Last Updated: 09/05/2025

1. Introduction
   1.1. Welcome to Cudlipp & Partners LTD (“Cudlipp & Partners,” “we,” “us,” or “our”). We are a property and asset-backed investment company dedicated to providing reliable, high-yield investment opportunities and guidance to our clients. Our registered address is 6 Elaine Court, Haverstock Hill, London, England, NW3 4RT. You may contact us at info@cudlippandpartners.com or via telephone on 020 4572 4067 if you have any questions about this Privacy Policy or your personal data.

1.2. This Privacy Policy is designed to inform you about how we collect, use, store, disclose, and manage your personal information (“personal data”). By accessing our website (www.cudlippandpartners.com) or engaging with our services (collectively referred to herein as “Services”), you consent to the collection and use of your personal data in accordance with this Privacy Policy. We aim to process your data fairly, lawfully, and transparently, adhering to our obligations under the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and any other applicable data protection legislation in the United Kingdom.

1.3. We recognise the importance of preserving your privacy and maintaining the confidentiality and security of the personal data you provide to us. This Privacy Policy sets out the foundation upon which we collect personal data about you, how we use and protect that data, and the rights you have in relation to it. In addition to the content herein, we may provide supplemental information or notices to you at the point of data collection, which will further detail how your data is processed in relation to specific Services.

1.4. Please read this Privacy Policy carefully to understand our practices regarding your personal data. If you do not agree with any part of this Privacy Policy, you should refrain from using our website or engaging with our Services. We reserve the right to make changes to this Privacy Policy from time to time. Any material changes will be posted on our website, and, where appropriate, we will notify you by e-mail or other suitable means. Your continued use of our website or Services after such updates have been posted will constitute your acknowledgement and acceptance of the changes.

2. Definitions
   2.1. “Personal data” means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly, by reference to details such as name, identification number, location data, online identifier, or one or more factors that are specific to the physical, economic, cultural, or social identity of that person.

2.2. “Processing” or “process” means any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means. Such operations include collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, erasure, or destruction.

2.3. “Controller” means the natural or legal person (in this case, Cudlipp & Partners LTD) that determines the purposes and means of the processing of personal data.

2.4. “Processor” means a natural or legal person who processes personal data on behalf of the Controller.

2.5. “UK GDPR” refers to the General Data Protection Regulation as retained in UK law following Brexit, complemented by the Data Protection Act 2018.

2.6. “Website” or “Site” refers to www.cudlippandpartners.com and any subdomains or associated web pages operated by Cudlipp & Partners.

3. Information We Collect
   3.1. Personal Data You Provide Voluntarily
   We may collect personal data directly from you in various ways, including when you:
   • Sign up for our Services or create an account with us (where relevant);
   • Fill out forms on our website, such as contact forms, subscription forms, or enquiry forms;
   • Correspond with us via email, telephone, or other communication channels;
   • Subscribe to our newsletters or marketing communications (e.g. via MailChimp);
   • Submit documents or information in connection with a prospective or ongoing investment;
   • Participate in any interactive features of our website (e.g., online chat tools, if applicable);
   • Apply for a job or submit a CV through our website or third-party recruitment portals;
   • Provide feedback or respond to surveys and questionnaires.

Depending on the nature of your interaction with us, the personal data we collect may include your name, address, email address, telephone number, date of birth, financial information (e.g., bank details, investment preferences), identification documents (e.g., passport or driving licence), national insurance number, or other details necessary for compliance with legal and regulatory requirements.

3.2. Data Collected Automatically
When you visit our website, we may automatically collect certain technical and usage data through cookies and similar tracking technologies. This can include:
• IP address (anonymised where possible);
• Browser type and version;
• Time zone setting and location data;
• Operating system and platform;
• Pages you visit and how you navigate through our Site;
• The date, time, and duration of your visit;
• Other diagnostic data to analyse trends and usage of our website.

For more information on how we use cookies and similar tracking technologies, please see the “Cookies and Tracking Technologies” section (Section 10) of this Privacy Policy.

3.3. Data from Third Parties
In certain circumstances, we may obtain personal data about you from third-party sources, such as:
• Business partners or referrers who introduce you to our Services;
• Payment service providers handling transactions on our behalf;
• Identity verification and fraud prevention agencies;
• Analytics providers (e.g., Google Analytics) to help us understand how visitors interact with our website;
• Publicly available sources such as Companies House or credit reference agencies, where permissible under applicable law.

Whenever we receive personal data from third parties, we will seek to ensure they are legally permitted or required to disclose such information to us. We will also handle your data in accordance with this Privacy Policy.

4. How We Use Your Personal Data
   4.1. Overview of Purposes
   We use the personal data we collect for a variety of purposes, which may include:
   • Providing our Services: To manage your relationship with us, process any investment transactions, administer your account, and keep track of your investment portfolio or any other services you have requested from us.
   • Communication: To respond to your enquiries, send important administrative information (such as changes to our terms, conditions, or policies), and provide customer support.
   • Marketing and promotional communications: To send you updates, newsletters, investment opportunities, or other information that we believe may be of interest to you, provided that you have consented to receive such communications or we have a legitimate interest in sending them.
   • Compliance with legal obligations: To meet our obligations under anti-money laundering regulations, confirm your identity, conduct due diligence, and comply with any other laws and regulations applicable to us.
   • Improving our website and Services: To administer and improve our Site and Services, diagnose technical issues, analyse user trends, and ensure our content is presented to you in the most effective manner.
   • Security and fraud prevention: To protect our business, our clients, and our website from malicious activities, fraud attempts, or other illegal or harmful behaviour, and to enforce our terms and conditions.
   • Recruitment: If you apply for a position with us, to process your application, assess your suitability, and communicate with you about the recruitment process.

4.2. Legal Bases for Processing
Under UK GDPR and other applicable data protection legislation, we rely on the following legal bases to process your personal data:
• Consent: In certain scenarios, we will only process your personal data if you have given your explicit or implicit consent for us to do so. This is commonly used for email marketing communications where you opt to receive such information. You can withdraw your consent at any time by contacting us or using the unsubscribe link in marketing emails.
• Contractual Necessity: We often process your personal data in order to fulfil our contractual obligations to you, for instance when providing investment services, responding to your enquiries, or managing any contractual relationship we have with you.
• Legal Obligation: We may need to process your personal data to comply with legal or regulatory obligations, such as performing anti-money laundering checks or providing data to regulatory bodies when legally required.
• Legitimate Interests: In some cases, we process your personal data to pursue our legitimate interests in a way that is proportionate and respects your privacy rights. Examples include using analytics tools to improve our Services, or sending you marketing communications about similar services you have previously used, provided you have not opted out.

4.3. Marketing Communications
We may send you direct marketing by email, telephone, or post, primarily to update you about new or existing investment products, special offers, or other information that may be relevant to you. You can opt out of receiving direct marketing messages at any time by:
• Clicking on the “unsubscribe” link in the marketing email;
• Replying to the email with the word “unsubscribe” in the subject line;
• Contacting us directly at info@cudlippandpartners.com.

Please note that if you opt out of marketing communications, we may still send you non-marketing communications, such as updates regarding your account, transaction confirmations, changes to our policies, or other administrative notices.

5. Disclosure of Your Personal Data
   5.1. Our Disclosure Practices
   We will not sell, rent, or trade your personal data to third parties. We may, however, share your personal data with the following categories of recipients in limited circumstances and only where necessary to provide our Services or fulfil a legal obligation:
   • Service Providers and Processors: We may share your data with trusted third-party service providers who perform services on our behalf, such as cloud storage providers, payment processors, IT support, marketing platforms (e.g., MailChimp), analytics providers (e.g., Google Analytics), and other operational services. These parties are only permitted to process your personal data in accordance with our instructions and must adhere to appropriate security measures.
   • Professional Advisers: We may share your data with our bankers, lawyers, auditors, accountants, or other professional advisers where necessary to obtain professional advice or maintain compliance with applicable laws and regulations.
   • Regulatory Bodies and Law Enforcement: Where required by law, or where necessary to protect our rights or the rights of others, we may disclose your personal data to courts, law enforcement agencies, governmental or regulatory bodies, and other third parties.
   • Business Transfers or Corporate Transactions: In the event of a merger, acquisition, or any form of sale of some or all of our assets, we may transfer your personal data to the buyer or prospective buyer, subject to that party entering into appropriate confidentiality agreements and processing the data in accordance with applicable law.

5.2. Third-Party Links and Services
Our website may include links to third-party websites, plug-ins, or applications (“Third-Party Sites”). Clicking on these links or enabling these connections may allow third parties to collect or share data about you. We do not control these Third-Party Sites and are not responsible for their privacy policies or practices. We encourage you to read the privacy policies of every website you visit or service you use that collects personal data.

6. International Data Transfers
   6.1. Your personal data may be transferred to, and stored at, destinations outside the UK or European Economic Area (“EEA”) in cases where our service providers or partners are based in those locations. Where such transfers occur, we ensure they are lawful and that your information is kept secure, in compliance with UK GDPR and other relevant data protection regulations. We take the following measures to ensure the security of your data when transferring it internationally:
   • Adequacy Decisions: We may rely on the existence of an adequacy decision by the UK government or European Commission, confirming that the destination country provides an adequate level of data protection.
   • Standard Contractual Clauses (“SCCs”): Where no adequacy decision is in place, we may use the relevant SCCs approved by the European Commission or the UK’s International Data Transfer Agreement mechanism to ensure equivalent data protection standards apply.
   • Additional Safeguards: We may also adopt supplementary technical, organisational, and contractual measures (e.g. encryption and strict data handling policies) to further protect your personal data.

6.2. If you require more information about the specific mechanisms used when transferring your personal data outside the UK or EEA, please contact us at info@cudlippandpartners.com.

7. Data Retention
   7.1. We retain your personal data only as long as is necessary to fulfil the purposes for which it was collected. The length of time we keep your data will depend on the nature of the data and the reasons for which we are processing it. In determining retention periods, we consider the following factors:
   • Contractual requirements: We retain data needed to deliver our Services or manage our contractual relationship with you for as long as that relationship remains in effect and for a reasonable period afterwards to deal with any follow-up issues or ensure compliance with legal requirements;
   • Legal obligations: We may need to retain certain records to comply with statutory obligations, such as tax and accounting laws or regulatory requirements relating to investments and financial conduct;
   • Dispute resolution: We may retain data where necessary to resolve disputes, enforce our agreements, and protect our legal rights;
   • Legitimate interests: In certain cases, we may store personal data for a specified time based on our legitimate interest, provided that such storage does not infringe your rights and freedoms under applicable law.

7.2. Once the retention period expires or the data is no longer necessary, we will either securely delete or pseudonymise your personal data. If we are unable to delete the data (e.g., because it has been stored in backup archives), then we will securely store and isolate the data from any further processing until deletion is possible.

8. Your Rights Under Data Protection Law
   8.1. Under UK GDPR and other applicable data protection laws, you have a number of rights regarding your personal data, described below. Please note that these rights are not absolute and, in certain cases, may be subject to legal exemptions or overridden by other legal requirements.

8.2. Right to Be Informed
You have the right to receive clear, transparent, and easily understandable information about how we use your personal data. We seek to meet this right by providing this Privacy Policy and any related notices or statements at the point where we collect your data.

8.3. Right of Access
You have the right to request a copy of the personal data we hold about you, as well as information on how we process your data. We will usually provide this to you without charge unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to comply. We may also require proof of identity to ensure we do not disclose your data to the wrong person.

8.4. Right to Rectification
You have the right to have your personal data corrected if it is inaccurate or incomplete. If you become aware that any of the information we hold about you is out of date, incomplete, or incorrect, please contact us to have it rectified.

8.5. Right to Erasure (Right to Be Forgotten)
You have the right to request the erasure of your personal data in certain circumstances, such as when:
• The data is no longer necessary for the purpose it was collected;
• You withdraw your consent (where processing was based on consent) and no other legal grounds justify continued processing;
• You successfully object to the processing under certain GDPR provisions;
• The data is unlawfully processed;
• Erasure is required to comply with a legal obligation.

We will remove or anonymise any data we hold about you unless we are legally required or have overriding legitimate grounds to continue processing the data.

8.6. Right to Restrict Processing
You have the right, in certain circumstances, to restrict the processing of your personal data. This means that we may only store your data but not use it. You can exercise this right if:
• You believe your personal data is inaccurate and you want us to verify its accuracy;
• Your data has been unlawfully processed, but you prefer restriction instead of erasure;
• We no longer need your data, but you need us to keep it for a legal claim;
• You have objected to the processing, and verification of our legitimate grounds is pending.

8.7. Right to Data Portability
You have the right, in certain circumstances, to receive your personal data in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer your data to another controller where technically feasible. This right applies only where the processing is based on your consent or on a contract and the processing is carried out by automated means.

8.8. Right to Object
In certain circumstances, you have the right to object to our processing of your personal data, including when the processing is for direct marketing or based on our legitimate interests. If you object, we will stop processing your personal data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or if processing is required for the establishment, exercise, or defence of legal claims.

8.9. Right Not to Be Subject to Automated Decision-Making
You have the right not to be subject to decisions based solely on automated processing, including profiling, which have legal or similarly significant effects on you. We do not currently engage in automated decision-making that produces legal or similarly significant effects based on your personal data. If this changes, we will inform you and update this Privacy Policy accordingly.

8.10. Exercising Your Rights
To exercise any of these rights, please contact us at info@cudlippandpartners.com with “Data Subject Request” in the subject line, specifying which right you wish to exercise. We will respond to your request as soon as is reasonably practicable and within any timeframe stipulated under applicable data protection laws. Please note that we may ask for additional information to verify your identity before processing your request.

9. Security Measures
   9.1. We maintain appropriate technical and organisational measures to protect your personal data from unauthorised or unlawful processing, accidental loss, destruction, or damage. These measures include:
   • Secure servers and encrypted data storage;
   • Firewalls and anti-virus software to protect against malicious attacks;
   • Access controls and user authentication procedures to limit access to your personal data;
   • Regular security audits and vulnerability assessments;
   • Staff training and data protection awareness programmes.

9.2. Although we make every effort to protect your personal data, please note that no transmission of data over the internet or electronic storage method can be guaranteed to be 100% secure. Therefore, we cannot fully guarantee the security of any information you transmit to us, and you provide it at your own risk. If you have reason to believe that the security of your data has been compromised, please contact us immediately.

10. Cookies and Tracking Technologies
    10.1. We use cookies and similar technologies (“Cookies”) to collect information about your interactions with our website. Cookies are small text files that websites place on your device to remember you when you return or browse from one page to another. Cookies help us enhance user experience, analyse site performance, and offer relevant services or advertisements.

10.2. Types of Cookies We Use
• Strictly Necessary Cookies: These Cookies are essential for the website to function properly and enable you to navigate the website, make use of its essential features, or access secure areas. Disabling these Cookies may impair the website’s performance.
• Functional Cookies: These Cookies allow the website to remember choices you make and provide enhanced, more personalised features (e.g., remembering your login details or the region you are in).
• Analytical/Performance Cookies: These Cookies collect anonymous information about how you use our Site (e.g., which pages you visit most often), which we use to improve how our Site works. For example, we use Google Analytics to analyse usage patterns and track how users move through our Site.
• Targeting or Advertising Cookies: These Cookies may be set by third-party advertising networks to build a profile of your interests and display relevant adverts on other sites.

10.3. How to Manage Cookies
You can control and manage Cookies through your browser settings. Most web browsers automatically accept Cookies, but you can usually modify your browser settings to decline Cookies if you prefer. You can also delete Cookies that have already been set. However, please note that disabling some Cookies may affect your ability to access certain features of our website.

10.4. Third-Party Cookies
We may allow certain trusted third parties, such as analytics providers and advertising partners, to place Cookies on our Site to collect information about your online activities over time and across different sites. This information is collected to help us measure the usage of our website, display content tailored to your interests, or gauge the effectiveness of our marketing campaigns. These third parties may also collect personal data about your online activities over time and across different websites, subject to their own privacy policies. We encourage you to review the privacy policies of these third parties to understand their data practices.

11. Children’s Privacy
    11.1. Our Services are not directed to individuals under the age of 18, and we do not knowingly collect personal data from children. If you are under 18, please do not submit any personal data to us. If you believe that we have mistakenly or unintentionally collected personal data from a child under the age of 18, please contact us at info@cudlippandpartners.com so that we can delete the information as soon as possible.

12. Investment-Related Disclosures
    12.1. As a property and asset-backed investment company, Cudlipp & Partners LTD may collect additional personal data related to your financial situation, investment preferences, and transaction history. This may include identifying your status as a retail investor, sophisticated investor, or high-net-worth individual. We may also process data and documentation to comply with Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) checks, including proof of identity and proof of address.
    12.2. All financial data we collect is processed solely for the purpose of administering your investments and complying with relevant regulations. We make every effort to use secure methods when transmitting, storing, or handling financial information, including encryption and password protection.
    12.3. Should you have any concerns about how your financial data is being processed, you may contact us for further details.

13. Data Quality and Accuracy
    13.1. We rely on you to ensure that the personal data you provide is accurate, complete, and up-to-date. Please inform us of any changes to your personal data so that we can maintain accurate records. Failing to provide accurate data may affect your ability to use our Services or receive important notices from us.
    13.2. Where you have created an online account with us, you may have the ability to update your details by logging in and editing your account profile. Otherwise, please let us know by contacting info@cudlippandpartners.com, and we will correct or update the relevant information promptly.

14. Complaints and Dispute Resolution
    14.1. We are committed to resolving any complaints about our collection or use of your personal data. If you have a complaint regarding our processing of your personal data, please contact us initially at info@cudlippandpartners.com with the subject line “Privacy Complaint.” We will investigate and endeavour to respond to your complaint within a reasonable time.
    14.2. If you are not satisfied with our response or believe we have not complied with data protection laws, you have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues. The ICO’s contact details are as follows:
    Website: www.ico.org.uk
    Telephone: 0303 123 1113
    Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

15. Your Obligations
    15.1. By using our website and Services, you agree to:
    • Provide accurate and up-to-date personal data where required;
    • Comply with all applicable data protection and privacy regulations when providing personal data to us, including, but not limited to, any obligations you may have in relation to personal data of other individuals (e.g., if you are disclosing someone else’s data for emergency contact purposes or as referees);
    • Promptly notify us if any of your personal data changes or appears to be inaccurate.

16. Corporate Changes and Restructuring
    16.1. If Cudlipp & Partners undergoes any business transitions such as mergers, acquisitions, corporate divestitures, or dissolution, your personal data may be transferred as part of that transaction. Where any such transfer occurs, we will ensure your personal data continues to be used in accordance with this Privacy Policy, or, if materially different, we will notify you of any changes.

17. Third-Party Websites and Social Media
    17.1. Our website may include social media features, such as the “Share” or “Like” button, or interactive mini-programmes that run on our Site. These features may collect your IP address, record which page you are visiting on our Site, and set a Cookie to enable the feature to function properly. Social media features and widgets may be hosted by a third party or directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing them.

18. Record-Keeping
    18.1. As part of our obligations under UK data protection laws, we keep detailed records of our data processing activities, including the categories of data processed, the purposes for which personal data is used, any transfers of data to third parties or outside the UK/EEA, and the technical and organisational security measures in place. These records help us demonstrate compliance to regulatory bodies and provide a roadmap for how and why we process personal data.

19. Data Protection Officer (DPO)
    19.1. We may appoint a Data Protection Officer (“DPO”) or an equivalent responsible individual to oversee compliance with data protection rules. If we appoint a DPO in the future, we will update this Privacy Policy to include their contact details. For now, any queries or concerns about data protection, or any other aspect of this Privacy Policy, should be addressed to info@cudlippandpartners.com.

20. Liability and Disclaimers
    20.1. While we endeavour to ensure that all information on our Site is accurate and up to date, and that your personal data is governed by strict security standards, we make no explicit guarantees or warranties. We shall not be held liable for any indirect, incidental, consequential, or punitive damages resulting from your use of the Site or any personal data breach unless as expressly required by law.
    20.2. Nothing in this Privacy Policy shall limit or exclude liability for death or personal injury resulting from negligence, fraud or fraudulent misrepresentation, or any other liability which cannot be lawfully limited or excluded.

21. Retaining and Accessing Investment Records
    21.1. In compliance with financial regulation, we may be required to keep certain records relating to your investments (including personal data) for a prescribed minimum period—often five years or longer, depending on the regulation. This helps ensure that we have records available in the event of an audit, dispute, or regulatory inspection.
    21.2. You may request information on the nature of these records, how long we intend to keep them, and under what circumstances they may be erased or archived by contacting info@cudlippandpartners.com.

22. Email and Communications Security
    22.1. Please be aware that email communications are not always secure. We encourage you to use caution when sending personal or financial information via email. We will never request you to send passwords or sensitive data via email. If we need to verify your financial details or identification documents, we will use secure upload portals or similarly encrypted methods to receive those documents wherever possible.

23. Changes to This Privacy Policy
    23.1. We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. For significant changes, we may notify you via email and/or a prominent notice on our website prior to the changes becoming effective.
    23.2. The “Last Updated” date at the top of this Privacy Policy will indicate when it was most recently revised. Your continued use of our Site or Services after the revised Privacy Policy has become effective indicates that you have read and understood the current policy.

24. Contact Us
    24.1. If you have any questions, concerns, or comments about this Privacy Policy, your personal data, or any data protection and privacy issues in general, please contact us:
    • By email: info@cudlippandpartners.com
    • By phone: 020 4572 4067
    • By post: Cudlipp & Partners LTD, 6 Elaine Court, Haverstock Hill, London, England, NW3 4RT

25. Summary of Key Points
    25.1. Cudlipp & Partners LTD is a property and asset-backed investment company dedicated to providing secure and high-yield investment opportunities. In doing so, we respect your privacy and are committed to safeguarding any personal data you provide.
    25.2. We collect personal data through direct interactions, automated technologies (e.g., cookies), and from third-party sources, always ensuring a lawful basis for processing such data.
    25.3. We use personal data for a range of purposes, including providing our Services, handling communications, sending marketing messages, fulfilling legal obligations, and improving our website’s performance.
    25.4. Your personal data may be shared with trusted service providers and regulators, but we never sell or trade your data to third parties. Where transfers of data occur outside the UK or EEA, we ensure adequate safeguards are in place.
    25.5. We retain personal data for as long as necessary to fulfil the purposes for which it was collected, and in accordance with any legal or regulatory requirements.
    25.6. You have rights under data protection law to access, rectify, erase, restrict, or object to the processing of your personal data, as well as to request data portability and withdraw consent at any time.
    25.7. Although we implement rigorous security measures to protect your personal data, we cannot guarantee absolute security. Please take precautions when transmitting sensitive information to us.
    25.8. We encourage you to read this Privacy Policy in full to understand our data practices, and to contact us if you have any further questions or concerns.

26. Additional Investor Protections
    26.1. As part of our duty to protect our clients’ interests, we maintain robust internal controls and governance procedures around the way we handle personal data tied to investments. We regularly review and test our systems for vulnerabilities and weaknesses, particularly those related to financial transactions.
    26.2. We also engage in periodic data protection impact assessments (DPIAs) for significant processing operations, especially when launching new investment products, implementing new technologies, or expanding into new geographic markets, to ensure that we identify and mitigate privacy risks to the extent possible.

27. Audits and Accountability
    27.1. Cudlipp & Partners LTD recognises the importance of accountability. We maintain detailed records of our data processing, including categories of personal data held, purposes of processing, any external data recipients, international transfers, and retention schedules.
    27.2. We subject these records to internal audits and may enlist external auditors to verify our ongoing compliance with data protection requirements. This proactive stance helps ensure we identify and resolve issues promptly, maintaining the high standards expected by our clients, partners, and regulators alike.

28. Staff Training and Confidentiality
    28.1. All personnel who handle personal data for Cudlipp & Partners LTD receive training on data protection, information security, and confidentiality. We ensure staff are aware of their roles and responsibilities in processing personal data, as well as the potential consequences of non-compliance.
    28.2. Employees are bound by confidentiality agreements and are prohibited from disclosing personal data to unauthorised parties. Disciplinary measures may be enforced for any breach of data protection policies.

29. Special Categories of Personal Data
    29.1. We generally do not seek to collect “special category” personal data, such as data concerning health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or genetic and biometric data, except where strictly necessary and with your explicit consent. If you voluntarily provide us with such data, we will process it in line with data protection laws and only for the necessary purpose it was provided.

30. Data Protection Impact Assessments (DPIAs)
    30.1. Where we envisage a new processing activity that is likely to result in a high risk to the rights and freedoms of data subjects, we conduct a DPIA. This helps us identify and minimise potential risks associated with the proposed processing. Depending on the outcome of the DPIA, we may consult the ICO or relevant supervisory authority before proceeding.

31. Monitoring and Enforcement
    31.1. We regularly monitor our data protection compliance and address any issues or breaches in a timely manner. In the unfortunate event of a personal data breach that poses a risk to your rights and freedoms, we will notify you and the relevant supervisory authority, typically within 72 hours, in accordance with our legal obligations.
    31.2. If you suspect any misuse or unauthorised access to your personal data, we urge you to notify us immediately at info@cudlippandpartners.com so we can investigate and take appropriate remedial actions.

32. Financial Promotions and Regulatory Compliance
    32.1. As an investment firm, Cudlipp & Partners may be subject to the regulation and oversight of financial and securities authorities. We may be required to collect, process, and retain certain personal data to comply with these regulatory frameworks. This includes verifying investor eligibility, ensuring compliance with financial promotion rules, and supporting regulatory audits or enquiries.
    32.2. In some instances, we may be obligated to share your personal data with regulatory or governmental authorities upon request, and where permitted by law. We assure you that any such disclosure will be managed securely and lawfully, ensuring that only the minimum necessary information is shared.

33. Cookies Within Email Communications
    33.1. Our email marketing campaigns may sometimes use tracking technologies to see whether emails are opened and which links recipients click on. This information helps us measure the effectiveness of our email campaigns and improve the content we deliver to you. You can disable image loading in your email client to reduce or eliminate such tracking techniques, or you may unsubscribe from marketing emails altogether by following the instructions provided in each email.

34. Data Collection in Offline Interactions
    34.1. We may, from time to time, collect personal data in offline contexts, such as at networking events, seminars, meetings, or when you contact us over the phone. Regardless of the collection context, our commitment to data protection remains, and we will ensure your data is processed in line with this Privacy Policy.
    34.2. Any offline records containing personal data (such as paper forms) are securely stored, restricted to authorised personnel, and disposed of via secure shredding once retention is no longer required.

35. Profiling
    35.1. We may use limited profiling techniques to provide you with services and content tailored to your investment interests and financial profile. For instance, we may use data about your investment history to predict which products might be most suitable for you.
    35.2. However, we do not engage in fully automated decision-making that produces legal or similarly significant effects. Any suggestions or personalisations made through profiling are subject to human oversight. If you object to this type of personalisation, you may contact us to have such processing restricted or clarified.

36. Minors and Consent
    36.1. Where we become aware that children’s personal data has inadvertently been collected, we will endeavour to erase it promptly. Parents or guardians who believe we may have collected data about their child should notify us at info@cudlippandpartners.com.
    36.2. If you are under 18, please do not provide us with any personal data. You should consult with a parent or guardian before using any of our Services.

37. Corporate Clients and Business Contacts
    37.1. If you are a corporate client or a representative of a business, we may process your work contact details and professional information for the purposes of managing our relationship, negotiating or performing a contract, or sharing updates relevant to our joint activities or the Services in which we both have an interest.
    37.2. This Privacy Policy applies to any personal data we hold about you in your capacity as a business representative, except where specific contractual data protection provisions override these terms.

38. Jurisdiction-Specific Provisions
    38.1. Although we are a UK-based entity, we acknowledge that we may have users or clients from other jurisdictions. For users situated in the European Economic Area, or other locations, the relevant data protection laws may apply to certain aspects of our processing. Where required, we will comply with those laws in addition to UK data protection legislation.
    38.2. Any dispute or claim arising out of or in connection with this Privacy Policy shall be governed by and construed in accordance with the laws of England and Wales, and the English courts shall have exclusive jurisdiction unless otherwise required by mandatory local laws.

39. Conclusion and Acceptance
    39.1. We value your privacy, and this Privacy Policy is a testament to our commitment to responsibly process and protect your personal data. By continuing to use our website and Services, you acknowledge that you have read and understood this Privacy Policy and agree to our handling of personal data as stated herein.
    39.2. If you have any queries regarding this Privacy Policy or wish to exercise any of your statutory rights, please contact us at info@cudlippandpartners.com or write to us at our registered address:
    Cudlipp & Partners LTD
    6 Elaine Court
    Haverstock Hill
    London
    England
    NW3 4RT

39.3. We encourage you to stay updated with the latest version of our Privacy Policy by visiting our website periodically.

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Thank you for taking the time to read this Privacy Policy. Your trust is important to us, and we strive every day to earn and maintain that trust by applying the highest standards of privacy and data protection in all aspects of our operations.

Cudlipp & Partners LTD © 2025. All rights reserved.
Registered Address: 6 Elaine Court, Haverstock Hill, London, England, NW3 4RT
Email: info@cudlippandpartners.com | Phone: 020 4572 4067