Privacy Policy

---

EFFECTIVE DATE: 30 JUNE 2025

I. INTRODUCTION

This Privacy Policy (“Policy”) is issued by Longshanks Capital Ltd (“Longshanks Capital,” “we,” “us,” or “our”), a proprietary trading firm incorporated under the laws of England and Wales under Company No. 16036454, with its registered office located at 20 Wenlock Road, London, England, N1 7GU—with the principal purpose of providing detailed notice concerning the collection, use, processing, retention, disclosure, protection, and transfer of personal information (“Personal Data”) in connection with the services and activities conducted by or on behalf of Longshanks Capital.

This Policy is intended to inform all data subjects (“you” or “your”), including but not limited to current and prospective clients, employees, contractors, vendors, service providers, website visitors, and any other individuals whose Personal 

Data Longshanks Capital may process their rights and how their data will be handled in full compliance with all applicable laws, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA), and other relevant regulatory frameworks.

While Longshanks Capital endeavors to employ rigorous data protection and privacy measures, the Policy also serves to limit and disclaim liability to the fullest extent permitted by applicable law.

II. DEFINITIONS

For this Policy, the following terms shall have the meanings ascribed below unless otherwise expressly indicated:

• “Personal Data” means any information relating to an identified or identifiable natural person.
• “Processing” refers to any operation or set of operations performed upon Personal Data, including but not limited to collection, recording, organization, storage, alteration, retrieval, consultation, use, disclosure, transmission, erasure, or destruction.
• “Data Subject” means any individual whose Personal Data is processed by Longshanks Capital.
• “Controller” means the entity that determines the purposes and means of processing Personal Data; herein, Longshanks Capital.
• “Processor” means a third party processing Personal Data on behalf of Longshanks Capital.
• “Consent” means any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which they signify agreement to the Processing of Personal Data relating to them.
• “Applicable Law” means all applicable statutory laws, regulations, regulatory guidance, orders, and binding decisions relating to data protection and privacy.
• “Third Country” means a country or territory outside the United Kingdom or the European Economic Area (“EEA”) that is not subject to an adequacy decision by the UK Information Commissioner’s Office.

III. CATEGORIES AND SOURCES OF PERSONAL DATA

We may collect, receive, and process various categories of Personal Data, including, but not limited to:

1. Identity Data: such as full name, gender, date of birth, government-issued identification numbers, and passport or other national identity documentation.
2. Contact Data: including telephone numbers, email addresses, and residential and business addresses.
3. Financial and Transactional Data: bank account details, payment card information, transaction history, trading orders, account balances, creditworthiness, and investment profiles.
4. Employment and Professional Data: job title, employer, employment history, qualifications, references, and relevant professional memberships.
5. Technical and Online Data: IP address, device identifiers, browser type and version, operating system, geolocation data, cookies and tracking technologies, and logs of interactions with our digital platforms.
6. Communications Data: content and metadata of correspondence, including emails, telephone calls, chat sessions, and video conferences.
7. Compliance and Screening Data: information gathered for anti-money laundering (AML), know-your-customer (KYC), counter-terrorism financing, sanctions screening, Politically Exposed Persons (PEP) lists, and other regulatory obligations.
8. Behavioral and Profile Data: derived data including risk tolerance, investment preferences, user profiling, and marketing preferences.
9. Third-Party Data: data lawfully obtained from third parties, such as credit reference agencies, public registries, or business partners.

The Personal Data we process may be provided directly by you or collected from third-party sources to the extent permitted by law.

IV. PURPOSES AND LEGAL BASES OF PROCESSING

Longshanks Capital processes Personal Data for specific, explicit, and legitimate purposes, including, but not limited to, the following:

4.1. To Perform and Manage Contracts:
Processing is necessary for the negotiation, execution, performance, and administration of contracts between Longshanks Capital and you, including client agreements, employment contracts, vendor engagements, and service arrangements.

4.2. To Comply With Legal and Regulatory Obligations:
Processing to satisfy Longshanks Capital’s obligations under applicable laws, including anti-money laundering laws, tax reporting, regulatory filings, fraud prevention, financial crime detection, investigations, and cooperation with governmental authorities.

4.3. To Pursue Legitimate Interests:
Longshanks Capital may process Personal Data to further its legitimate business interests, including but not limited to risk management, internal audit, business continuity, security, fraud detection and prevention, client relationship management, business development, and enforcement of contractual rights, provided that such interests do not override your fundamental rights and freedoms.

4.4. To Obtain and Manage Consent:
Where processing is based on your explicit consent, we shall ensure that such consent is freely given, informed, specific, and unambiguous, and that it may be withdrawn at any time without detriment.

4.5. To Protect Vital Interests:
In rare cases, Processing may be necessary to protect your or another person’s life or physical integrity.

4.6. To Conduct Marketing and Communications:
Processing may be undertaken for direct marketing and communication purposes, strictly per your marketing preferences and applicable legal frameworks.

V. METHODS AND MODES OF PROCESSING

Longshanks Capital utilizes manual and automated means to collect and Process Personal Data, which may include:

• Direct collection via websites, mobile applications, emails, telephone, face-to-face meetings, and correspondence.
• Automated collection through website cookies, session recordings, analytics, and monitoring software.
• Receipt from third parties, including regulatory bodies, financial institutions, credit reference agencies, public databases, and service providers.
• Internal system records, audit logs, transaction reports, and compliance databases.

VI. SHARING AND DISCLOSURE OF PERSONAL DATA

Longshanks Capital will not sell or rent your Personal Data to third parties. We may disclose Personal Data to:

6.1. Service Providers and Processors:
We engage third-party providers to perform business services, including IT and cloud hosting, data processing, legal, accounting, compliance, payroll, and customer relationship management, subject to stringent contractual data protection obligations.

6.2. Financial Institutions and Counterparties:
Banks, brokers, custodians, and other financial entities are involved in transactional and operational processes.

6.3. Regulators and Governmental Authorities:
Where required by law, regulation, court order, or investigation.

6.4. Legal Advisors and Dispute Resolution Entities:
For enforcement of legal rights, litigation, or dispute resolution.

6.5. Potential or Actual Acquirers:
In the event of mergers, acquisitions, corporate restructuring, or the sale of assets, with confidentiality and limited use restrictions.

6.6. Fraud and Security Monitoring Entities:
Entities involved in fraud prevention, cybersecurity, and incident response.

In all such disclosures, Longshanks Capital will use reasonable efforts to ensure that recipients safeguard Personal Data and process it only as permitted.

VII. INTERNATIONAL TRANSFERS

Personal Data may be transferred to countries outside the UK and EEA (“Third Countries”). In such cases, Longshanks Capital shall implement adequate safeguards, including but not limited to:

• Utilizing countries recognized by the UK Information Commissioner’s Office as providing an adequate level of protection.
• Employing UK ICO-approved Standard Contractual Clauses.
• Binding Corporate Rules or equivalent mechanisms.
• Additional technical protections, such as encryption or pseudonymization.

VII. DATA RETENTION AND DESTRUCTION

Personal Data will be retained only as long as necessary to fulfill the purposes outlined herein or as otherwise required by law or contractual obligations. Retention periods vary by data category and regulatory context, including but not limited to:

• Client identification and verification data: minimum five years post-relationship termination.
• Financial transaction records: generally five to seven years or longer if legally mandated.
• Employee records: per statutory limits applicable in the UK.
• Marketing data: until withdrawal of consent or cessation of communication.

Once retention periods expire, data will be securely deleted, anonymized, or destroyed in a manner that ensures irretrievability.

IX. DATA SECURITY AND CONFIDENTIALITY

Longshanks Capital adopts reasonable and appropriate technical and organizational measures to protect Personal Data from unauthorized or unlawful processing, accidental loss, destruction, or damage, including but not limited to:

• Encryption of data in transit and at rest.
• Network and endpoint security measures.
• Physical access controls.
• Regular security audits and risk assessments.
• Staff training on data protection and confidentiality obligations.
• Incident detection and response protocols.

No method of transmission over the internet or electronic storage is completely secure; therefore, Longshanks Capital does not warrant absolute security but strives to implement best practices.

X. YOUR RIGHTS AS A DATA SUBJECT

Subject to Applicable Law and exceptions, you may have the following rights concerning your Personal Data:

• Right of Access: to request confirmation of Processing and obtain copies of Personal Data.
• Right to Rectification: to correct inaccurate or incomplete data.
• Right to Erasure: to request deletion where lawful and not outweighed by overriding interests.
• Right to Restrict Processing: to limit Processing under certain conditions.
• Right to Data Portability: to receive Personal Data in a structured, commonly used, and machine-readable format.
• Right to Object: to Processing based on legitimate interests or direct marketing.
• Right to Withdraw Consent: where consent is the legal basis for Processing.
• Right to Lodge a Complaint: with the UK Information Commissioner’s Office or relevant supervisory authority.

Requests must be submitted and will be processed per statutory timelines.

XI. COOKIES AND ONLINE TRACKING TECHNOLOGIES

Our websites may employ cookies, web beacons, and similar technologies to improve user experience, provide authentication, perform analytics, and display targeted advertisements.

XII. LIMITATION OF LIABILITY

To the fullest extent permitted by law, Longshanks Capital expressly disclaims all liability for damages, losses, costs, or claims arising directly or indirectly from the Processing of Personal Data, except for damages arising from Longshanks Capital’s gross negligence or willful misconduct.

Longshanks Capital’s total liability under this Policy shall be limited to the greater of (a) GBP 1,000 or (b) the aggregate fees paid by you in the twelve (12) months preceding the claim.

No liability is assumed for:

• Indirect, incidental, special, punitive, or consequential damages.
• Data breaches or losses caused by unauthorized third parties beyond our reasonable control.
• Loss of business opportunity or reputation.

XIII. POLICY AMENDMENTS

This Policy may be revised from time to time to reflect changes in legal requirements, business practices, or technological developments. All changes will be effective upon posting on Longshanks Capital’s website and/or notification to you by appropriate means.

Continued use of services following updates constitutes acceptance of the updated Policy.