Privacy Notice

Introduction

Castlebar Capital LLP (the “Firm”) is committed to protecting and respecting your privacy. This Policy explains how your personal information is processed by the Firm, including any affiliates listed in the Data Controllers and Contact section below (hereinafter also collectively referred to as “us”, or “we”).

This notice explains how Castlebar Capital LLP uses personal information about people outside the Firm. It applies to you if you are:

an investor or prospective investor in a fund we manage, or a separately managed account client or prospective client, or someone connected with one — for example a director, beneficial owner or authorised signatory;
someone who works for a company whose securities we research, hold or trade, or for a broker, bank, law firm, accountant or other adviser we deal with;
someone who works for one of our suppliers or service providers;
applying to us for a role, or sending us a CV or expression of interest;
a visitor to our website, or someone who contacts us through it.

If you work for the Firm, or are a member or contractor, a separate notice applies to you.

Who we are and how to contact us

Castlebar Capital LLP is the data controller for the personal information described in this notice. We are authorised and regulated by the Financial Conduct Authority.

Firm: Castlebar Capital LLP
Registered number: OC445484
Address: 7 Stratford Place, London, W1C 1AY
Email: coralie.yeo@castlebar-capital.com
Telephone: +44 (0)20 3836 2313

We have not appointed a data protection officer. Questions about this notice, and requests to exercise your rights, should go to the contact above.

The information we collect

Investors, clients and people connected with them

Your name, address, email address and telephone number; date of birth and nationality; your employer, position and business contact details; information about your financial circumstances, including your profession, income, assets and liabilities; your tax status and tax identification numbers; your bank details; details of your holdings, subscriptions, redemptions and dealing history; and the documents and checks we are required to carry out under anti-money-laundering legislation, which can include information about criminal convictions and about whether you hold a prominent public position.

People who work for counterparties, issuers, brokers and advisers

In researching and executing our investment strategy we hold the names, job titles and business contact details of individuals who work for the companies whose securities we research, hold or trade, and for the brokers, banks, law firms, accountants and other advisers we deal with. Where we are given confidential or inside information we are also required to record the names of the individuals involved and the date they received it.

This is business information about you in your professional capacity. We do not build profiles of you and we do not use it for marketing.

People who work for our suppliers and service providers

Your name, position and business contact details, and where relevant the details we need to pay invoices and to carry out anti-money-laundering and sanctions checks.

Job applicants

Your name and contact details, your employment history and qualifications, and anything else you choose to send us. If we take your application forward we will also collect references and, before any appointment, the background checks the Financial Conduct Authority requires us to carry out.

Website visitors and people who contact us

If you use the contact form on our website we receive the name, email address and message you submit, together with anything you attach. Our website records limited technical information about visits, as described in section 12.

Where we get your information

Most often, directly from you. We also obtain information:

from our fund administrator, and from the advisers, intermediaries and placement agents who introduce investors to us;
from publicly available sources, in particular company filings and announcements, offering documents, regulatory registers such as the FCA Register and Companies House, corporate websites, and press and market coverage;
from screening and due diligence providers, where we are required to carry out anti-money-laundering, sanctions or adverse media checks;
from our business dealings with the organisation you work for.

Where we obtain business contact information from public sources, contacting every individual concerned would involve disproportionate effort. In those cases we make this notice available on our website instead, which is what UK data protection law permits.

Why we use your information, and our lawful basis

We must have a lawful basis for using your personal information. The bases we rely on are set out below.

If you are an investor or client

- Accepting and administering your investment or mandate, maintaining the register, processing subscriptions and redemptions, paying distributions, and reporting to you - performance of a contract with you, or steps taken at your request before entering one (Article 6(1)(b)).
- Anti-money-laundering, sanctions and tax reporting checks, and keeping the records we are required to keep - compliance with a legal obligation (Article 6(1)(c)).

If you are a prospective investor or client

- Telling you about the funds and services we offer, where you or your adviser has asked us to or where we reasonably believe it is of interest to you professionally - our legitimate interests in developing our business (Article 6(1)(f)). You can object at any time.

If you work for a counterparty, issuer, broker or adviser

- Researching investments, dealing with counterparties, executing and settling transactions, and maintaining the business relationships our strategy depends on - our legitimate interests in running our investment business (Article 6(1)(f)). You can object at any time.
- Recording who has received confidential or inside information, and monitoring for market abuse - compliance with a legal obligation (Article 6(1)(c)).

If you work for a supplier or service provider

- Managing the relationship, obtaining services and paying invoices - performance of a contract, and our legitimate interests in administering our supplier relationships (Article 6(1)(b) and (f)).

If you are a job applicant

- Considering your application and communicating with you about it - our legitimate interests in recruiting, and steps prior to entering a contract of employment (Article 6(1)(f) and (b)).
- Keeping your details on file after an unsuccessful application, in case a suitable role arises - your consent, which you can withdraw at any time (Article 6(1)(a)).

Everyone

- Running our business - IT and security, internal administration, record keeping, insurance, professional advice, and establishing or defending legal claims - our legitimate interests in operating the Firm (Article 6(1)(f)), and compliance with legal obligations (Article 6(1)(c)).

Sensitive information

Some information needs extra protection under data protection law. We only handle it where we have to.

Information about criminal convictions and offences. Our anti-money-laundering and sanctions checks can reveal this. We process it because we are required to by law and because it is necessary in the substantial public interest of preventing financial crime, relying on the conditions in Schedule 1 to the Data Protection Act 2018 for the prevention and detection of unlawful acts and for regulatory requirements.

Special category information. We do not seek information about your health, ethnicity, religion, politics, trade union membership, genetics, biometrics or sexual orientation. Occasionally it appears in documents provided to us or in public sources. Where that happens we rely on the condition that the information has been made public by you, or on the substantial public interest conditions above, and we do not use it for any purpose other than the one for which the document was provided.

Who we share your information with

We do not sell your personal information. We may share it with the following, we can give you a current list of the providers we use on request:

The funds we manage and their service providers - including our fund administrator, transfer agent, depositary, custodian and the funds' auditors and legal advisers.
Brokers, banks and counterparties - where necessary to execute and settle transactions.
Our professional advisers - our auditors, accountants, lawyers and compliance consultants.
Our IT and software providers - including Microsoft, our managed IT provider, our website and hosting providers, and the provider of the artificial intelligence assistance tool we use internally. These providers act on our instructions and may not use your information for their own purposes.
Regulators, law enforcement, courts and tax authorities - where we are required or permitted to disclose information, including to the Financial Conduct Authority and HM Revenue & Customs.
A prospective purchaser - if we sell or merge part of our business, subject to appropriate confidentiality protections.

Where your information is held, and transfers outside the UK

Our own records are held in the United Kingdom, in our offices and on systems we control.

Some of the providers we use are based outside the United Kingdom, principally in the United States. This includes providers of cloud software, website hosting and content delivery, and the artificial intelligence assistance tool we use for internal drafting and administration. Some providers also replicate backups across data centres in other countries for resilience.

Where we transfer your personal information outside the United Kingdom, we do so under the International Data Transfer Addendum to the European Commission's standard contractual clauses, or under another transfer mechanism recognised by UK data protection law. You can ask us for a copy of the safeguards we rely on using the contact details in section 1.

Automated decisions and artificial intelligence

We may use artificial intelligence tools to help with tasks such as drafting, summarising documents and building internal reporting. Our internal policy restricts what may be put into those tools, a member of our team initiates and reviews every use, and the output is never used to make a decision about you. We do not permit our providers to use information we submit to train their models.

How long we keep your information

Investor and client records, including anti-money-laundering records— seven years after the end of the relationship, or longer where a regulator, tax authority or law requires it.
Business contact details of counterparty, adviser and supplier personnel- seven years from our last contact with you.
Records of who received confidential or inside information- seven years from the date of the record.
Unsuccessful job applications- two years, unless you ask us to delete them sooner.
Website enquiries that do not lead to a relationship- seven years, in line with the retention period that applies to our business communications generally.

At the end of these periods we delete the information or anonymise it so it can no longer identify you.

Do you have to give us your information?

If you are investing with us or becoming a client, some information we are legally required to collect, in particular anti-money-laundering and tax information. If you do not provide it we will not be able to accept your investment or act for you. Everything else is voluntary, although it may limit what we can do for you.

Your rights

You have the following rights over your personal information. They do not all apply in every situation, and they are subject to our own legal and regulatory obligations, for example we cannot delete records we are required to keep.

Be informed: to be told how we use your personal information, which is what this notice is for.
Access: to ask for a copy of the personal information we hold about you.
Rectification: to ask us to correct information that is inaccurate or incomplete.
Erasure: to ask us to delete your information, where we have no continuing reason to keep it.
Restriction: to ask us to limit how we use your information while a query about it is resolved.
Portability: to ask us to transfer certain information to you or another organisation in a machine-readable form.
Object: to object to our using your information where we rely on our legitimate interests, and to object at any time to direct marketing.
Automated decisions: rights in relation to decisions taken about you by automated means. We do not take such decisions; see section 8.

To exercise any of these rights, contact us using the details in section 1. We will respond within one month, and will tell you if we need longer because your request is complex. There is normally no charge.

A cookie is a small file that a website places on your device. Our website is built on the Wix platform and uses only cookies set by that platform. We do not use advertising cookies, social media cookies or cross-site tracking, and we do not share cookie data with anyone for their own purposes.

The cookies we use

XSRF-TOKEN — security; protects against a form of attack that misuses your session. Expires when you close your browser.
hs — security. Expires when you close your browser.
server-session-bind — security; links your session to the server handling it. Expires when you close your browser.
svSession — identifies your browser so our website behaves consistently as you move between pages, and lets us count how many people visit. Expires after 13 months.
bSession — used by the Wix platform to monitor how our website is performing. Expires the same day.

Under the Privacy and Electronic Communications Regulations, as amended by the Data (Use and Access) Act 2025, consent is not needed for cookies that are strictly necessary for a website to work, or that are used only to obtain statistical information about how it is used. The cookies above fall into those two categories.

We use the information only to keep our website working and secure and to understand in general terms how it is used. We do not use it for advertising, marketing or profiling, we do not build a picture of you as an individual, and we do not combine it with information from other sources.

You can block or delete cookies through your browser settings, and every major browser lets you do this for a particular website as well as generally. The settings are usually found under Privacy or Site Settings, and your browser's help pages explain how. If you block the cookies above, parts of our website may not work properly.

If you have any question about our use of cookies, please contact us using the details in section 1.

How to complain

If you are unhappy with how we have handled your personal information, please contact us using the details in section 1. We will acknowledge your complaint within 30 days and respond as soon as we are able. If you are not satisfied with our response, you can complain to the Information Commissioner's Office:

- Online at ico.org.uk/make-a-complaint

- By telephone on 0303 123 1113

- By post to the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

You can complain to the Information Commissioner at any time. You do not have to come to us first, although it will often be quicker if you do.

Changes to this notice

We review this notice at least once a year and whenever our processing changes materially. The current version is always the one published on our website, and the date and version number appear at the top. Where we make a change that materially affects how we use your personal information, we will tell you directly.