Our Privacy Policy was last updated on 4 May, 2026.
At Fermat Capital Management, LLC, we take your privacy seriously. This Privacy Notice explains what Personal Data we collect, why we collect it, how we use it and how we keep it safe. It applies to everyone whose Personal Data we handle - whether you are a client, a prospective client, a business contact, a visitor to our website or anyone else we interact with. It also explains your privacy rights and how the law protects you.
If you are based in the EEA or the UK, please also read the Supplementary Information at the end of this Privacy Policy - it sets out the additional rights you have under the GDPR and UK GDPR.
Definitions
| Account | means a unique account created for you to access our Service or parts of our Service. |
| Company | refers to Fermat Capital Management, LLC (and any affiliates). |
| Cookie Policy | means the cookie policy set out at the end of this Privacy Notice. |
| Cookies | means small text files placed on your Device by a website, used to store information about your browsing session. For further details, please see our Cookie Policy. |
| Device | means any device that can access the Service, such as a computer, mobile phone or tablet. |
| EEA | means the European Economic Area. |
| GDPR | means the EU General Data Protection Regulation (Regulation (EU) 2016/679). |
| Personal Data | means any information relating to an identified or identifiable individual. |
| Privacy Notice | means this privacy notice. |
| Service | means our business activities and operations, including our website accessible at www.fcm.com and any other products, services or activities we carry out. |
| Service Provider | means any third-party company or individual engaged by us to process Personal Data on our behalf in connection with the Service. |
| UK GDPR | means the GDPR as it forms part of UK law by virtue of the European Union (Withdrawal) Act 2018. |
| Usage Data | means data collected automatically when you use the Service, such as the duration of a page visit. |
| Website | means the Fermat Capital Management, LLC website, accessible at www.fcm.com. |
Categories of Personal Data We Process
The table below sets out the categories of Personal Data we may collect and the types of data fields within each category. The precise data we collect will depend on how you interact with us and the nature of our relationship with you.
| Data Category | Examples of Data Fields |
|---|---|
| Identity and Contact Information | First name and last name; email address; telephone number; postal address (street, city, state/province, ZIP/postal code, country); job title; company name. |
| Identity Verification Data | Copies of identity documents (e.g. passport, driver's license); date of birth; nationality; identity and verification check results; sanctions and PEP screening results. |
| Professional and Employment Data | Employer name; job title; role and department; professional qualifications; work history; business contact details. |
| Account and Profile Data | Username; password (encrypted); account preferences and settings; saved items; personalization choices. |
| Financial and Transaction Data | Bank account details; credit or debit card details; billing address; transaction history; invoice data; payment processing information. |
| Communications and Interaction Data | Records of emails, telephone calls and other correspondence with us; inquiries and complaint details; dates and times of communications; records of requests submitted to us; customer service interaction records. |
| Marketing and Preferences Data | Marketing communication preferences; records of marketing communications sent and responses received; survey responses; event registration details; opt-in and opt-out records. |
| Feedback and Survey Data | Responses to surveys and feedback forms; product reviews and testimonials; customer satisfaction scores; other voluntary feedback provided to us. |
| Event and Meeting Data | Information about your attendance at our events, webinars, meetings and training sessions; registration details; attendance records; any recordings made with prior notice. |
| Technical and Usage Data | IP address; browser type and version; device type and identifier; operating system; screen resolution; language settings; pages visited; time and date of visit; time spent on each page; unique device identifiers; mobile device type and unique ID; mobile operating system. |
| Cookie and Tracking Data | Cookie identifiers; browsing history and session data; analytics data (e.g. pages visited, time on page, referral source); data collected via web beacons and similar tracking technologies. For further details, please see our Cookie Policy. |
| Location Data | Approximate or precise location derived from your IP address, GPS data or other location-based services where you have permitted this. |
| Security and Access Data | Information about your access to our systems, facilities and premises; access logs and authentication records; CCTV footage where you visit our offices. |
| Publicly Available Data | Information from public sources such as company registers, public directories, professional networking sites (e.g. LinkedIn), news articles and other publicly accessible databases. |
| Inferred and Derived Data | Data we create or infer about you based on your interactions with us, such as customer segments, interests, preferences, behavioral scores and risk assessments. |
| Legal and Compliance Data | Information relating to disputes, claims or legal proceedings involving you; compliance check results; AML and sanctions screening records; records required for regulatory reporting purposes; correspondence with regulatory authorities. |
| Special Category Data | In limited circumstances only, and where permitted or required by law or with your explicit consent: health or disability information (e.g. accessibility requirements at events); information revealing political opinions or affiliations (e.g. where required for regulatory due diligence). We will always inform you separately when we collect special category data. |
How We Use Your Personal Data
We only use your Personal Data where we have a clear and valid reason to do so. The table below sets out what we use it for and the legal basis we rely on in each case.
| Purpose of Use | Our Legal Basis |
|---|---|
| To provide and maintain our Service, including to monitor the usage of our Service and ensure it functions correctly. | Contract performance: We need to process your data to perform our contract with you. Legitimate interest: To operate and maintain a functional and secure service. |
| To manage your account and respond to your inquiries, requests and complaints. | Contract performance: To fulfill our contractual obligations to you. Legitimate interest: To maintain effective business relationships and provide you with the information or services you have requested. |
| To send you marketing communications, including updates, news, promotions and invitations to events, where you have consented or where we have a legitimate interest to do so. | Consent: Where required by applicable law, we will only send marketing communications where you have agreed to receive them. Legitimate interest: To promote our services and keep existing customers informed. You can opt out at any time. |
| To protect our systems, premises, data and people, including preventing and detecting fraud, security threats, cyberattacks and other harmful or unlawful activity. | Legitimate interest: To keep our IT systems, network, premises, data and personnel secure and to protect against threats. |
| To comply with our legal, regulatory and professional obligations, including record keeping, regulatory reporting, tax compliance and responding to lawful requests from authorities. | Legal obligation: We are required by law to process certain data for compliance purposes. |
| To prevent, detect and investigate crime, including fraud, money laundering and other criminal activity. | Legal obligation: Where required by applicable law. Legitimate interest: To prevent criminal activity and protect our business. |
| To establish, exercise or defend legal claims, manage disputes and conduct internal investigations where necessary. | Legitimate interest: To protect our legal rights and resolve any disputes. |
| To improve and develop our products, services and website through research, analysis, surveys, testing and feedback. | Legitimate interest: To continuously improve what we offer you. |
| To manage business transactions, including mergers, acquisitions, reorganizations or sales of all or part of our business, where your data may be transferred as part of such transaction. | Legitimate interest: To manage and develop our business, including through corporate transactions. |
| To analyze your preferences and behavior to better understand our users, improve our services and personalize your experience with us. | Legitimate interest: To understand our users and improve our offerings. Consent: Where we use cookies or similar technologies for analytics purposes. |
| To conduct internal audits, maintain internal records and ensure compliance with our policies and procedures. | Legal obligation: Where required by law. Legitimate interest: To ensure good governance and compliance with our internal standards. |
Who We Share Your Personal Data With
We may share your Personal Data with the following categories of recipients. We only share what is necessary and always ensure appropriate protections are in place.
— Service Providers: We work with third-party companies who help us run our business and deliver our Service - for example, IT providers, analytics services and customer support tools. These providers can only use your Personal Data on our instructions and are not permitted to use it for any other purpose.
— Our affiliates and group companies: We may share your Personal Data within the Fermat group of companies where needed for shared functions such as IT, compliance, finance or customer support. All affiliates are required to handle your Personal Data in accordance with this Privacy Notice.
— Professional advisers: We may share your Personal Data with our lawyers, auditors, accountants and insurers where they need it to provide their services to us.
— Fraud prevention and credit reference agencies: We may share your Personal Data with fraud prevention services, identity verification providers and credit reference agencies to help us detect and prevent fraud and financial crime.
— Regulators and authorities: We may share your Personal Data with regulators, tax authorities and other public bodies where we are required or permitted to do so by law, or as part of our routine reporting obligations.
— Business transfers: If we are involved in a merger, acquisition, sale or reorganization, your Personal Data may be transferred as part of that transaction. We will take steps to ensure it remains protected.
— With your consent: Where you have given us your consent, we may share your Personal Data for the specific purpose you agreed to.
— Legal requirements: We may disclose your Personal Data if we are required to do so by law or in response to a valid request from a public authority such as a court or government agency.
— Protection of rights: We may also disclose your Personal Data where we reasonably believe it is necessary to comply with a legal obligation; protect and defend our rights or property; prevent or investigate wrongdoing; protect the safety of any person; or defend against legal liability.
How Long We Keep Your Personal Data
We only keep your Personal Data for as long as we need it. This means we will retain it for as long as is necessary to fulfill the purposes described in this Privacy Notice, or for as long as the law requires us to.
Technical and usage information is generally held for a shorter period, unless we need to keep it longer to maintain the security or functionality of our Service, or where we are legally required to do so.
International Transfers
Because we are a global business, your Personal Data may sometimes be processed in countries outside your own. Some of these countries may have different data protection laws to those where you are based.
Wherever your Personal Data is transferred, we take appropriate steps to keep it safe and to ensure it is handled in accordance with this Privacy Notice. We will not transfer your Personal Data internationally unless adequate safeguards are in place.
How We Protect Your Personal Data
Keeping your Personal Data secure is important to us. We use appropriate technical and organizational measures to protect it against unauthorized access, loss or misuse. No system is completely secure, so while we do everything we reasonably can, we cannot guarantee absolute security.
Third-Party Service Providers
Some of our Service Providers may access your Personal Data in order to carry out tasks on our behalf. They are contractually required to keep it secure and may only use it for the purpose for which it was shared.
Analytics
We use third-party analytics providers to help us understand how our Service is being used and to improve it. For more information about how Cookies and similar technologies are used for analytics, including how to opt out of Google Analytics, please see our Cookie Policy.
Children's Privacy
Our Service is not intended for children as defined under applicable law, and we do not knowingly collect Personal Data from children without appropriate parental or guardian consent. If you are a parent or guardian and are concerned your child has shared Personal Data with us, please get in touch and we will promptly look into it.
Where the law requires us to obtain parental or guardian consent before collecting Personal Data from a child, we will always do so. If we discover that we have collected a child's Personal Data without the appropriate consent, we will delete it promptly.
Links to Other Websites
Our Service may include links to third-party websites. If you follow one of these links, please be aware that those sites have their own privacy notices, which we encourage you to read. We are not responsible for the privacy practices of any third-party sites.
Changes to This Privacy Notice
We review and update this Privacy Notice from time to time. If we make any material changes, we will let you know by posting the updated Privacy Notice on our Website and displaying a prominent notice.
The 'Last updated' date at the top of this Privacy Notice tells you when it was most recently revised. We encourage you to check back periodically so you are always up to date.
Contact Us
We are always happy to help. If you have any questions about this Privacy Notice, or about how we handle your Personal Data, please get in touch:
— By visiting this page on our website: https://www.fcm.com/contact.html
Supplementary Information (GDPR and UK GDPR)
The information in this section applies to you if you are based in the European Economic Area (EEA) or the United Kingdom (UK) and we handle your Personal Data under the GDPR or UK GDPR.
Who is Responsible for Your Personal Data?
Fermat Capital Management, LLC is the data controller responsible for your Personal Data. If you have any questions, please contact us using the details in the Contact Us section above.
Our Legal Bases for Using Your Personal Data
Data protection law requires us to have a valid legal reason - called a 'legal basis' - every time we use your Personal Data. We rely on the following bases under Article 6 of the GDPR:
(a) Contract performance (Article 6(1)(b)): we need to use your Personal Data to carry out a contract with you, or to take steps you have asked for before we enter into one;
(b) Legal obligation (Article 6(1)(c)): we are required by law to use it;
(c) Legitimate interests (Article 6(1)(f)): we have a genuine business reason to use it, and that reason is not outweighed by your rights and interests; and
(d) Consent (Article 6(1)(a)): you have agreed to us using it for a specific purpose. You can withdraw your consent at any time, and this will not affect anything we did before you withdrew it.
Our Privacy Principles
When we handle your Personal Data, we are committed to the following principles. We will always use it:
(a) lawfully, fairly and in a transparent way;
(b) for specified, explicit and legitimate purposes only;
(c) in a manner that is adequate, relevant and limited to what is necessary;
(d) accurately and, where necessary, kept up to date;
(e) for no longer than is necessary for the purpose; and
(f) securely, using appropriate technical and organizational measures.
International Transfers
If we transfer your Personal Data outside the EEA or the UK to a country that does not offer the same level of protection, we will put appropriate safeguards in place. These typically include EU Standard Contractual Clauses and/or the UK International Data Transfer Agreement (IDTA). In limited cases, we may rely on an exemption under Article 49 of the GDPR, for example where the transfer is necessary to carry out your contract. Please contact us if you would like more information about how we protect your data when it is transferred internationally.
Your Rights
Under the GDPR and UK GDPR, you have a number of important rights over your Personal Data. These rights are not absolute - in some cases they may not apply, or may be subject to certain conditions - but where they do apply, we will always try to respond promptly. Your rights include:
(a) The right of access: you can ask us for a copy of the Personal Data we hold about you;
(b) The right to rectification: you can ask us to correct any Personal Data that is wrong or incomplete;
(c) The right to erasure: in certain circumstances, you can ask us to delete your Personal Data;
(d) The right to restriction: you can ask us to pause our use of your Personal Data in certain circumstances;
(e) The right to data portability: where we use your Personal Data based on your consent or to carry out a contract, and the processing is done by automated means, you can ask us to send it to you or to another organization in a structured, machine-readable format;
(f) The right to object: you can object to us using your Personal Data where we rely on legitimate interests - and you always have the right to object to your data being used for direct marketing; and
(g) Rights related to automated decision-making: you have the right not to have decisions made about you based solely on automated processes (including profiling) where those decisions have a significant effect on you.
To exercise any of these rights, please contact us using the details in the Contact Us section above. We aim to respond within one month, though complex requests may take a little longer - we will always let you know if that is the case. We will not usually charge a fee, unless your request is clearly unfounded or excessive.
How to Complain
If you are unhappy with how we have handled your Personal Data, please contact us first - we would always prefer the opportunity to put things right. You also have the right to complain to the data protection authority in your country. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk. In the EEA, you can find your local authority at edpb.europa.eu.
Do You Have to Give Us Your Personal Data?
In most cases, sharing your Personal Data with us is entirely voluntary. However, there are situations where we need certain information from you - for example, to provide a service, to enter into a contract, or to meet a legal obligation. Where this applies, we will make this clear at the time. If you choose not to provide it, we may not be able to help you in the way you have requested.
Cookie Policy
Last updated: May 4, 2026
What Are Cookies?
Cookies are small text files that get placed on your Device when you visit a website. They are widely used to make websites work, remember your preferences and give operators useful information about how their site is being used.
About This Cookie Policy
This Cookie Policy is issued by Fermat Capital Management, LLC and covers our Website at www.fcm.com. For more information about how we handle your Personal Data generally, please read our Privacy Notice above.
What Cookies Do We Use?
We use four types of Cookies on our Website:
(a) Strictly Necessary Cookies: These are essential for our Website to work. They handle things like logging you in and keeping your account secure. Because we cannot operate the Website without them, we do not need to ask for your consent to use them.
(b) Preference Cookies: These remember whether you have accepted our use of Cookies on this Website.
(c) Functionality Cookies: These remember choices you make - such as your login details or preferred language - so you do not have to set them again every time you visit.
(d) Analytics Cookies: These help us understand how people use our Website by collecting information such as which pages are visited and how long visitors spend on them. They may indirectly identify you. We will only place these Cookies on your Device with your consent.
Other Tracking Technologies
Our Cookie Inventory
The table below lists the specific Cookies we currently use on our Website. Please note that the Cookies we use may change from time to time — we will update this Cookie Policy when they do.
| Cookie Name | Provider | Type | Purpose | Expiry |
|---|---|---|---|---|
| PHPSESSID | www.fcm.com | Necessary | Store and identify a user's unique session ID for managing user session on the website. | 7 days |
| trackalyzer | tracking.leadlander.com | Analytics | Analyse website visitors and monitor traffic patterns. | 1 year |
| _ga | .google.com | Analytics | Registers a unique ID used to generate statistical data on how the visitor uses the website. | 2 years |
Some pages of our Website and our emails may use web beacons (also called clear gifs, pixel tags or single-pixel gifs). These are tiny image files that help us track things like page views and email opens.
Google Analytics
We use Google Analytics (provided by Google LLC) to understand how people use our Website. Google Analytics uses Cookies to collect information such as your (shortened) IP address, the pages you visit and how long you spend on each page. This data is sent to and stored by Google, and may be processed in the United States. Google uses it to compile reports on Website activity on our behalf. Your IP address is never combined with other data held by Google. For more information, visit: https://policies.google.com/privacy. To opt out, install the Google Analytics opt-out browser add-on: http://tools.google.com/dlpage/gaoptout.
Third-Party Cookies
In addition to the Cookies we set ourselves ("first-party Cookies"), some Cookies on our Website are set by third parties — for example, analytics providers, social media platforms or advertising networks. These are known as "third-party Cookies." We do not control how third parties use the data they collect via their Cookies. We encourage you to read the privacy and cookie policies of any third-party services you use, as their practices may differ from ours.
How to Manage Your Cookies
You can update your Cookie preferences at any time by clicking [Cookie Preferences link] on our Website. Please note that strictly necessary Cookies cannot be switched off - they are essential for the Website to function properly.
You can also control Cookies through your browser settings. Please be aware that turning off certain Cookies may affect how our Website works for you. If you need help finding these settings, check your browser's help menu.
How We Obtain Your Consent
When you first visit our Website, you will be shown a cookie banner asking for your consent to place non-essential Cookies on your Device. You can choose to accept all Cookies, reject all non-essential Cookies, or customize your preferences by cookie category. Your choices will be saved and applied each time you visit our Website.
You can change or withdraw your consent at any time by clicking [Cookie Preferences link] on our Website. Where you withdraw consent, we will stop placing the relevant Cookies on your Device. Please note that some features of our Website may not work as intended if you decline certain Cookies.
Do Not Track
Some browsers have a "Do Not Track" (DNT) feature that signals to websites that you do not want your online activity tracked. Our Website does not currently respond to DNT signals, as there is no industry-agreed standard for how websites should interpret them. However, you can manage your Cookie preferences directly using the options described above.
Session and Persistent Cookies
Cookies come in two types: session Cookies, which are deleted as soon as you close your browser, and persistent Cookies, which stay on your Device until they expire or you delete them.
Changes to This Cookie Policy
We may update this Cookie Policy from time to time. Any changes will be posted on our Website. We encourage you to check back periodically to stay informed.
Contact Us
If you have any questions about this Cookie Policy or how we use Cookies, please get in touch at: https://www.fcm.com/contact.html