SICOS Terms & Conditions
By consulting the http://www.sicos.io ("Site"), you accept the following terms and conditions. As the content of the Site might change, we invite you to consult this page regularly. As used herein, the term "you" and "your" shall mean the user of this Site, and the term "Sicos", "we" and "our" shall mean SICOS SECURITIES, a Luxembourg limited liability company (société à responsabilité limitée), with professional address at 2 C, Parc d'Activités, L-8308 Capellen, Grand Duchy of Luxembourg, registered with the Luxembourg Register of Commerce and Companies (“RCS”) under number B 220970 and with VAT number LU29988948.

SICOS SECURITIES is registered with the Luxembourg financial regulator CSSF under number A3353 as a sub-threshold alternative investment fund manager in accordance with Article 3(2) of the Law of 12 July 2013 on alternative investment fund managers.

1. Sustainability disclosure:
No consideration of adverse impacts of investment decisions on sustainability factors.

Under the European Commission's Sustainable Action Plan the SFDR is part of a broader legislative package that came into effect on 10 March 2021.
To meet the SFDR disclosure requirements, SICOS SECURITIES identifies, assesses and, where possible and appropriate, seeks to manage sustainability risks for the sub-threshold alternative investment fund Aquarius Alternative High Yield Debt Fund S.C.S. (the “Fund”) as part of its risk management process. SICOS SECURITIES believes that the integration of this risk analysis could help to enhance the long-term value of the portfolio for Investors, in accordance with the investment objective and investment policy of the Fund.
However, data and reliable sources in terms to measure the sustainability impact of the underlying economic activities of relevant market players for the investment strategy of the Fund are not existent or do not exist in a verifiable manner.Considering the fact of not being able to verify ESG data obtained by third-parties, we are not in a position to pronounce 100% affirmative action in relation to sustainability risks.
Therefore, the Fund is not promoting environmental or social characteristics within the meaning of article 8 of SFDR nor has sustainable investment as its objective within the meaning of article 9 of SFDR. For the purposes of Article 7 of the EU Taxonomy Regulation, the SICOS SECURITIES confirms that the investments underlying this financial product (i.e. the Fund) do not take into account the EU criteria for environmentally sustainable economic activities.
As regards disclosures obligations under article 4(1) of SFDR SICOS SECURITIES does therefore not and does not intend to, consider adverse impacts of investment decisions on sustainability factors as per Article 4 (1) (b) of SFDR.

2. SICOS Organizational Statement:
SICOS helps its clients to manage innovative investment vehicles. SICOS is the brand under which all offices operate.

3. Legal Disclaimer:
Note that any information contained in this Site is subject to copyright. Any program, publication, design, product, process, software, technology, information, know-how, or idea described in, or related to, the Site may be the subject to other rights, including other intellectual property rights, which are owned by SICOS or one of its legal entities or other parties and are not licensed to you hereunder.
The information contained in this Site is for general guidance on matters of interest only.
The application and impact of laws can vary widely based on the specific facts involved. Given the changing nature of laws, professional standards, rules and regulations, and the inherent hazards of electronic communication, we do not guarantee or warrant the Site will be uninterrupted, without delay, error-free, omission-free, or free of viruses.
Accordingly, the information on this Site is provided with the understanding that the authors, publishers and SICOS are not herein engaged in rendering professional advice and services. As such, it should not be used as a substitute for consultation with professional advisers. Before making any decision or taking any action, you should consult a SICOS professional.
While we have made every attempt to ensure that the information contained in this Site has been obtained from reliable sources, we are not responsible for any errors or omissions, or for the results obtained from the use of this information. All information in this Site is provided "as is", with no guarantee of representation, of completeness, accuracy, timeliness or of the results obtained from the use of this information, and without warranty of any kind, express or implied, including, but not limited to warranties of performance, merchantability and fitness for a particular purpose. In no event will SICOS, including any SICOS entity, partners, agents or employees thereof, be liable to you or anyone else for any decision made or action taken in reliance on the information in this Site nor for any damages, even if advised of the possibility of such damages.
Certain links in this Site connect to other web sites maintained by third parties over whom we have no control. SICOS makes no representations as to the accuracy or any other aspect of information contained in other web sites.
The laws of Luxembourg shall exclusively govern all disputes and all other proceedings outcoming of the connection and the content of this Site. The Court of Luxembourg-City shall have exclusive jurisdiction over all disputes and all other proceedings related to the content and the connection to this Site.

4. SICOS Online Privacy Statement:
This privacy statement explains what information we gather about you, what we use that information for and to whom we give that information. It also sets out your rights in relation to your information and who you can contact for more information or queries.

What does this privacy statement cover?
This privacy statement explains how we are committed to protecting your privacy and handling your information in an open and transparent manner.

This privacy statement sets out how we will collect, handle, store and protect information about you when:

  • you use “our Site” or
  • we perform any other activities that form part of the operation of this Site.

    • This privacy statement also contains information about when we share your personal information with third parties (for example, our service providers).

    In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.

    What information do we collect?
    We may collect personal information from you when you use this Site.

    We may collect or obtain such data because you give it to us (for example in a form on our Site). We may also collect or obtain personal information from you because we observe or infer that data about you from the way you interact with us or others. For example, to improve your experience when you use this Site and ensure that it is functioning effectively, we (or our service providers) may use cookies (small text files stored in a user’s browser) and Web beacons which may collect personal information. Additional information on how we use cookies and other tracking technologies and how you can control these can be found in our cookie notice.

    The personal information that we collect or obtain in such circumstances may include: your name; e-mail address; country of residence; employment and education details; your postings on any blogs, forums, wikis and any other social media applications that we provide; your IP address; your browser type and language; your access times; complaint details; details of how you like to interact with us and other similar information.

    The personal information we collect may also include so-called ‘sensitive’ or ‘special categories’ of personal information, such as details about your dietary requirements (for example, where we provide you with lunch during a meeting).

    The types of personal information and special categories of personal information that we collect may vary depending on how you use our Site. In some rare circumstances, we might also gather other special categories of personal information about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.

    We understand the importance of protecting children's privacy. Our website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.

    How we use information about you

    Use of personal information collected via our Site

    We may also use your personal information collected via our Site:
  • to manage and improve our Site
  • to tailor the content of our Site to provide you with a more personalized experience and draw your attention to information regarding services that may be of interest to you
  • to manage and respond to any request you submit through our Site.

    • Use of personal information for other activities that form part of the operation of our business In addition to the purposes connected to the operation of our Site above, we may use your personal information for the purposes of, or in connection with:
  • applicable legal or regulatory requirements
  • requests and communications from competent authorities
  • sending you thought leadership or details of products and services that may be of interest to you; contacting you to receive feedback on these services; and contacting you for other market or research purposes;
  • protecting our rights.

    • The legal grounds we use for processing personal information.

    We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal information. 

    We use your personal information for the purposes outlined above because of: (a) our legitimate interests in the effective delivery of our Site; (b) our legitimate interests in the effective and lawful operation of our Site so long as such interests are not outweighed by your interests; (c) the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency. 

    To the extent that we process any sensitive personal information relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) the processing is necessary for the establishment, exercise or defense of legal claims or (iii) you have made the data manifestly public.

    Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you. If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication or e-mail.  

    To whom we disclose your information
    In connection with one or more of the purposes outlined in the “How we use information about you” section above, we may disclose details about you to: third parties that provide services to us; competent authorities and other third parties that reasonably require access to personal information relating to you for one or more of the purposes outlined in the “How do we use information about you?” section above.

    Our Site may host various blogs, forums, wikis and other social media applications that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement.

    Please note that some of the recipients of your personal information referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations. The adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal information to third countries. Please contact us for further details of the transfers described above and the adequate safeguards used in respect of such transfers. 

    We may also need to disclose your personal information if required to do so by law, by a regulator or during legal proceedings.

    We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
    Protection of your personal information
    We use a range of physical, electronic and managerial measures to ensure that we keep your personal information secure, accurate and up to date. These measures include: 
  • education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal information
  • administrative and technical controls to restrict access to personal information on a ‘need to know’ basis
  • technological security measures, including fire walls, encryption and anti-virus software
  • physical security measures, such as staff security passes to access our premises. 

    • Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.

    How long do we keep your information?
    We will hold your personal information on our systems for the longest of the following periods:
    (i) as long as is necessary for the relevant activity or services;
    (ii) any retention period that is required by law;
    (iii) the end of the period in which litigation or investigations might arise in respect of the services. 

    Your rights
    You have various rights in relation to your personal information. In particular, you have a right to: 
  • obtain confirmation that we are processing your personal information and request a copy of the personal information we hold about you
  • ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete
  • ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information
  • object to our processing of your personal information.

    • To exercise any of your rights, or if you have any other questions about our use of your personal information, please send an email to the following address: [email protected]

    Right to complain
    If you are unhappy with the way we have handled your personal information or any privacy query or request that you have raised with us, you have a right to complain to the EU Data Protection Authority in your jurisdiction.

    Changes to this privacy statement
    We may modify or amend this privacy statement from time to time.
    To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.