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Website Accessibility

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At Devenir Capital Ltd., we care about being accessible and inclusive of everyone. That’s why we’ve built our website with as few barriers to information as possible. It’s designed to be usable across devices, for users with differing abilities.
For more information, please feel free to contact us.

Privacy & Security

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This Privacy Policy describes the practices of Devenir Capital Ltd. In connection with information that we collect through devenircapital.com (the “Website”), as well as through HTML formatted email messages that we send to you that link to this Privacy Policy (the “Emails” and together with the Website, the “Services”). We are concerned about privacy issues and want you to be familiar with how we collect, use and disclose information. By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

Certain sections or pages on this Website may contain separate terms and conditions (collectively, “Additional Privacy Terms”), which are in addition to this Privacy Policy. This Privacy Policy hereby incorporates by this reference any additional terms and conditions with respect to the Website that are made available by Devenir Capital Ltd. through the Website, or otherwise made available to you by Devenir Capital Ltd.. In the event of a conflict between this Privacy Policy and any Additional Privacy Terms, the Additional Privacy Terms will govern for those sections or pages governed by such Additional Privacy Terms. For the avoidance of doubt, this Privacy Policy does not govern your use of, and all references to the Website herein will be deemed to exclude, any websites other than the Website, including any Devenir Capital Ltd. “portals” or other sites that are not on the Website but that may be linked to or otherwise made available by the Website, which sites are governed by separate privacy terms and conditions available on such sites.

PERSONAL INFORMATION

Personal Information We May Collect

Personal Information” is information that identifies you as an individual or relates to an identifiable person, including your name, telephone number, postal address and email address.

How We May Collect Personal Information

We and our service providers may collect Personal Information in a variety of ways, including:

Through the Services: We may collect Personal Information through the Services, e.g., when you contact us or request more information about a service or product.

How We May Use Personal Information

We may use Personal Information:

To respond to your inquiries and fulfill your requests, such as to respond to your requests for additional information about our products or services.

To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions and policies.

To send you marketing communications that we believe may be of interest to you.

To personalize your experience on the Services by presenting products and offers tailored to you.

For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

As we believe to be necessary or appropriate:

• under applicable law, including laws outside your country of residence;
• to comply with legal process;
• to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
• to enforce our terms and conditions;
• to protect our operations or those of any of our affiliates;
• to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
• to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

To our affiliates for the purposes described in this Privacy Policy.

To our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.

To third parties, to permit them to send you marketing communications, consistent with your choices.

To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

As we believe to be necessary or appropriate:

• under applicable law, including laws outside your country of residence;
• to comply with legal process;
• to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
• to enforce our terms and conditions;
• to protect our operations or those of any of our affiliates;
• to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
• to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

Browser and device information

Information collected through cookies, pixel tags and other technologies
Demographic information and other information provided by you

Aggregated information

If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.

Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services and to recognize your computer in order to assist your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies to track responses to our online advertisements.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.

IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.

Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

From you: Information such as your preferred means of communication is collected when you voluntarily provide it.

By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information (such as combining your name with your location). If we do, we will treat the combined information as Personal Information as long as it is combined.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure, but there are steps you can take to protect your Personal Information.

Ensure you are on the right site: Check that you are on the real Devenir capital Ltd. website before you sign in by checking the browser bar for a valid certificate.

Monitor your account activity: Checking your account activity frequently can help to prevent or detect fraud earlier.

Password management: Use passwords that are long in length and complex in nature. Complexity is achieved by using a combination of upper and lower case letters, numbers, and special characters. A passphrase of longer length adds more complexity to a password. Do not reuse passwords across accounts or websites, or share your password with anyone. Devenir Capital Ltd. will never ask for your password.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the instructions at the bottom of each email or contacting us.

Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we not share your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by contacting us.

Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes: If you would prefer that we not share your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt-out of this sharing by contacting us.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Information through the Services.

CROSS-BORDER TRANSFER

The Services are controlled and operated by us from Mauritius and are not intended to subject us to the laws or jurisdiction of any country or territory. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

SENSITIVE INFORMATION

Unless we reach out to you and specifically request certain information from you, which we may do on occasion, including, for example, in order to comply with applicable law or regulation, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, credit card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or criminal background).

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us.

Terms & Conditions

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PLEASE READ THESE TERMS OF SERVICE CAREFULLY. Your use of the Site (as defined below) constitutes your consent to this Agreement (as defined below).

BY USING THE SITE, YOU AFFIRM THAT YOU ARE OF LEGAL AGE TO ENTER INTO THIS AGREEMENT.

IF YOU ARE AN INDIVIDUAL ACCESSING OR USING THE SITE ON BEHALF OF, OR FOR THE BENEFIT OF, ANY CORPORATION, PARTNERSHIP OR OTHER ENTITY WITH WHICH YOU ARE ASSOCIATED (AN “ORGANIZATION”), YOU REPRESENT AND WARRANT THAT YOU HAVE THE LEGAL AUTHORITY TO BIND SUCH ORGANIZATION TO THIS AGREEMENT; IF YOU DO NOT HAVE SUCH LEGAL AUTHORITY, SUCH ORGANIZATION WILL NOT ACCESS, USE OR OTHERWISE BENEFIT FROM THE SITE. References to “you” and “your” in this Agreement will refer to both the individual using the Site and any such Organization. 

IF YOU DO NOT AGREE TO THIS AGREEMENT, INCLUDING THE TERMS AND CONDITIONS BELOW, DO NOT ACCESS THIS SITE, OR ANY PAGES THEREOF.

The information contained in this Site is for informational purposes only, and does not constitute a solicitation, an offer, or a recommendation to buy or sell any investment instruments, to effect any transactions, or to conclude any legal act of any kind whatsoever. Unauthorized use of the Site and Devenir Capitals systems, including but not limited to unauthorized entry into Devenir Capital Ltd. systems, misuse of passwords or misuse of any information posted on the Site is strictly prohibited. We do not, and does not intend to, provide investment, legal, audit or tax advice through or in connection with this Site, and does not represent that any investments, securities or services discussed on this Site are suitable for any investor. Investments and investment strategies discussed on this Site may not be suitable for you.  You should weigh any investment decision carefully after considering your specific investment objectives and financial circumstances.  When making a decision about your investments, you should also seek the advice of a professional financial advisor. 

1. Changes. We may change this Agreement from time to time by notifying you of such changes by any reasonable means, including by posting a revised Agreement through the Site. Any such changes will not apply to any dispute between you and us arising prior to the date on which we post the revised Agreement incorporating such changes, or otherwise notify you of such changes.Your use of the Site following any changes to this Agreement will constitute your acceptance of such changes. The information and materials made available by the Site, and the terms, conditions and descriptions that appear on the Site, are subject to change. We may, at any time and without liability, modify or discontinue all or part of the Site (including access to the Site via any third-party links); charge, modify or waive any fees required to use the Site; or offer opportunities to some or all Site users.

2. Information Submitted Through the Site. Your submission of information through the Site is governed by the Site’s Privacy Policy.  You represent and warrant that any information you provide in connection with the Site is and will remain accurate and complete, and that you will maintain and update such information as needed.  We may use and rely on the information that you provide in connection with the Site without independent verification thereof.

3. Jurisdictional Issues. The Site is controlled or operated (or both) from Mauritius, and is not intended to subject Devenir Capital Ltd. to any non-Mauritius jurisdiction or law. Any use of in doing so. We may limit the Site’s availability at any time, in whole or in part, to any person, geographic area or jurisdiction that we choose.

4. Rules of Conduct. In connection with the Site, you must not:

• Post, transmit or otherwise make available through or in connection with the Site any materials that are or may be:
  1. threatening, harassing, degrading, hateful or intimidating, or otherwise fail to respect the rights and dignity of others;
  2. defamatory, libelous, fraudulent or otherwise tortious;
  3. obscene, indecent, pornographic or otherwise objectionable;
  4. protected by copyright, trademark, trade secret, right of publicity or privacy or any other proprietary right, without the express prior written consent of the applicable owner; or
  5. material nonpublic information or otherwise confidential information with respect to which you are subject to contractual or fiduciary non-disclosure obligations.
• Post, transmit or otherwise make available through or in connection with the Site any virus, worm, Trojan horse, Easter egg, time bomb, spyware or other computer code, file or program that is or is potentially harmful or invasive or intended to damage, disable or hijack the operation of, or to monitor the use of, any hardware, software or equipment (each, a “Virus”).
• Use the Site for any purpose that is fraudulent or otherwise tortious or unlawful.
• Harvest or collect information about users of the Site.
• Use the Site for any commercial solicitation purposes, or transmit through or in connection with the Site any spam, chain letters or other unsolicited communications.
• Interfere with or disrupt the operation of the Site or the servers or networks used to make the Site available, including by hacking or defacing any portion of the Site; disable or erase software, hardware or data used for the operation of the Site; or violate any requirement, procedure or policy of such servers or networks.
• Restrict or inhibit any other person from using the Site or provide unauthorized access to the Site.
• Reproduce, modify, adapt, translate, create derivative works of, sell, rent, lease, loan, timeshare, distribute or otherwise exploit any portion of (or any use of) the Site except as expressly authorized herein, without Devenir Capital Ltd. express prior written consent.
• Reverse engineer, decompile or disassemble any portion of the Site, except where such restriction is expressly prohibited by applicable law.
• Remove any copyright, trademark or other proprietary rights notice from the Site.
• Frame or mirror any portion of the Site, or otherwise incorporate any portion of the Site into any product or service, without Devenir Capital ltd. express prior written consent.
• Systematically download and store Site content.
• Use any robot, spider, site search/retrieval application or other manual or automatic device to retrieve, index, “scrape,” “data mine” or otherwise gather Site content, or reproduce or circumvent the navigational structure or presentation of the Site, without Devenir capital’s Ltd.express prior written consent. Notwithstanding the foregoing, and subject to compliance with any instructions posted in the robots.txt file located in the Site’s root directory, Devenir Capital Ltd. grants to the operators of public search engines permission to use spiders to copy materials from the Site for the sole purpose of (and solely to the extent necessary for) creating publicly available, searchable indices of such materials, but not caches or archives of such materials. Devenir Capital Ltd. reserves the right to revoke such permission either generally or in specific cases, at any time and without notice. You are responsible for obtaining, maintaining and paying for all hardware and all telecommunications and other services needed for you to use the Site.

5. Resources. The Site may make available information, data, materials, services, products, merchandise, functionality or other resources (collectively, “Resources”), as well as references and links to such Resources. Resources may be made available by Devenir Capital Ltd. or by third parties, and may be made available for any purpose, including for general information purposes. We make no representations as to the accuracy, validity, timeliness, completeness, reliability, integrity, quality, legality, usefulness, appropriateness or safety of any Resources, or any intellectual property rights therein. By creating a link to a third party website, Devenir Capital Ltd. does not endorse or recommend any products or services offered or information contained at that website. Resources, and the availability of Resources, are subject to change at any time without notice. We disclaim all liability and responsibility arising from any reliance placed on any Resources by you or any other user of the Site, or by anyone who may be informed of the content of any Resources. It is your responsibility to ascertain and obey all applicable local, state, federal and foreign laws regarding the use, possession or acquisition of any Resources.

6. Licenses Granted to Us.Certain Site functionality may provide users with the ability to make available certain information, data, materials or other resources (each, a “Submission”) through or in connection with the Site. For purposes of clarity, you retain ownership of each Submission that you make available through or in connection with the Site (each, “Your Submission”).  You hereby grant to us a worldwide, royalty-free, fully paid-up, non-exclusive, perpetual, irrevocable, transferable and fully sub licensable (through multiple tiers) license, without additional consideration to you or any third party, to reproduce, distribute, perform and display (publicly or otherwise), create derivative works of, adapt, modify and otherwise use, analyze and exploit Your Submissions, in any format or media now known or hereafter developed, and for any purpose (including promotional purposes, such as testimonials).

In addition, if you provide to us any ideas, proposals, suggestions, concepts, know-how, techniques or other materials (“Feedback”), whether related to the Site or otherwise, such Feedback will be deemed Your Submission, and you hereby acknowledge and agree that such Feedback is not confidential, and that your provision of such Feedback is gratuitous, unsolicited and without restriction for any purpose, and does not place Devenir Capital Ltd. under any fiduciary or other obligation. Without limiting the foregoing, Devenir Capital Ltd. will not be subject to any obligations of confidentiality regarding any information that you provide to us except as otherwise specifically agreed in writing by Devenir Capital Ltd. or required by law.

You represent and warrant that

• you have all rights necessary to grant the licenses granted in this section;
• Your Submissions are complete and accurate; and
• Your Submissions and your provision thereof to us (whether through or in connection with the Site or otherwise) are not fraudulent, tortious or otherwise in violation of any applicable law or any right of any third party. You further irrevocably waive any “moral rights” or other rights with respect to attribution of authorship or integrity of materials regarding each Submission that you may have under any applicable law under any legal theory.

7. Monitoring. We may (but have no obligation to) monitor and/or analyze Your Submissions or your access to or use of the Site. We may disclose information regarding your access to and use of the Site, and the circumstances surrounding such access and use, to anyone for any reason or purpose.

8. Your Limited Rights. Subject to your compliance with this Agreement, and solely for so long as you are permitted by Devenir Capital Ltd. to use the Site, you may view and use any portion of the Site to which we provide you access under this Agreement, solely in accordance with the functionality that we make available to you and solely for your personal, non-commercial use, or, if you are an Organization, solely for your internal business use.

9. DISCLAIMER OF WARRANTIES. While we seek to maintain the timeliness, integrity and security of the Site, we do not guarantee that the Site is or will remain updated, complete, correct or secure, or that access to the Site will be uninterrupted. The Site may include inaccuracies, errors and materials that violate or conflict with this Agreement. You agree that you will independently confirm any such information presented through the Site before relying on such information. Additionally, third parties may make unauthorized alterations to the Site. If you become aware of any such alteration, contact us with a description of such alteration and its location on the Site.

10. LIMITATION OF LIABILITY. Devenir Capital Ltd. will not be liable for any indirect, incidental, consequential, special, exemplary or punitive damages of any kind arising out of or in connection with the site or this agreement, under any contract, tort (including negligence), strict liability or other theory, including damages for loss of profits, use or data, loss of other intangibles, loss of security of submissions (including unauthorized interception by third parties of any submissions), even if advised in advance of the possibility of such damages or losses. without limiting the foregoing, Devenir Capital Ltd. will not be liable for damages of any kind resulting from your use of or inability to use the site (including any interruptions, defect or delays in your ability to use the site) or from any resources or third party resources, including from any virus or malicious code or other defect in the site or files that may be transmitted in connection therewith even if Devenir Capital Ltd. or representatives thereof are advised of the possibility of such damages, losses or expenses. your sole and exclusive remedy for dissatisfaction with the site or any resources or third party resources is to stop using the site.

11. Indemnity. Except to the extent prohibited under applicable law, you agree to defend, indemnify and hold harmless Devenir Capital Ltd. and their respective successors and assigns from and against all claims, liabilities, damages, judgments, awards, losses, costs, expenses and fees (including attorneys’ fees) arising out of or relating to

• (a) your use of, or activities in connection with, the Site (including Your Submissions); and
• (b) any violation or alleged violation of this Agreement by you.

12. Termination. This Agreement is effective until terminated. Devenir Capital Ltd. may terminate or suspend your use of the Site at any time and without prior notice, for any or no reason, including if Devenir Capital Ltd. believes that you have violated or acted inconsistently with the letter or spirit of this Agreement. Upon any such termination or suspension, your right to use the Site will immediately cease, and Devenir Capital Ltd. may, without liability to you or any third party, immediately delete Your Submissions, without any obligation to provide any further access to Your Submissions.

13. Governing Law;< Jurisdiction. This Agreement is governed by and shall be construed in accordance with the laws of FSC Mauritius.

14. Filtering. We hereby notify you that parental control protections (such as computer hardware, software or filtering services) are commercially available that may assist you in limiting access to material that is harmful to minors. Information identifying current providers of such protections is available from https://en.wikipedia.org/wiki/Comparison_of_content-control_software_and_providers. Please note that Devenir Capital Ltd. does not endorse the above website or any of the products or services listed on such site, such site is a Third Party Resource (and is subject to separate terms and conditions) and any use of such site is at your own risk.

15. Information or Complaints If you have a question or complaint regarding the Site, please contact us at our contact information.  Please note that e-mail communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your e-mail correspondence with us.

16. Miscellaneous. This Agreement does not, and shall not be construed to, create any partnership, joint venture, employer-employee, agency or franchisor-franchisee relationship between you and Devenir Capital Ltd. If any provision of this Agreement is found to be unlawful, void or for any reason unenforceable, that provision will be deemed severable from this Agreement and will not affect the validity and enforceability of any remaining provision. You may not assign, transfer or sublicense any or all of your rights or obligations under this Agreement without our express prior written consent. We may assign, transfer or sublicense any or all of our rights or obligations under this Agreement without restriction. No waiver by either party of any breach or default under this Agreement will be deemed to be a waiver of any preceding or subsequent breach or default. Any heading, caption or section title contained herein is for convenience only, and in no way defines or explains any section or provision. All terms defined in the singular shall have the same meanings when used in the plural, where appropriate and unless otherwise specified. Any use of the term “including” or variations thereof in this Agreement shall be construed as if followed by the phrase “without limitation.” This Agreement, including any terms and conditions incorporated herein, is the entire agreement between you and Devenir Capital Ltd. relating to the subject matter hereof, and supersedes any and all prior or contemporaneous written or oral agreements or understandings between you and Devenir Capital Ltd. relating to such subject matter. For clarity, nothing in this Agreement amends or modifies, or has any effect upon, the terms and conditions of any separate agreement that you may have entered into

• with Devenir Capital Ltd. that does not relate to the subject matter of this Agreement or
• with any third party. Notices to you (including notices of changes to this Agreement) may be made via posting to the Site or by e-mail (including in each case via links), or by regular mail. Without limitation, a printed version of this Agreement and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to this Agreement to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form. Devenir Capital Ltd. will not be responsible for any failure to fulfill any obligation due to any cause beyond its control.

General Disclosures and Disclaimers

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Information contained in this website is for informational purposes only and does not constitute a recommendation, offer, general solicitation or confirmation of terms. Investments and investment strategies discussed on this website may not be suitable for you.  You should weigh any investment decision carefully after considering your specific investment objectives and financial circumstances. Information contained in this website is based upon generally available information believed to be reliable, but no representation is made as to the accuracy, timeliness or completeness of such information or that any returns indicated will be achieved. Changes to assumptions may have a material impact on returns. Price/availability is subject to change without notice. Past performance is not indicative of future results.

The information contained in this website is not intended for distribution or use in any jurisdiction or country where such distribution or use would be contrary to local law or regulation. Representatives of Devenir Capital Ltd. may only conduct business in jurisdictions where they are licensed or exempt from the licensing requirements. Clients should contact a Devenir Capital representative in their home jurisdiction unless governing law permits otherwise.

Anti-Money Laundering Disclosures

Company Status with Regulators
Devenir Capital is a Mauritius FSC regulated GBL company.
Anti-Money Laundering Program

The policy of Devenir Capital Ltd. is to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets. The Devenir Capital Ltd., Anti-Money Laundering (“AML”) Program has been designed to comply with legal and regulatory requirements, by:

• Including procedures that can be reasonably expected to detect and cause the reporting of suspicious transactions and the implementing regulations thereunder;
• Providing for independent testing for compliance to be conducted by appropriate staff or by a qualified outside party;
• Designating individuals responsible for implementing and monitoring the day-to-day operation and internal controls of the AML Program; and,
• Providing for ongoing training of appropriate staff.

Customer Identification Program

In compliance with anti-money laundering requirements, Devenir Capital Ltd. has developed and implemented a Customer Identification Program (“CIP”) to identify and verify the identity of customers that open new accounts. The purpose of the CIP process is to ensure that Devenir Capital has taken reasonable efforts to determine the identity of its customers through documentary and or non-documentary means.

​​Order Handling and Trading Disclosures

FINRA Rule 5310 – Best Execution

In any equity transaction for a customer, Devenir Capital Ltd. will use reasonable care in seeking to obtain the most advantageous terms reasonably available under the circumstances for the execution of a customer’s order.  In determining where to send customers’ orders Devenir Capital Ltd. takes into consideration in, among other things, the size and type of order, the terms and instructions of the order, the trading characteristics of the security, the character of the market for the security, the accessibility of quotations, transaction costs, the opportunity for price or size improvement, the speed of execution, the availability of efficient and reliable order handling systems, the level of service provided by the market venue and the customer’s overall objectives with respect to the market conditions at the time of the order. Devenir Capital Ltd. regularly reviews transactions for quality of execution.

Extended Trading Hours

FINRA Rule 2265 requires that Devenir Capital disclose to you the following potential risks if you engage in equities transactions during extended trading hours (4:00pm – 9:29:59am Eastern Standard Time)

• Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular trading hours. As a result, your order may only be partially executed, or not at all.
• Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular trading hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price when engaging in extended hours trading than you would during regular trading hours.
• Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular trading hours, or upon the opening the next morning. As a result, you may receive an inferior price when engaging in extended hours trading than you would during regular trading hours.
• Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours trading system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.
• Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular trading hours. Similarly, important financial information is frequently announced outside of regular trading hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
• Risk of Wider Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security

Business Continuity Disclosure

Devenir Capital Ltd. has developed and implemented a Business Continuity Plan (“BCP”) designed to address and mitigate the potential consequences of a significant business disruption.

Our BCP is intended to permit the temporary continuation of the key parts of our business despite the occurrence of a significant business disruption with a goal of recovering the key aspects of our business within twenty four hours or less. Our BCP also is designed to safeguard employees, protect our books and records, and provide ready access for our clients to any securities and/or funds in the custody of our partnering bank depositories in the event that we are unable to achieve a timely recovery.

Our BCP tries to anticipate the various types of events that could interfere with our ability to operate on a normal basis. Staff have been assigned to specific recovery responsibilities and trained in special procedures to be followed should an event occur that could cause a disruption to occur. Devenir Capital Ltd. has deployed an overlapping communications triangle that connects three geographically diverse locations to ensure flexibility and redundancy in our ability to communicate internally and externally. All mission critical systems have been duplicated in each of our data centers with data backed up electronically on a near synchronized basis at locations over 700 miles apart and also duplicated in physical form and sent to secure off-site facilities at the end of each business day. We also have deployed redundant communication lines from multiple locations with industry utilities, information providers, and clearing organizations. We have established alternative methods to communicate with our employees, clients and regulators.

We believe that our BCP meets or exceeds all industry standards and regulatory requirements. We further believe that we have implemented reasonable and prudent measures to overcome or at least mitigate the consequences of an event that would otherwise interfere with the normal course of our business. However, because it is not possible to anticipate the nature, scope, impact and consequence of every possible business disruption, Devenir capital Ltd. does not represent or guaranty that it will be able to continue or resume business operations within any specified period of time under all circumstances.

Devenir Capital Alternative Investments (“DCAI”)

This website provides general information about DCAI and its investment strategies. This material is provided for informational purposes only and nothing herein constitutes investment, legal, accounting or tax advice, or a recommendation to buy, sell or hold a security. Investments and investment strategies discussed on this website may not be suitable for you. You should weigh any investment decision carefully after considering your specific investment objectives and financial circumstances.

All information is current as of the date of this material and is subject to change without notice. Any views or opinions expressed may not reflect those of Devenir Capital as a whole. DCAI products and services may not be available in all jurisdictions or to all client types. Investing entails risks, including possible loss of principal. Investments in hedge funds and alternative investments are speculative and generally involve a higher degree of risk than more traditional investments. Investments in hedge funds and alternative investments are intended for sophisticated investors. Indexes are unmanaged and are not available for direct investment. Past performance is not indicative of future results.

Information contained in this website is based upon generally available information believed to be reliable, but no representation is made as to the accuracy, timeliness or completeness of such information or that any returns indicated will be achieved. Changes to assumptions may have a material impact on returns. 

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