Last Updated: 08/12/2025
1. Introduction & Scope
These Terms of Business ("Terms") govern the relationship between SRL Partners Ltd t/as Xenith Capital ("Xenith Capital", "we", "us") and you ("the Client", "you") regarding your use of our automated trading strategies and related services.
Important Regulatory Status: Xenith Capital is not authorised or regulated by the Financial Conduct Authority (FCA). We operate strictly as a Strategy Provider to Pelican Trading (a trading name of London & Eastern LLP). London & Eastern LLP is authorised and regulated by the FCA (Firm Reference No. 534484).
By accessing our strategies, website, or connecting your brokerage account to our signals, you agree to be bound by these Terms.
2. Nature of Our Services
2.1 Strategy Provision: We provide algorithmic trading signals and strategy parameters ("the Intelligence") which are executed automatically via our regulated infrastructure partners.
2.2 No Investment Advice: Xenith Capital provides factual market analysis and automated signals. We do not provide personal investment advice. Nothing in our communications should be construed as a recommendation to buy or sell any specific financial instrument based on your personal financial circumstances.
2.3 Execution: All trade execution, custody of funds, and brokerage services are provided by Vantage Global Limited (regulated by the VFSC, Vanuatu). Xenith Capital does not execute trades or hold client funds.
3. Fees and Charges
3.1 Performance Fee Model: Unlike traditional subscriptions, our primary revenue model is based on a Performance Fee (typically 30-40%, subject to the specific strategy offer).
3.2 High Water Mark: Fees are calculated based on a "High Water Mark" principle. This means you are only charged a fee if your account generates a net profit above its previous highest value. This calculation is adjusted for capital flows: if you withdraw funds, the High Water Mark is reduced proportionally. This ensures that performance fees are calculated based on genuine trading profit, rather than penalized by your decision to withdraw capital.
3.3 Deduction: By connecting to a Xenith strategy, you authorise our partner broker (Vantage) to automatically deduct these performance fees from your trading account and remit them to us (via Pelican Trading).
3.4 Brokerage Costs: You are responsible for all standard brokerage costs applied by Vantage, including spreads, swaps, and commissions.
4. Risks and Liability
4.1 High Risk: You acknowledge that trading Forex, CFDs, and Cryptoassets involves a high degree of risk. It is possible to lose all of your invested capital.
4.2 No Guarantees: Past performance is not a reliable indicator of future results. Xenith Capital makes no guarantee that any strategy will achieve its investment objectives or avoid losses.
4.3 Limitation of Liability: To the maximum extent permitted by law, Xenith Capital shall not be liable for:
Any trading losses incurred by following our strategies.
Losses arising from technical failures, latency, or internet outages affecting the broker or Pelican infrastructure.
Losses arising from the insolvency or negligence of the broker (Vantage Global Limited).
5. Investment Process & Cooling Off
5.1 Onboarding: To access our strategies, you must complete the onboarding process via our partner portal, which includes Identity Verification (KYC) and an Appropriateness Test.
5.2 Restricted Mass Market Investments (RMMI): Our Crypto and FX strategies are classified as RMMIs. You acknowledge that you may be subject to a mandatory 24-hour cooling-off period before you can connect to specific strategies.
6. Termination
6.1 By You: You may stop using our services at any time by disconnecting your account from the strategy via the Pelican/Vantage portal.
6.2 By Us: We reserve the right to terminate your access to our strategies if you breach these Terms or if our relationship with our infrastructure partners changes.
7. Intellectual Property
7.1 All strategy logic, algorithms, performance data, and content provided by Xenith Capital remain our intellectual property. You may not reverse-engineer, copy, or resell our signals.
8. Privacy and Data Protection
8.1 We process your personal data in accordance with our Privacy Policy.
8.2 By using our services, you consent to the sharing of your data with Pelican Trading and Vantage Global Limited for the purposes of account administration and fee calculation.
9. Complaints
9.1 If you have a complaint about our service, please contact us at info@xenithcapital.co.uk. 9.2 Please note that as an unauthorised firm, complaints regarding Xenith Capital generally cannot be referred to the Financial Ombudsman Service (FOS). Complaints regarding the regulated activities of Pelican Trading or Vantage Global Limited should be directed to those entities respectively.
10. Governing Law
These Terms are governed by and construed in accordance with the laws of England and Wales. The courts of England and Wales shall have exclusive jurisdiction to settle any dispute arising out of or in connection with these Terms.
Privacy Statement
I/We, Xenith Capital are committed to respecting and protecting the privacy of anyone using our site and the confidentiality of any information that you provide us with. The purpose of this statement is to set out how we use any personal information that we may obtain from you.
Data Protection Act 1998 (‘the Act’)
We are registered under the Data Protection Act and comply with the Act in all our dealings with your personal data.
Use and collection of personal information
In general you can visit our website without telling us who you are and without revealing any information about yourself. If, however, you use our site you will need to register and you will be asked to provide certain information such as your contact details. We will store this data and hold it on computer or otherwise.
We may use information that you provide:
To register you with our website and to administer it.
For assessment and analysis, e.g. marketing, customer and product analysis, to enable us to review, develop and improve our services.
If you do not want us to use data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data.
We may disclose your personal information to third parties:
In the event we sell or buy any business or assets, in which case we might disclose your personal data to the prospective buyer or seller.
If we are under a legal duty to disclose or share your personal data in order to comply with or meet any legal obligation.
Cookies
We collect information directly from you in a number of ways. One way is through our use of ‘cookies’. Most websites use cookies in order to make them work, or to work more efficiently, as well as to provide information to the owners of the website. They help us to understand how our customers and potential customers use our website so we can develop and improve the design, layout, content and function of the site. Cookies are small text files that are placed on your computer’s hard drive by websites that you visit. They save and retrieve pieces of information about your visit to the website – for example, how you entered the site, how you navigated through the site and what information and documentation was of interest to you. This means that when you go back to a website, it can give you tailored options based on the information it has stored about you on your last visit.
Some of our cookies are used to simply collect information about how visitors use our website and these types of cookies collect the information in an anonymous form.
Where there is a login process relating to buying products or services from us we also use cookies to store personal registration information so that you do not have to provide it to us again on subsequent visits.
The rules about cookies on websites have recently changed. If you are uncomfortable with the use of cookies, you can disable cookies on your computer by changing the settings in the preferences or options menu in your browser. You can set your browser to reject or block cookies or to tell you when a website tries to put a cookie on your computer. You can also delete any cookies that are already stored on your computer’s hard drive. However, please be aware that if you do delete and block all cookies from our website, parts of the site will not then work. This is because some of the cookies we use are essential for parts of our website to operate. Likewise, you may not be able to use some products and services on other websites without cookies.
To find out more about cookies, including seeing what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
If you do not wish to accept cookies from our website, please leave this site immediately and then delete and block all cookies from this site. Alternatively, you may opt out of receiving information from us by e-mail, telephone, or post. Our e-mail address is info@xenithcapital.co.uk.
Security
We endeavour to take all reasonable steps to protect your personal information. However, we cannot guarantee the security of any data that you disclose online and we will not be responsible for any breach of security unless this is due to our negligence or wilful default.
Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will aim to inform you before collecting your data if we intend to use your data for such purposes or we intend to disclose your information to any third party for such purpose. You can exercise your right to prevent this happening by checking certain boxes on the forms we use to collect your data.
General
You have the right to see personal data (as defined under the Data Protection Act) that we keep about you upon receipt of a written request and payment of a fee of £10. Any request should be sent to:
