capital Limited, Block 3, Harcourt Centre, Harcourt Terrace, Dublin D02 A339, Ireland; info <at> emmonicapital.com.

This policy should be read together with our Terms of Use and Cookie Declaration.

2. The personal data we collect

Site visitors. When you visit the Site, our web server automatically records technical information, including your IP address, browser type, and the pages you visit, in standard server logs maintained by our hosting provider for security and operational purposes. The Site sets only strictly necessary cookies, described in our Cookie Declaration. We do not use analytics, advertising or tracking technologies.

Enquiries. If you contact us through the Site’s contact form or by email, we collect the information you provide: your name, email address and the content of your message.

Registered users. If you apply for access to the Downloads area, we collect your name, email address and any information you provide in support of your registration, together with records of your account and login activity. Registrations are reviewed and approved manually.

Investors and prospective investors. If you invest, or take steps to invest, in a fund managed by Emmoni, we collect the information required to process and administer your investment, including identity, contact, tax and bank details and documentation required under anti-money laundering and counter-terrorist financing law. Much of this information is collected and processed through the fund’s subscription documents and its administrator, and is described further in the data protection notice accompanying those documents. 

We do not knowingly collect personal data from children, and the Site is not directed at them.

3. Why we process your data, and on what legal basis

We process personal data for the following purposes:

  • To operate and secure the Site — maintaining server logs, preventing abuse and unauthorised access, and remembering your jurisdiction selection. Legal basis: our legitimate interests in operating a secure and functional website.
  • To respond to enquiries. Legal basis: our legitimate interests in communicating with people who contact us; where your enquiry relates to entering into an investment, steps taken at your request prior to entering into a contract.
  • To assess and administer access to the Investor Materials area, including verifying that applicants are persons to whom the materials may lawfully be made available. Legal basis: our legitimate interests in restricting access to eligible recipients, and compliance with our legal obligations under securities laws.
  • To administer investments and comply with law — including anti-money laundering, counter-terrorist financing, tax reporting (such as FATCA and CRS) and regulatory obligations to the Central Bank of Ireland. Legal basis: compliance with legal obligations; performance of a contract.
  • To exercise or defend legal claims. Legal basis: our legitimate interests.

We do not use your personal data for marketing without your consent, we do not sell personal data, and we do not carry out automated decision-making or profiling that produces legal or similarly significant effects.

4. Who we share your data with

We share personal data only as needed with:

  • Service providers acting on our behalf, including our website hosting provider [hosting provider name, location], IT support providers, and the fund’s administrator, depositary/custodian, auditors, legal and tax advisers;
  • Regulatory and public authorities, including the Central Bank of Ireland, the Revenue Commissioners and tax authorities in other jurisdictions, where we are legally required or empowered to do so;
  • Courts, law enforcement and professional advisers where necessary to comply with law or to establish, exercise or defend legal claims.

We require service providers processing personal data on our behalf to do so only on our instructions and under appropriate contractual safeguards.

5. International transfers

Personal data is stored and processed [in the European Economic Area / describe actual hosting location]. Where personal data is transferred outside the EEA — for example to service providers or authorities in the United States — we ensure an appropriate safeguard is in place, such as an adequacy decision of the European Commission or the European Commission’s Standard Contractual Clauses, unless a legal derogation applies. [Confirm hosting location and any US service providers before publishing.]

6. How long we keep your data

We keep personal data only as long as necessary for the purposes described above:

  • Server logs and technical data: retained by our hosting provider for a short rolling period.
  • Enquiries: for as long as needed to deal with your enquiry and for a reasonable period afterwards.
  • Downloads accounts: for the life of the account and a reasonable period after closure.
  • Investor records: for the periods required by anti-money laundering, tax and company law, which generally require retention for a number of years after the end of the investor relationship.

7. Your rights

Subject to the conditions and exemptions in data protection law, you have the right to: access your personal data; have inaccurate data rectified; have data erased; restrict processing; receive your data in a portable format; and object to processing carried out on the basis of our legitimate interests. Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at [contact email]. We will respond within the timeframes required by law. You also have the right to lodge a complaint with the Data Protection Commission (dataprotection.ie) or with the supervisory authority in the EU member state where you live or work.

8. Security

We apply appropriate technical and organisational measures to protect personal data, including encrypted connections to the Site (HTTPS), access controls on the Investor Materials area, and restriction of access to personal data to those who need it. No transmission over the internet is completely secure, and transmission of information to the Site is at your own risk.

9. Changes to this policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised “last updated” date. If we make material changes to how we process investor data, we will notify affected investors directly.

10. Contact

Questions about this policy or our processing of personal data should be sent to info <at> emmonicapital.com or to Emmoni Capital Limited, Block 3, Harcourt Centre, Harcourt Terrace, Dublin D02 A339, Ireland.