Axebrook Capital LLP: Privacy Notice

This Privacy Notice sets out how Axebrook Capital LLP (“Axebrook” or “we”) collects, holds and uses personal data. Axebrook will only collect and use personal data in ways that are described here, and in a way that is consistent with its obligations and your rights under data protection law

1. Information About Us

Axebrook Capital LLP is a limited liability partnership registered in England and Wales with Partnership Number OC435402.

Registered & trading address: 5, Swallow Place, London W1B 2AF

Website: www.axebrook.com

2. What Does This Notice Cover?

This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified – this includes obvious information such as your name and contact details, but also less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
• The right to access the personal data we hold about you. Part 10 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling: We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact ususing the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office (https://ico.org.uk) or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first, using the details in Part 11.

5. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal data set out in the table below. We do not collect any ‘special category’ or ‘sensitive’ personal data. Data may be collected through interaction with the Axebrook team by email, telephone or in person, from public websites and data sources, or via intermediaries such as an investment advisor or third party recruiter.

Data subject	Data collected
Investors (actual and prospective)	Contact information, including name, personal and business address, email, telephone number; Identification information for the purposes of Know Your Client and Anti-Money Laundering processes; and Information relating to investment knowledge and experience.
Employees (actual and prospective)	Contact information including name, address, email, telephone number; Educational qualifications; and Employment history.
Service providers	Business information, including business name, job title, profession and business contact details (email and/or telephone number)

6. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes our lawful bases for doing so:

Data subject	Lawful basis for processing
Investors (actual and prospective)	Contract Legal obligation Legitimate interests
Employees (actual and prospective)	Contract Legal obligation
Service providers	Contract

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information on ourproducts or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.Wewill not share your personal data with third parties for marketing purposes.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows usto do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will You Keep My Personal Data?

The retention of certain types of data is governed by regulatory or legal requirements, in which case we will adhere to those timescales. Under FCA Rules, client records must be retained for a minimum of five years after the client ceases to be a client of the Firm. Where there is no such prescribed retention period, we will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. 

8. How and Where Do You Store or Transfer My Personal Data?

Wemay store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will only store or transfer personal data in or to third countries that are deemed to provide an adequate level of protection for personal data, or where specific approved contracts have been put in place which ensure the same levels of personal data protection that apply under the Data Protection Legislation. 

The security of your personal data is important to us, and to protect your data, we take a number of important measures, including the following:

• ensuring that appropriate physical and logical security is put in place around digital records;
• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
• putting in place procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

9. Do You Share My Personal Data?

Wewill not share any of your personal data with any third parties for any purpose other than the provision of investment management services to potential and actual investors in funds or other vehicles that we manage (the “Funds”), in which case personal data may be disclosed where necessary (in order to provide such services) to our professional advisers, the Funds and their service providers. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

10. How Can I Access My Personal Data?

If you want to know what personal data we hold about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a subject access request.

All subject access requests should be made in writing and sent to the email or postal address shown in Part 11. 

There is not normally any charge for a subject access request, however if your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will acknowledge receipt of your subject access request within five working days, and will generally respond to your subject access request within two weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details: 

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website, www.axebrook.com. This Privacy Notice was last updated on 1^st May 2023.