Privacy Policy

Last updated August 2026

Capel Asset Management (“Capel”)

1. Introduction

Capel Asset Management (“Capel”, “we”, “us” or “our”) is committed to protecting personal data and being transparent about how we collect, use and share information. This Privacy Policy explains how we process personal data relating to clients, prospective clients, intermediaries, professional contacts, suppliers, website users and other individuals who engage with Capel.

This policy is intended to support compliance with the UK General Data Protection Regulation, the Data Protection Act 2018 and applicable regulatory expectations for firms handling financial and client information. It should be reviewed against Capel’s actual operating model, regulatory permissions and internal data map before publication.

2. Who we are

For the purposes of data protection law, Capel will usually act as the data controller for the personal data described in this policy. This means Capel decides why and how personal data is processed.

Contact details: Suite 2.04, 20 North Audley Street, London, W1K 6WE, info@capelasset.com.

3. Personal data we collect

· Identity and contact details, such as name, address, date of birth, email address, telephone number, signatures and proof of identity.

· Financial and investment information, such as portfolio details, investment objectives, risk profile, transaction history, bank account information, source of funds and tax status.

· Regulatory and due diligence information, including anti-money laundering checks, sanctions screening, politically exposed person checks and client classification information.

· Communications information, such as emails, meeting notes, call records and records of instructions or enquiries.

· Website and technical information, such as IP address, device information, browser type, cookie identifiers and analytics data.

· Supplier, adviser and professional contact information required to manage business relationships.

4. How we use personal data

· To assess suitability, provide investment management services and administer client accounts.

· To verify identity, carry out onboarding checks and meet anti-money laundering, sanctions, tax reporting and other legal or regulatory obligations.

· To communicate with clients, advisers, custodians, administrators and other relevant parties.

· To manage risk, governance, audit, compliance monitoring, complaints and record keeping.

· To maintain the security and resilience of our systems, premises and services.

· To manage supplier relationships and internal business operations.

· To send service updates, market commentary or marketing communications where permitted by law or where consent has been obtained.

5. Lawful bases for processing

Capel processes personal data only where it has a lawful basis to do so. Depending on the circumstances, we may rely on: performance of a contract; compliance with a legal obligation; our legitimate interests in operating and protecting our business, managing client relationships and meeting regulatory expectations; consent, where required; or, in limited cases, the establishment, exercise or defence of legal claims.

6. Sharing personal data

We may share personal data with custodians, administrators, platform providers, brokers, banks, professional advisers, auditors, insurers, IT and cloud service providers, identity verification providers, regulators, tax authorities, law enforcement agencies and other parties where necessary to provide services, comply with law, manage risk or protect our rights. We require service providers to protect personal data and use it only for authorised purposes.

7. International transfers

Where personal data is transferred outside the United Kingdom, Capel will ensure that appropriate safeguards are in place. These may include adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU standard contractual clauses, or another transfer mechanism permitted under data protection law.

8. Retention

Capel keeps personal data only for as long as necessary for the purposes for which it was collected, including to provide services, meet legal and regulatory obligations, resolve disputes and maintain business records. Retention periods may vary depending on the type of data, the relationship with Capel and applicable regulatory or statutory requirements.

9. Security

Capel uses appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. These measures may include access controls, staff training, secure systems, supplier due diligence, backup procedures and incident response processes.

10. Your rights

Individuals may have rights to request access to personal data, correction, erasure, restriction, portability, objection to processing and withdrawal of consent where processing is based on consent. These rights are subject to legal limits and may not apply in every circumstance. To exercise these rights, please contact Capel using the details in this policy.

11. Cookies and website data

If Capel operates a website, it may use cookies or similar technologies to make the site work, improve performance, understand usage and support communications. Where required, Capel will obtain consent before placing non-essential cookies and will provide further information in a cookie notice or preference tool.

12. Complaints

If you have concerns about how Capel handles personal data, please contact us first so that we can try to resolve your concern. You also have the right to complain to the UK Information Commissioner’s Office.

13. Changes to this policy

Capel may update this Privacy Policy from time to time to reflect changes in law, regulation, guidance or business operations. The latest version should be made available through Capel’s usual client and website channels.