Privacy Policy
Last Updated: January 2025
Duchas Group Ltd. (Company Number: 16774558, registered office: 1 Kings Avenue, London, N21 3NA ) ("Duchas," "we," "us," or "our") is committed to protecting and respecting your privacy in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and applicable international data protection laws.
1. Data Controller
Duchas Group Ltd. is the data controller responsible for your personal data. For data protection queries, contact our Data Protection Officer at: info@duchasgroup.com
2. Information We Collect
We collect and process the following categories of personal data:
- Identity Data: Name, title, business affiliations
- Contact Data: Email address, telephone numbers, business address
- Professional Data: Fund information, AUM range, investment strategy, company details
- Technical Data: IP address, browser type, device information, time zone settings, location data, operating system
- Usage Data: Information about how you use our website and services
- Marketing and Communications Data: Your preferences for receiving marketing communications and your communication preferences
3. Legal Basis for Processing
We process personal data under the following lawful bases:
- Legitimate Interests: To operate and improve our business, respond to inquiries, and provide administrative support services (Article 6(1)(f) UK GDPR)
- Consent: For marketing communications and non-essential cookies (Article 6(1)(a) UK GDPR)
- Contract Performance: To fulfill our contractual obligations to clients (Article 6(1)(b) UK GDPR)
- Legal Obligation: To comply with applicable laws and regulations (Article 6(1)(c) UK GDPR)
4. How We Use Your Information
We use your personal data only for specified, explicit, and legitimate purposes:
- To provide information about our administrative coordination services
- To respond to consultation requests and provide customer support
- To coordinate with third-party licensed professionals on your behalf
- To send service updates and administrative communications
- To comply with legal and regulatory obligations
- To improve our website functionality and user experience
- To send marketing communications (with your explicit consent only)
- To conduct analytics and measure website performance
- To recommend appropriate service levels based on your fund structure and needs
- To identify appropriate jurisdictions and corresponding service providers for your fund
- To coordinate the drafting of agreements and disclosures tailored to your planned fund structure
- To coordinate the completion of regulatory filings required for your fund launch
5. Cookies and Tracking Technologies
This website uses cookies and similar tracking technologies, including Meta Pixel. We implement a two-tier cookie system:
- Essential Cookies: Strictly necessary for website operation (no consent required)
- Analytics and Marketing Cookies: Used only after you provide explicit consent via our cookie banner
You may withdraw cookie consent at any time by clearing your browser cookies or contacting us. Note that disabling essential cookies may affect website functionality.
6. Data Retention
We retain personal data only as long as necessary for the purposes stated or as required by law:
- Consultation Inquiries: 3 years from last contact
- Client Data: Duration of business relationship plus 7 years
- Marketing Data: Until consent is withdrawn or 2 years of inactivity
- Marketing/Cookie Data: Maximum 13 months
Clarification of Terms: 'Marketing materials' refers to promotional content and documents we create (retained for duration of use plus 7 years), while 'Marketing data' referred to in our Privacy Policy means your personal marketing preferences and consent records (retained until consent withdrawn or 2 years of inactivity).
After retention periods expire, we securely delete or anonymize personal data.
7. Data Sharing and Third-Party Disclosure
We do not sell, rent, or trade personal data. We share data only in the following circumstances:
- Service Providers: Trusted third parties who assist with website hosting, email delivery, analytics, and CRM services under strict data processing agreements
- Professional Partners: Licensed attorneys, compliance consultants, and other professionals (with your explicit consent)
- Legal Requirements: When required by law, court order, or governmental authority
- Business Transfers: In connection with any merger, sale, or acquisition (with notification to affected individuals)
All third-party processors are contractually obligated to protect your data in accordance with UK GDPR requirements.
8. International Data Transfers
Some of our service providers are located outside the United Kingdom and European Economic Area. When transferring data internationally, we ensure appropriate safeguards are in place, including:
- Standard Contractual Clauses approved by the UK Information Commissioner's Office
- Adequacy decisions confirming equivalent data protection standards
- Binding Corporate Rules or other approved transfer mechanisms
9. Your Data Protection Rights
Under UK GDPR and Data Protection Act 2018, you have the following rights:
- Right of Access: Request copies of your personal data
- Right to Rectification: Correct inaccurate or incomplete personal data
- Right to Erasure: Request deletion of personal data under certain circumstances
- Right to Restrict Processing: Request limitation of processing in certain situations
- Right to Data Portability: Receive personal data in a structured, machine-readable format
- Right to Object: Object to processing based on legitimate interests or for direct marketing
- Right to Withdraw Consent: Withdraw consent at any time (where processing is based on consent)
- Right to Lodge a Complaint: File a complaint with the Information Commissioner's Office (ICO)
To exercise any of these rights, contact us at info@duchasgroup.com. We will respond within one month of receiving your request.
10. Data Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction, including:
- SSL/TLS encryption for data transmission
- Secure server infrastructure with restricted access
- Regular security assessments and updates
- Staff training on data protection obligations
- Incident response procedures
11. Children's Privacy
Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, contact us immediately.
12. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. Material changes will be communicated through prominent website notice or direct communication. Continued use of our services after changes constitutes acceptance of the updated policy.
13. Contact Information and Complaints
Data Protection Officer:
Duchas Group Ltd.
Email: info@duchasgroup.com
Address: 1 Kings Avenue, London, N21 3NA
Supervisory Authority:
If you believe your data protection rights have been violated, you may lodge a complaint with the Information Commissioner's Office (ICO):
Website: https://ico.org.uk
Telephone: 0303 123 1113
Terms of Service
Last Updated: January 2025
These Terms of Service ("Terms") constitute a legally binding agreement between you ("Client," "you," or "your") and Duchas Group Ltd., Company Number 16774558, registered office at 1 Kings Avenue, London, N21 3NA ("Duchas," "we," "us," or "our"). By accessing or using our website or services, you acknowledge that you have read, understood, and agree to be bound by these Terms.
1. Definitions and Interpretation
In these Terms, unless the context otherwise requires:
- "Administrative Services" means non-regulated operational coordination and support services provided by Duchas
- "Licensed Professionals" means independent third-party attorneys, compliance consultants, and other regulated professionals
- "Regulated Activities" means investment advice, portfolio management, legal services, and other activities requiring regulatory authorization
- "Services" means the administrative coordination services described on our website
- "Website" means duchasgroup.com and all associated pages and subdomains
2. Scope of Services
2.1 Non-Regulated Services: Duchas provides administrative coordination and operational support services only. We do NOT provide, and are NOT authorized to provide:
- Investment advice or portfolio management services
- Legal services or legal advice
- Regulated compliance or Chief Compliance Officer (CCO) services
- Custody or safekeeping of client assets
- Financial planning or tax advice
- Any other regulated financial services
2.2 Third-Party Professionals: All Regulated Activities are performed exclusively by independent Licensed Professionals who maintain appropriate licenses, registrations, and professional liability insurance. Duchas serves solely as an administrative coordinator and is not responsible for the advice, services, or actions of Licensed Professionals.
2.3 No Attorney-Client Relationship: No attorney-client, investment adviser-client, or other fiduciary relationship exists between you and Duchas. Such relationships exist only between you and the respective Licensed Professionals you engage.
3. Regulatory Status and Disclaimers
3.1 Regulatory Authorization: Duchas Group Ltd. is NOT:
- Registered with the U.S. Securities and Exchange Commission (SEC) as an investment adviser
- Registered with any U.S. state securities regulator
- Authorized or regulated by the UK Financial Conduct Authority (FCA)
- Authorized or regulated by any other financial regulatory authority
- A member of any self-regulatory organization
3.2 No Investment Advice: Nothing on this Website or in our Services constitutes investment advice, portfolio management advice, financial advice, legal advice, tax advice, or any form of professional advice requiring regulatory authorization. All content is for general informational purposes only.
3.3 No Offer or Solicitation: Nothing on this Website constitutes an offer to sell, a solicitation to buy, or a recommendation of any security or investment product. No content should be construed as an offer or solicitation in any jurisdiction where such offer or solicitation would be unlawful.
4. Eligibility and Acceptable Use
4.1 Eligibility: Our Services are available only to:
- Investment managers and fund operators, primarily in the United States and select international jurisdictions
- Individuals who are at least 18 years of age
- Entities with legal capacity to enter into binding agreements
- Persons who are not prohibited by applicable law from accessing our Services
4.2 Geographic Restrictions: Our Services are primarily designed for U.S.-based managers, though we may serve international clients where legally permissible. We do not provide services to individual investors seeking investment opportunities.
4.3 Prohibited Uses: You agree not to:
- Use our Services for any unlawful purpose or in violation of applicable laws
- Misrepresent your identity, affiliation, or qualifications
- Attempt to gain unauthorized access to our systems or networks
- Interfere with or disrupt the operation of the Website
- Transmit viruses, malware, or other harmful code
- Engage in any fraudulent, deceptive, or manipulative activity
- Violate any intellectual property rights
5. Client Responsibilities and Representations
5.1 Independent Judgment: You acknowledge and agree that:
- You are solely responsible for evaluating and selecting Licensed Professionals
- You must conduct your own due diligence on all service providers
- You will make all business and investment decisions independently
- You understand the risks associated with fund management and operations
5.2 Regulatory Compliance: You represent and warrant that you will:
- Comply with all applicable securities laws and regulations
- Obtain all necessary licenses, registrations, and regulatory approvals
- Engage qualified Licensed Professionals for all Regulated Activities
- Not rely on Duchas for legal, compliance, or investment advice
5.3 Information Accuracy: You agree to provide accurate, complete, and current information and to promptly update any information that changes.
6. Intellectual Property Rights
6.1 Ownership: All content, materials, trademarks, logos, service marks, trade names, and intellectual property on the Website are owned by or licensed to Duchas Group Ltd. and are protected by UK and international copyright, trademark, and other intellectual property laws.
6.2 Limited License: We grant you a limited, non-exclusive, non-transferable, revocable license to access and use the Website for your personal, non-commercial use. You may not:
- Reproduce, distribute, modify, or create derivative works
- Reverse engineer, decompile, or disassemble any Website components
- Remove or alter any copyright, trademark, or proprietary notices
- Use our content for commercial purposes without written permission
7. Disclaimers and Limitations of Liability
7.1 "AS IS" Basis: THE WEBSITE AND SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.
7.2 No Warranties: Duchas makes no representations or warranties regarding:
- The accuracy, completeness, or reliability of Website content
- The quality, suitability, or performance of Licensed Professionals
- Investment outcomes, fund performance, or regulatory compliance
- Uninterrupted or error-free operation of the Website
- Security of data transmission over the internet
7.3 Limitation of Liability: TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, DUCHAS GROUP LTD., ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, AND AFFILIATES SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO DAMAGES FOR LOSS OF PROFITS, REVENUE, DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES, ARISING FROM OR RELATED TO YOUR USE OF THE WEBSITE OR SERVICES, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
7.4 Liability Cap: In no event shall Duchas's total aggregate liability to you exceed the lesser of (a) the amounts actually paid by you to Duchas in the twelve (12) months preceding the claim, or (b) $25,000 USD.
7.5 Third-Party Liability: Duchas is not responsible or liable for the acts, omissions, errors, representations, warranties, breaches, or negligence of any Licensed Professionals or third-party service providers, or for any personal injuries, death, property damage, or other damages or expenses resulting therefrom.
8. Indemnification
You agree to indemnify, defend, and hold harmless Duchas Group Ltd., its directors, officers, employees, agents, affiliates, and Licensed Professionals from and against any and all claims, liabilities, damages, losses, costs, expenses (including reasonable attorneys' fees), arising from or related to:
- Your use or misuse of the Website or Services
- Your violation of these Terms
- Your violation of any applicable law or regulation
- Your violation of any third-party rights
- Any information or content you provide
9. Links to Third-Party Websites
The Website may contain links to third-party websites or services that are not owned or controlled by Duchas. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites. You acknowledge and agree that Duchas shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods, or services available on or through any such websites.
10. Termination
10.1 Right to Terminate: We reserve the right to suspend or terminate your access to the Website or Services at any time, with or without cause, with or without notice, for any reason including breach of these Terms.
10.2 Effect of Termination: Upon termination, your right to use the Website and Services will immediately cease. Sections of these Terms that by their nature should survive termination shall survive, including but not limited to disclaimers, limitations of liability, and indemnification provisions.
11. Dispute Resolution and Governing Law
11.1 Governing Law: These Terms shall be governed by and construed in accordance with the laws of England and Wales, without regard to conflict of law principles.
11.2 Jurisdiction: Subject to Section 11.3 below, you agree that any dispute arising from or relating to these Terms or your use of the Website shall be subject to the exclusive jurisdiction of the courts of England and Wales.
11.3 Arbitration (Optional): The parties may mutually agree to submit disputes to binding arbitration under the rules of the London Court of International Arbitration (LCIA).
12. Changes to Terms
We reserve the right to modify or replace these Terms at any time at our sole discretion. Material changes will be communicated through prominent Website notice or direct communication. Your continued use of the Website following the posting of changes constitutes acceptance of those changes. If you do not agree to the modified Terms, you must discontinue use of the Website and Services.
13. Severability and Waiver
13.1 Severability: If any provision of these Terms is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary, and the remaining provisions shall remain in full force and effect.
13.2 Waiver: No waiver of any term of these Terms shall be deemed a further or continuing waiver of such term or any other term, and a party's failure to assert any right or provision under these Terms shall not constitute a waiver of such right or provision.
14. Entire Agreement
These Terms, together with our Privacy Policy and any other legal notices published by Duchas on the Website, constitute the entire agreement between you and Duchas concerning the Website and Services and supersede all prior or contemporaneous communications and proposals, whether oral or written.
15. Contact Information
For questions about these Terms, please contact:
Duchas Group Ltd.
Company Number: 16774558
Registered Office: 1 Kings Avenue, London, N21 3NA
Email: info@duchasgroup.com
Regulatory Compliance Statement
Last Updated: January 2025
Note: Capitalized terms used but not defined herein shall have the meanings assigned to them in our Terms of Service.
This Regulatory Compliance Statement provides important information about the regulatory status, business activities, and compliance framework of Duchas Group Ltd. ("Duchas"). All prospective clients should carefully review this Statement before engaging our services.
1. Company Information
Legal Entity: Duchas Group Ltd.
Company Number: 16774558
Registered Office: 1 Kings Avenue, London, N21 3NA
Country of Incorporation: United Kingdom
Business Type: Private Limited Company
2. Regulatory Status
2.1 UK Regulatory Status:
- Duchas Group Ltd. is NOT authorized or regulated by the Financial Conduct Authority (FCA)
- We do NOT hold any FCA permissions or authorizations
- We are NOT registered to conduct any regulated activities under the Financial Services and Markets Act 2000 (FSMA)
- We do NOT appear on the FCA's Financial Services Register
2.2 U.S. Regulatory Status:
- Duchas is NOT registered with the U.S. Securities and Exchange Commission (SEC) as an investment adviser under the Investment Advisers Act of 1940
- We are NOT registered with any U.S. state securities regulator
- We are NOT registered as a broker-dealer with the SEC or Financial Industry Regulatory Authority (FINRA)
- We do NOT hold any SEC, state, or FINRA registrations or licenses
- We are NOT subject to SEC examination or oversight
2.3 Other Jurisdictions:
- Duchas is NOT authorized or regulated by any financial regulatory authority in any jurisdiction
- We do NOT hold any regulatory licenses or permissions for financial services
3. Scope of Non-Regulated Business Activities
3.1 Permitted Activities: Duchas provides the following non-regulated administrative and operational coordination services:
- Administrative Coordination: Project management and coordination of fund formation and operational activities
- Vendor Liaison: Facilitating introductions to and coordination with Licensed Professionals
- Marketing Support: Website development, presentation design, and marketing materials creation (subject to compliance review by client's counsel)
- Operational Support: Process documentation, workflow optimization, and administrative assistance
- Technology Coordination: Website hosting, portal management, and technology vendor coordination
3.2 Explicitly Prohibited Activities: Duchas does NOT and will NOT:
- Investment Advisory Services: Provide investment advice, portfolio management, or investment recommendations of any kind
- Trading or Execution: Execute trades, manage portfolios, or make investment decisions
- Legal Services: Provide legal advice, draft legal documents, or represent clients before regulatory authorities
- Compliance Services: Serve as Chief Compliance Officer (CCO), file regulatory reports, or provide compliance advice
- Custody or Safekeeping: Hold, custody, or safeguard client assets or funds
- Tax Services: Provide tax advice, prepare tax returns, or render tax opinions
- Accounting Services: Provide accounting advice or prepare financial statements
- Fund Administration: Calculate NAV, process subscriptions/redemptions, or maintain investor records
- Brokerage Services: Effect securities transactions or hold customer funds or securities
4. Role of Licensed Professionals
4.1 Independent Third Parties: All Regulated Activities are performed exclusively by independent Licensed Professionals who are:
- Properly licensed, registered, or authorized by appropriate regulatory authorities
- Subject to regulatory oversight and examination
- Covered by professional liability insurance
- Operating independently of Duchas
- Directly engaged and compensated by clients
4.2 Categories of Licensed Professionals:
- Securities Attorneys: Licensed attorneys specializing in investment fund formation and securities regulation
- Compliance Consultants: Registered compliance professionals and Chief Compliance Officers
- Fund Administrators: Registered fund administration firms
- Auditors: Licensed public accounting firms
- Other Professionals: As required based on fund structure and regulatory requirements
4.3 No Agency or Fiduciary Relationship: Duchas does not act as agent, representative, or fiduciary for any Licensed Professional. Duchas receives no referral fees, commissions, or compensation from Licensed Professionals for client referrals.
5. Client Responsibilities
5.1 Regulatory Obligations: Clients are solely responsible for:
- Determining applicable regulatory requirements for their activities
- Obtaining all necessary licenses, registrations, and regulatory approvals
- Complying with all applicable securities laws and regulations
- Filing all required regulatory reports and submissions
- Maintaining compliance with ongoing regulatory obligations
- Engaging qualified Licensed Professionals for all Regulated Activities
5.2 Due Diligence: Clients must conduct their own due diligence on all Licensed Professionals, including verification of:
- Regulatory licenses, registrations, and authorizations
- Professional qualifications and experience
- Disciplinary history and regulatory standing
- Professional liability insurance coverage
- References and track record
5.3 Independent Decision-Making: Clients acknowledge that all business and investment decisions are made independently and are not influenced, directed, or controlled by Duchas.
6. Data Protection Compliance
Duchas complies with all applicable data protection laws, including:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Privacy and Electronic Communications Regulations (PECR)
For details on our data processing activities, see our Privacy Policy. To exercise data protection rights, contact: info@duchasgroup.com
7. Anti-Money Laundering and Sanctions Compliance
7.1 AML Compliance: While Duchas is not subject to direct AML regulation, we maintain policies consistent with UK Money Laundering Regulations, including:
- Client identification and verification procedures
- Enhanced due diligence for higher-risk clients
- Monitoring for suspicious activity
- Record-keeping and documentation requirements
7.2 Sanctions Compliance: Duchas complies with all applicable UK and international sanctions regimes, including sanctions administered by:
- UK Office of Financial Sanctions Implementation (OFSI)
- U.S. Office of Foreign Assets Control (OFAC)
- United Nations Security Council
- European Union (where applicable)
8. Disclaimers and Risk Warnings
8.1 No Guarantees or Warranties: Duchas makes no representations, warranties, or guarantees regarding:
- Investment performance or outcomes
- Regulatory approval or compliance status
- The quality, suitability, or performance of Licensed Professionals
- Successful fund formation or fundraising
- The accuracy or completeness of any information provided
8.2 Investment Risks: All investments involve substantial risk of loss. Past performance is not indicative of future results. Clients should carefully consider investment objectives, risks, charges, and expenses before investing. Consult with qualified financial, legal, and tax advisers before making investment decisions.
8.3 Regulatory Changes: Securities laws and regulations are subject to change. Clients are responsible for monitoring regulatory developments and ensuring ongoing compliance with current requirements.
9. Conflicts of Interest
9.1 Disclosure: Duchas maintains policies to identify and manage potential conflicts of interest, including:
- Disclosure of business relationships with service providers
- Prohibition on undisclosed referral fees or commissions
- Fair treatment of all clients
- Confidentiality of client information
9.2 No Proprietary Trading: Duchas does not trade securities, manage investments, or maintain proprietary trading accounts.
10. Record Retention
Duchas maintains business records in accordance with UK Companies Act requirements and industry best practices, including:
- Client agreements and engagement letters: 7 years
- Financial records: 7 years
- Correspondence and communications: 7 years
- Marketing materials (our created promotional content): Duration of use plus 7 years
11. Complaints and Dispute Resolution
11.1 Complaints Procedure: If you have a complaint about our services, please contact us in writing at info@duchasgroup.com. We will acknowledge your complaint within 5 business days and provide a substantive response within 30 days.
11.2 Alternative Dispute Resolution: As Duchas is not FCA-regulated, we are not required to participate in the Financial Ombudsman Service. However, disputes may be resolved through:
- Direct negotiation
- Mediation through an independent mediator
- Arbitration under LCIA rules (if mutually agreed)
- Litigation in the courts of England and Wales
12. Professional Indemnity Insurance
While not required by regulation, Duchas maintains professional indemnity insurance appropriate to the nature and scale of our business activities.
13. Regulatory Monitoring and Updates
Duchas actively monitors regulatory developments affecting our business and client activities. This Compliance Statement may be updated periodically to reflect changes in applicable laws, regulations, or business practices. Material changes will be communicated to clients.
14. Verification of Regulatory Status
Prospective clients can verify the regulatory status of investment advisers and other financial professionals through:
15. Contact Information
For regulatory compliance questions or concerns:
Duchas Group Ltd.
Company Number: 16774558
Registered Office: 1 Kings Avenue, London, N21 3NA
Compliance Email: info@duchasgroup.com
General Inquiries: info@duchasgroup.com
Important Notice: This Regulatory Compliance Statement is provided for informational purposes only and does not constitute legal, financial, or regulatory advice. Prospective clients should consult with qualified legal counsel and compliance professionals to understand their specific regulatory obligations and requirements.