Terms Of Use

Legal Notices and No Offer or Advice

By entering our website (the “site”), you hereby confirm that you are an accredited investor or an institutional investor or equivalent thereof, as these terms are defined under section 4 of the Securities and Futures Act (Cap. 289 of Singapore), and you acknowledge your agreement with and understanding of the following Legal Notices and Terms of Use (the “Legal Notices”) pertaining to this site including all material on it. 

Any of Gateway Holdings Limited, Gateway (Cayman) Limited, Gateway Management Company Pte. Ltd. or GWP Management Limited (collectively “Gateway” or “We”) may change, suspend or discontinue any aspect of this site at any time, including the availability of any feature, database or content therein. Your continued use of the site after any such modifications shall constitute your acceptance of the modified Legal Notices. If you do not agree with these Legal Notices and agree to abide by these Legal Notices for any reason, please do not use this site.

Gateway Management Company Pte. Ltd. (“Gateway Singapore”) is regulated by the Monetary Authority of Singapore as a capital markets services licence holder to conduct fund management activities. 

GWP Management Limited (“Gateway Dubai”) is regulated by Dubai Financial Services Authority (“DFSA”) and holds a Category 3C License. DFSA regulated firms are subject to Client Classification requirements and the services or products promoted in this website may not be suitable for Retail Clients under the DFSA rules and regulations. Any information provided is only for the use of Professional Client or Market Counter Party and cannot be relied upon by Retail Clients (as these terms are defined in the Glossary Module of the DFSA). Professional Clients may not be afforded the Retail Client protection and compensation rights that may generally be available to them from within the DFSA and other jurisdictions.

You acknowledge that the content of this site is for general, informational purposes only. Gateway does not render or offer to render investment advice through this website. Nothing on this website constitutes or forms a part of any offer for sale or subscription of, or any invitation to offer to buy or subscribe for, any securities or promise to undertake or solicit business, nor should it or any part of it form the basis of, or be relied upon in connection with, any contract or commitment whatsoever. Nothing on this website constitutes an invitation to engage in any services of Gateway.

For the avoidance of doubt, nothing in this website shall constitute or be construed as an offer to sell or the solicitation of an offer to buy in any jurisdiction where an offer and/or solicitation is not authorised to be made without compliance with any registration, regulatory approval or other legal requirements, including in any state or other jurisdiction to any person to whom it is unlawful to make such offer or solicitation in such state or jurisdiction and that such distribution and the offer and sale of securities or collective investment schemes in certain jurisdictions may be restricted by law. Any offer or solicitation will be made only through a final private placement memorandum, subscription agreement or related documents with respect to a particular investment opportunity and will be subject to the terms and conditions contained in such documents, including the qualifications necessary to become an investor.

In Singapore, this communication is only made to, or directed at, the following persons: (a) persons who are accredited investors as defined under the Securities and Futures Act, Cap 289; and (b) persons who are institutional investors as defined under the Securities and Futures Act, Cap 289 (“Singapore Relevant Persons”). This communication is not addressed to, and must not be distributed to or acted on by, any person in the Singapore who is not a Singapore Relevant Person. Any investment or investment activity to which this communication relates is available only to the Singapore Relevant Persons and will be engaged in only with such persons.

Save for Gateway Singapore, none of the other Gateway entities (“Non-Singapore Entities”) are licensed, registered, authorised or approved to carry on any regulated activities in Singapore. Nothing in this website is intended to constitute an offer for, or an invitation to engage in any services of the Non-Singapore Entities. Nothing in this website shall be construed as the Non-Singapore Entities holding themselves out to be licensed, registered, authorised or approved to carry on any regulated activities in Singapore.

For the avoidance of doubt, nothing in this website shall be construed as Gateway undertaking to provide or carry on fund management on your behalf or providing you with any financial advisory services, investment, accounting, tax, legal or other advice, and nothing on the site is to be deemed a recommendation that you buy, sell or hold any security or other investment or that you pursue any investment style or strategy. If you would like investment, accounting, tax or legal advice, you should consult with your own advisors with respect to your individual circumstances and needs.

Save for Gateway Dubai, none of the other Gateway entities (“Non-Dubai Entities”) are licensed, registered, authorised or approved to carry on any regulated activities in Dubai. Nothing in this website is intended to constitute an offer for, or an invitation to engage in any services of the Non-Dubai Entities. Nothing in this website shall be construed as the Non-Dubai Entities holding themselves out to be licensed, registered, authorised or approved to carry on any regulated activities in Dubai International Financial Centre (“DIFC”).

For the avoidance of doubt, nothing in this website shall be construed as Gateway undertaking to provide or carry on fund management on your behalf or providing you with any financial advisory services, investment, accounting, tax, legal or other advice, and nothing on the site is to be deemed a recommendation that you buy, sell or hold any security or other investment or that you pursue any investment style or strategy. If you would like investment, accounting, tax or legal advice, you should consult with your own advisors with respect to your individual circumstances and needs.

No Warranties

We have compiled this site in good faith and while we use reasonable efforts to include accurate information on this site, the site is provided on an “as is” basis with no warranties of any kind. We do not warrant that the information on the site is accurate, reliable, up-to-date or correct, that this site will be available at any particular time or location, or that this site is free of viruses or other harmful components. Your use of this site and use or reliance upon any of the materials on this site is solely at your own risk.

Modifications to Content

We may, at our discretion, modify or discontinue any or all of the materials published on this site (the “Content”), or any portion thereof, at any time with or without notice.

Confidentiality

All information available through the privileged area of the site is confidential and proprietary to us. This includes all investment information and results, offering materials, financial statements and other information provided through this part of the site. You will use your best efforts to keep all this information strictly confidential. You will not disclose any of this information to any person or use it for any purpose other than those strictly permitted by us, in writing.

Login I.D. and Passwords

Access to specific areas of this site requires the usage of a Login I.D. and associated password. You agree to keep this information confidential, and not to provide it to any other person except your employees, counsel and other professional advisors who have a need to access the information to advise you regarding your investment. If you have a Login I.D. and password, you are responsible for the activities which occur in connection with their usage and as such should take steps to protect them from misuse. If you become aware of any unauthorized use of, loss or theft of your Login I.D. and password, you will immediately inform us.

Material Interests

Gateway and/or its directors, officers and employees may have or have had interests or positions or traded in financial instruments that are referenced on this site. Furthermore, such entities or persons may have or have had a relationship with or may provide or have provided finance or other services to or serve or have served as directors of relevant companies. Companies in which investments are made may compete with one another.

International Use

This site is controlled, developed and maintained from Singapore and Dubai. Due to the global nature of the Internet, this site may be accessed by users in countries other than Singapore and Dubai. We make no warranties that materials on this site are appropriate or available for use in such locations. If it is illegal or prohibited in your country of origin to access or use this site, then you should not do so. Those who choose to access this site outside of Singapore and Dubai do so on their own initiative and are responsible for compliance with all local laws and regulations.

Ownership

The contents of this website are intended for the personal, non-commercial use of its users. All Content is protected by copyright, trademark and all other applicable intellectual property laws, and are owned and controlled by Gateway or a party credited as the provider of such Content. Except to the extent permitted by law and/or as specifically set forth in these Legal Notices, you may not reproduce, modify, adapt, translate, exhibit, publish, transmit, participate in the transfer or sale of, create derivative works from, distribute, perform, display, reverse engineer, decompile or disassemble, or in any way exploit any of the Content, source code or software forming part of this website in whole or in part. Gateway reserves the right to terminate at any time, and without notice, any users’ access to this website.

Submitted Materials

Unless specifically requested, Gateway does not solicit, nor does Gateway wish to receive, any confidential, secret or proprietary information or other material from you through this website, by e-mail, through the “Contact Us” feature, or in any other way. Any materials submitted or sent on or through this website in any manner (collectively, “Submitted Materials”) will be deemed not to be confidential or secret, and may be used by us in any manner consistent with these Legal Notices. By submitting Submitted Materials on this website, you: (i) represent and warrant that you either own your Submitted Materials, or that you have the necessary licenses, rights, consents and permissions to use such Submitted Materials and submit them to this website; and (ii) you grant Gateway a royalty-free, unrestricted, worldwide, perpetual, irrevocable, non-exclusive and fully transferable, assignable and sublicensable right and license to use such material (in whole or part) in any manner and/or to incorporate it (in whole or in part) in other works (including, without limitation, this website), products or services in any form, media, or technology now known or later developed. Gateway is not obligated to review any Submitted Materials. Gateway cannot be responsible for maintaining any Submitted Material you provide to this website, and we may delete or destroy any such Submitted Material at any time.

User Conduct

• Without limitation of the other terms and conditions set forth herein, while accessing or using this website, the Content and/or the various other features available on this website, you agree that you shall not:
• impersonate any person or entity or misrepresent your affiliation with any other person or entity, whether actual or fictitious, including anyone from this website or Gateway;
• Use, redistribute, republish or exploit any part of this website or any Content for any commercial or promotional purposes;
• Obtain or attempt to gain unauthorized access to other computer systems, materials, information or any services available on or through this website through any means, including through means not intentionally made publicly available or provided for through this website;
• Engage in spidering, “screen scraping,” “database scraping,” harvesting of e-mail addresses or other personal information, or any other automatic or unauthorized means of accessing, logging-in or registering on this website, or obtaining lists of users or other information from or through this website including, without limitation, any information residing on any server or database connected to this website;
• Use this website, the Content or its features and services in any manner that could interrupt, damage, disable, overburden or impair this website or interfere with any other party’s use and enjoyment of this website, including, without limitation, sending mass unsolicited messages or “flooding” servers with requests;
• Use this website or the Content (including by submitting Submitted Materials) to, or in any other manner, violate, plagiarize or infringe the rights of third parties, including without limitation, copyright, trademark, trade secret, confidentiality, contract, patent, rights of privacy or rights of publicity or any other proprietary or legal right;
• Upload, post, publish, distribute or otherwise transmit any information or material which constitutes or contains a virus, spyware, or other harmful component, or which contains any embedded links, advertising, chain letters or pyramid schemes of any kind;
• Disclose any sensitive, proprietary or confidential information, about yourself or anyone else;
• Attempt (or encourage or support anyone else’s attempt) to circumvent, reverse engineer, decrypt, or otherwise alter or interfere with this website; or
• Use this website or its services (or any Content), in whole or in part, or submit any information to this website, in violation of any applicable law, rule or regulation.

Limitation of Liability

Gateway hereby disclaims all warranties, conditions and representations of any kind with regard to this website, including any implied warranties or conditions of satisfactory quality, merchantability, non-infringement of third-party rights, freedom from viruses or other harmful code, or fitness for a particular purpose.

This website and the information contained herein are provided “as is.” The information contained on this website is gathered from sources deemed to be reliable; however, Gateway does not warrant the accuracy, adequacy or completeness of the information and material contained on this website as of the viewing date and expressly disclaims liability for errors or omissions in such information and materials. Gateway does not make any commitment to update any material or information on this website.

Gateway is not liable for any consequential, incidental, special, punitive or exemplary damages or any loss of profits arising out of any use of, or inability to use, this website or any portion thereof, regardless of whether Gateway has been apprised of the likelihood of such damages occurring and regardless of the form of action, whether in contract, warranty, tort (including negligence), strict liability, or otherwise.

By accessing and/or using this website, you agree to indemnify, defend and hold Gateway and its respective officers, directors, partners, employees, members, agents, information providers, affiliates, licensors and licensees (collectively, the “Indemnified Parties”) harmless from and against any and all liability and costs, including without limitation reasonable attorneys fees and expenses, incurred by the Indemnified Parties in connection with any claim arising out of a breach by you of these Legal Notices or the representations, warranties and covenants deemed made by you hereunder. You agree to cooperate as fully as reasonably required in the defense of any claim. Gateway reserves the right, at its own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you. You shall not enter into any settlement agreement which affects the rights of any of the Indemnified Parties, or requires any of the Indemnified Parties to take any action, without Gateway’s prior written approval.

There may be legal requirements in various countries and jurisdictions which may restrict the information that can be accessed. Persons who obtain information from this website should inform themselves about and observe any restrictions imposed in the jurisdiction in which this website is accessed.

Links from Other Websites

This site may contain links to, or may be linked from, other sites that are not maintained by us and to which we have not provided permission. We do not endorse, have any responsibility for, or make any representations about, any other sites, including their products and services, content, communications and website use policies. We expressly disclaim any responsibility for your access to or use of such other sites.

Past Performance

Any performance data or comments expressed on this site are an indication of past performance. Past performance is not indicative of future results; no representation is being made that any investment will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided.

Aggregate Data

We generally record certain usage information, such as the number and frequency of visitors to this site. This information may include the websites that you access immediately before and after your visit to our site, the Internet browser you are using, and your IP address. If we use such data at all, it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally. We may employ cookies.

Complaints

To make a complaint, please email david.fennell@gatewayfund.net. To do this anonymously, please email the dedicated Gateway Partners email address at IQEQ (ethicall@IQEQ.com).

Personal Data

When you register to request access to our site, we may collect certain personal data from you in accordance with our Privacy Policy. This policy describes how we may collect, use, disclose, process and/or transfer your personal data when you visit our site. For example, we may collect personal data such as your name, phone number, physical address, net-assets, income and e-mail address, for reasonable business purposes including, but not limited to, confirming your qualifications to access the site. We may also, in connection with the operation of our site and provision of services to you:(i) use external service providers to operate and maintain our site as well as provide search engine optimization services; (ii) track website statistics by way of anonymised data usage; and (iii) employ other persons to perform work on our behalf, such as sending response to any queries received. These persons may have access to your personal data, but only for the purpose of performing their duties. These persons may not use your personal data for any other purpose. We will not use your personal data for direct marketing or for any other purpose not stated in these terms of use except (a) if we are required to make disclosures (or if we deem disclosures necessary in connection with suspected violation of any law or regulation) to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding; (b) where it is permitted by law; and/or (c) if you have provided your consent to such use of the personal data. Please refer to our Privacy Policy for further details.

Gateway Dubai is allowed to collect personal data by the Commissioner of Data Protection of the Dubai International Financial Centre (“DIFC”) and it processes, stores and transfers personal data in accordance with notification made to Commissioner of and in line with the DIFC Data Protection Law No. 1 of 2007 and its regulations thereunder.

Telephone Calls

Calls to Gateway may be recorded.

Governing Law

You agree that your use of this site and any disputes relating to any of them shall be governed in all respects by the laws of Singapore, DIFC and Cayman Islands. Any dispute relating to the above shall be subject to the exclusive jurisdiction of the Singapore courts.

Contact Information

Please contact us if you have any questions about our site or these Legal Notices. Electronic mail or other communications made through this site are not secure and we do not guarantee the confidentiality of such communications.

Should you have any queries regarding Gateway Partners Data Protection Policy, please reach out to the Company Data Protection Officer / Data Controller with contact details as follows:

For Gateway Singapore related requests:

Angelica Tan

angelica.tan@gatewayfund.net 

#06-01A Suntec Tower Two, 9 Temasek Blvd, Singapore 038989

Phone: +65 6908 7404

For Gateway Dubai related requests:

David Fennell

david.fennell@gatewayfund.net 

19-03 ICD Brookfield Place, DIFC, Dubai 507080

United Arab Emirates

Phone: +971 (0)4 518 5911

Advisory to General Public and Potential Investors

Gateway Partners has recently become aware that some investors have been approached by a firm attempting to lure them into making investments on the basis of their investment approach and portfolio, which is a precise impersonation of Gateway’s approach and existing investment portfolio. Individuals or institutions who have been approached to make such investments at that firm do so at their own risk and we advise caution and for investors to conduct the necessary pre-investment due diligence.

To be clear, Gateway Partners operates only through management offices in Singapore and Dubai with no offices or investment affiliates in other locations. The firm is registered in Cayman Islands and the management companies of the firm are regulated by the MAS in Singapore and the DFSA in the DIFC. We are committed to the highest standards of integrity, transparency, and accountability. If you have been approached recently under false pretences or have become aware of the false and inappropriate use of Gateway’s name or its portfolio, please contact us immediately.