PRIVACY POLICY

Company Name: Cavenham Capital Limited (‘the Company’)
Company Contact details:
Compliance Officer,
info@cavenhamcapital.com
Date: 22 May 2018
The Company is an investment management and advisory business which provides investment management and advice to professional clients.
The Company must process personal data (including sensitive personal data) so that it can
provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on a registration
form or via our website, or we may collect them from another source such as a conference. The
Company must have a legal basis for processing your personal data. For the purposes of providing you
with investment management services and/or information relating to advice relevant to you we will only use your
personal data in accordance with this privacy statement. At all times we will comply with current data
protection laws.
Contents
1. Collection and use of personal data
a. Purpose of processing and legal basis
b. Legitimate interest
c. Statutory/contractual requirement
d. Recipients of data
2. Information to be provided when data is not collected directly from the data subject
a. Categories of data
b. Sources of data
3. Overseas transfers
4. Data retention
5. Your rights
6. Automated decision making
7. Cookies
8. Login files
9. Links to external sites
10. Sale of the business
11. Data security
12. Changes to this privacy statement
13. Complaints or queries

1. Collection and use of personal data
a. Purpose of processing and legal basis
The Company will collect your personal data (which may include sensitive personal data) and will
process your personal data for the purposes of providing you with investment advisory services. This includes
for example, contacting you about investment opportunities, assessing your suitability for those opportunities,
updating our databases, arranging payments to you and
developing and managing our services and relationship with you and our clients.
You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these
communications from us.
In some cases we may be required to use your data for the purpose of investigating, reporting and
detecting crime and also to comply with laws that apply to us. We may also use your information
during the course of internal audits to demonstrate our compliance with certain industry standards.
We must have a legal basis to process your personal data. The legal bases we rely upon to offer our
work-finding services to you are:
• Your consent, where required;
• Where we have a legitimate interest ;
• To comply with a legal obligation that we have;
• To fulfil a contractual obligation that we have with you.
b. Legitimate interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and
does not go against what you would reasonably expect from us. Where the Company has relied on a
legitimate interest to process your personal data our legitimate interests is/are as follows:
• Managing our database and keeping client records up to date;
• Providing investment management and advisory services to you and our clients;
• Contacting you to seek your consent where we need it;
• Giving you information about similar products or services that you have used from us recently;
c. Statutory/contractual requirement
The Company has certain legal and contractual requirements to collect personal data (e.g. to comply
with the regulations set by the UK Financial Conduct Authority,
immigration and tax legislation.) Our clients
may also require this personal data, and/or we may need your data to enter into a contract with you.
If you do not give us personal data we need to collect we may not be able to continue to provide investment
services to you. 
d. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following
recipients:
• Issuers of securities
• Service providers
2. Information to be provided when data collected not from the data subject
Categories of data: The Company may have collected the following personal data on you:
Personal data:
• Name, address, mobile no., email
• National insurance no. (UK) or passport number
Sensitive personal data:
• Photo identification
• Criminal convictions
• Bank details
Source of the personal data: The Company sourced your personal data/sensitive personal data:
• From data provided by you and from major websites including LinkedIn
• Software providers who we use to support our services
• Cookies listed in section 7
This information came from a publicly accessible source.
3. Overseas Transfers
The Company may transfer the information you provide to us to countries outside the European
Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps
to ensure adequate protections are in place to ensure the security of your information. The EEA
comprises the EU member states plus Norway, Iceland and Liechtenstein. 
4. Data retention
The Company will retain your personal data only for as long as is necessary for the purpose we collect
it. Different laws may also require us to keep different data for different periods of time. 
We will only keep your information for as long as is legally required by HMRC and other regulatory authorities. This is currently 3 to 6 years.
Where the Company has obtained your consent to process your personal/sensitive personal data, we
will do so in line with our retention policy. Upon expiry of that period the Company will seek further
consent from you. Where consent is not granted or where you are no longer a Client then the Company will cease to process your personal data/sensitive personal data.
5. Your rights
Please be aware that you have the following data protection rights:
• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate
interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.
Where you have consented to the Company processing your personal/sensitive personal data you
have the right to withdraw that consent at any time by contacting the Compliance Officer via email to
info@cavenhamcapital.com. Please note that if you withdraw your consent to further processing that
does not affect any processing done prior to the withdrawal of that consent, or which is done
according to another legal basis.
There may be circumstances where the Company will still need to process your data for legal or official
reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary
for those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please
contact us using the details above and we will take reasonable steps to check its accuracy and correct
it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data
we process for you, access your personal data or exercise any of the other rights listed above.
6. Automated decision-making – not applicable
7. Log Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather
broad demographic information for aggregate use. IP addresses are not linked to personally
identifiable information.
8. Links to external websites
The Company’s website may contains links to other external websites. Please be aware that the
Company is not responsible for the privacy practices of such other sites. When you leave our site we
encourage you to read the privacy statements of each and every website that collects personally
identifiable information. This privacy statement applies solely to information collected by the
Company’s website. 
9.Sale of business
If the Company’s business is sold or integrated with another business your details may be disclosed to
our advisers and any prospective purchasers and their advisers and will be passed on to the new
owners of the business.
10.Data Security
The Company takes every precaution to protect our users’ information. In addition we do not store
any financial or critical information about individuals or companies. All details provided are stored on
a secure remote server or secure external service providers that are monitored. Access to your information is available to you through by contacting us by email.
Only employees who need the information to perform a specific job are granted access to your information.
The Company uses all reasonable efforts to safeguard your personal information. However, you should
be aware that the use of email/ the Internet is not entirely secure and for this reason the Company
cannot guarantee the security or integrity of any personal information which is transferred from you
or to you via email/ the Internet.
If you have any questions about the security at our website, you can email the Compliance Officer at
info@cavenhamcapital.com
12.Changes to this privacy statement
We will update this privacy statement from time to time. We will post any changes on the statement
with revision dates. If we make any material changes, we will notify you.
13.Complaints or queries
Cavenham Capital Limited is registered with the Information Commissioner’s Office under registration number ZA473885.

If you wish to complain about this privacy notice or any of the procedures set out in it please contact:
Compliance Officer at
info@cavenhamcapital.com
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113
or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal
data be processed outside of the UK, if you believe that your data protection rights have not been
adhered to.