Privacy Policy

Who we are

UKAP Holdings Limited (company number 07505002) and UKAP Investments Limited, each of First Floor, 85 Great Portland Street, London, W1W 7LT, act as data controllers for the personal data processed through this website and the Group's investor portals (the Shareholder Portal and the Loan Note Portal). Together they are referred to in this policy as "the Group", "we" or "us".

We are registered with the Information Commissioner's Office (ICO) as required under the Data Protection Act 2018. You can contact us about anything in this policy at admin@ukapgroup.co.uk or by writing to the address above.

The personal data we collect

We collect and process the following categories of personal data:

• Enquiry data — your name, email address, telephone number and the content of any enquiry or correspondence you send us through this website.
• Shareholder and noteholder data — your name, address and contact details, holdings, transactions, certificates and payment instructions, where you hold securities or loan notes in the Group.
• Portal account data — your sign-in credentials, account activity and communications made through the investor portals.
• Technical and usage data — your IP address, browser type and version, device information, pages visited and the date and time of visits, collected automatically when you use this website.
• Cookie data — information collected through cookies and similar technologies, as described in our Cookie Policy.

How we use your data and our lawful bases

We only process personal data where we have a lawful basis under the UK GDPR. The table below sets out what we use each category of data for and the basis we rely on.

Cookies

This website uses essential cookies and, with your consent, analytics and marketing cookies. Full details of the cookies we use, their retention periods and how to manage your preferences are set out in our Cookie Policy.

Who we share your data with

We do not sell personal data to anyone. We share personal data only with:

• Service providers who support the operation of the Group, this website and the investor portals, including hosting, email and IT providers acting as processors under written contracts.
• Professional advisers such as lawyers, accountants and auditors, where necessary for the services they provide to us.
• Registrars, brokers and payment providers involved in administering your holdings or distributions.
• Regulators, tax authorities, courts and law enforcement where we are required to do so by law.

International transfers

Some of our service providers process data outside the United Kingdom. Where personal data is transferred internationally we ensure it is protected by an adequacy regulation, the UK International Data Transfer Agreement or the UK addendum to EU standard contractual clauses, together with appropriate supplementary measures.

How long we keep your data

We retain personal data only for as long as necessary for the purposes for which it was collected, including to satisfy statutory record-keeping requirements. In outline:

• Statutory shareholder and noteholder registers: for as long as you remain a holder and thereafter as required by company and tax law (typically at least six years).
• Enquiry correspondence: up to three years from our last contact with you, unless a longer period is required in connection with a legal claim.
• Portal account records: for the life of your account and thereafter as required for audit and legal purposes.
• Technical and usage data: up to 24 months in aggregated or pseudonymised form.

How we protect your data

We apply appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, and restricting access to those who need it for their role. The investor portals require authenticated access and are hosted on infrastructure with industry-standard security controls.

If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the ICO and, where required, you, in accordance with the UK GDPR.

Your rights

Under UK data protection law you have the following rights in relation to your personal data:

• Access — to request a copy of the personal data we hold about you.
• Rectification — to have inaccurate or incomplete data corrected.
• Erasure — to ask us to delete your data where there is no good reason for us to keep it.
• Restriction — to ask us to suspend processing in certain circumstances.
• Objection — to object to processing based on legitimate interests.
• Portability — to receive certain data in a structured, commonly used format.
• Withdrawal of consent — where we rely on consent, to withdraw it at any time, for example through the cookie preferences control in the footer of every page.

Complaints

If you are unhappy with how we handle your personal data, please contact us first at admin@ukapgroup.co.uk so we can try to resolve the matter.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection, at ico.org.uk or by telephone on 0303 123 1113.

Changes to this policy

We may update this policy from time to time. The date at the top of this page shows when it was last revised. Significant changes will be highlighted on this page or, where appropriate, notified to shareholders and noteholders directly.

Contact us

To exercise any of your rights, or for any question about this policy, contact us at admin@ukapgroup.co.uk or write to us at First Floor, 85 Great Portland Street, London, W1W 7LT.