Privacy, Complaints & Remuneration Policies

Privacy Statement

True Capital Limited respects your privacy and is committed to protecting it. We provide this privacy statement to inform you of our Privacy Policy and practices.

Information we collect:

Personal information

This is information that is associated with your name or personal identity.

Once you choose to provide us with personal information, you can be assured it will be used only as required in providing our services to you and to support your customer relationship with True. We take the trust you place in us seriously.

You can request a copy of the personal information we hold for you at any time.

Non-personal information

This is predominantly data about website usage and operations that are not associated with a specific personal identity. Most non-personal data is collected via cookies.

How we use your information

True uses your personal information for a legal and legitimate interest, such as:

Newsletters & True Insights: if you have requested to receive True’s newsletters or Thought Leadership documents we will use your email address to send these to you.

Event invitations: where we believe that one of our events will be of commercial interest to you we will use your email address to send you a save the date or an invitation.

Seed funding applications: if you submit an application for seed funding, we will use the data provided in the form to assess your suitability and to contact you regarding your application. In addition, where we feel that there may be a commercial interest for you within our wider Live Network we may share your contact information where we feel that it is appropriate to do so and where your interests and fundamental rights do not override those interests.

Innovator Club applications: if you submit an application to join our Innovator Club we will use the data provided in the form to assess your suitability and to contact you regarding your application. In addition, where we feel that there may be a commercial interest for you within our wider Live Network, we may share your contact information where we feel that it is appropriate to do so and where your interests and fundamental rights do not override those interests.

Recruiting: if you are a candidate for a position with True, we will use personal information about you in connection with recruiting you, processing your application for the position, or, if applicable, extending an offer or hiring you. You may also provide us with your email address to receive information on open positions with True. Doing so could trigger an email from us to you inviting you to complete an application of send your curriculum vitae, resume or other information

True’s services: we may contact you to provide you with our services and support, and to help us better understand your needs and requirements. We may also use your information to contact you directly regarding our services. These include providing you with information about our funds and to assess and respond to your enquiries and requests.

Legal obligations: we will use or process personal information as necessary for compliance a legal obligation to which we are subject.

Other legitimate interests: we will process your personal information for any of our other legitimate interests not described above where your interests and fundamental rights do not override those interests. These include managing ongoing relationships with you, to keep in touch with you as part of our professional network and let you know about opportunities you may be interested in.

Who we share your information with

True will not sell, rent or lease your personal information to others. We may disclose your personal information to others in the following circumstances and/or for the following purposes:

  • Where it is necessary for the provision of information or services to you.
  • Where we are required to do so by the courts or to comply with other legal, statutory and/or regulatory obligations including accounting and taxation requirements.
  • To our wider network where we believe that there is a legitimate commercial interest and where your interests and fundamental rights do not override those interests.
  • To prevent and/or detect crime.
  • Your data will always be managed with reference to all relevant laws and regulations.
  • Communications with you.

To ensure you are kept fully informed we may contact you by mail, email and other means of communication to provide you with information on special offers, research, and promotions of investments, products and services. If you do not want to receive this information you can write us via email: privacy@true.global.

Questions about the Privacy Policy

Privacy and security are important to us. We are committed to building a trusting relationship with you, and we will continually monitor feedback and seek to improve our services to meet your needs. If you have any questions about this Privacy Policy or the practices of this website, or you would like to provide comments, please send us an email at privacy@true.global.

Complaints Policy

Our Complaints Procedure

True Capital Ltd places a premium on the successful outcome of complaints — successful both in terms of the satisfaction of the customer and the protection and enhancement of the firm’s reputation. To this end the following procedures have been designed to produce as efficient and fair an outcome to any complaint raised.

The Procedure

Should you have a complaint that we have been unable to resolve by the close of business the third business day after you raised it, you should write to our Compliance Officer via email: privacy@true.global. Alternatively, you may call us on +44 (0)20 3740 6940 and ask to speak to the Compliance Officer. You will then receive a written acknowledgement that your complaint has been received and will be investigated. The known facts of the complaint will be confirmed in the acknowledgement. The Compliance Officer will decide who is the most appropriate person to investigate the matter.

Finalising the complaint

True Capital Ltd requires all complaint investigations to have been finalised within 8 weeks from the date on which the matter was originally raised. On the conclusion of the investigation, the Compliance Officer will write to you stating: whether the complaint has been upheld or rejected; if the complaint was upheld, detailing any offer of compensation; that the complainant, if from a retail customer or individual, may have the right to complain directly to the Financial Ombudsman Service, with their contact details, and enclosing a copy of the Financial Ombudsman Service explanatory leaflet.

Time-barred complaints

If we receive a complaint which relates to a matter which is: to have become aware that he had cause for complaint; we may reject the complaint without considering the merits. The Ombudsman may waive the time limits in exceptional circumstances.

Remuneration Policy

All True Capital Limited staff remuneration (including that of its Directors) is comprised of fixed and variable remuneration. It is the policy of the Firm that fixed and variable remuneration are appropriately balanced and are clearly distinguished for each individual, with clear financial and non-financial criteria used in determining fixed and variable components. The objectives of the financial incentives are to:

  • promote the long-term success (both financial and non-financial) of True;
  • attract, motivate and retain suitable staff;
  • promote sound and effective risk management

True Capital's primary business is acting as AIFM to its funds. As such, it's remuneration policies and practices are designed to ensure that employees are incentivised to manage those funds appropriately. Financial and non-financial criteria used to assess the performance of each employee will differ depending on the seniority and role of each employee. They encompass demonstrated commitment to True's values and ethos, conduct of the employee, and contributions to business performance and/or corporate strategy (including long-term effects).

All decisions in relation to the remuneration of all staff are made and approved exclusively by the Board with no input from external consultants. True's Remuneration Policy is maintained exclusively by its Board.

For the performance year ending 31/03/2024 True paid the following:

  • Total fixed remuneration: £4,739,584
  • Total variable remuneration: £885,001