The Data Protection (Bailiwick of Guernsey) Law, 2017 requires us to provide certain information to you. We provide this via our Privacy Notice below. This applies to all personal data collected by the Ravenscroft entities except for that relating to recruitment.

1 WHO ARE WE?

1.1 Ravenscroft Capital Limited (Guernsey registered company 66484) (RCL) wholly owns Ravenscroft Corporate Finance Limited (Guernsey registered company 67128) (RCFL) and Ravenscroft Project Management Limited (Guernsey registered company 66837) (RPML).

1.2 Together, these companies are the “Ravenscroft entities”, each with a registered office at PO Box 222, 20 New Street, St Peter Port, Guernsey GY1 4JG.

1.3 RCFL is licensed by the Guernsey Financial Services Commission to carry controlled investment business under the Protection of Investors (Bailiwick of Guernsey) Law, 2020. 1.4 Our contact details are:

Email: DP@ravenscroftcapital.com

Postal address: PO Box 222, 20 New Street, St Peter Port, Guernsey GY1 4JG

Telephone: +44 (0)1481 735340

2. TO WHOM DOES THIS PRIVACY NOTICE APPLY?

2.1 This Privacy Notice sets out how the Ravenscroft entities, as joint data controllers, collect, process and retain personal data. ‘Personal data’ means any information relating to an identified or identifiable (living) individual.

2.3 This Privacy Notice applies to you as a:

• related party of a client or prospective client of any of the Ravenscroft entities;
• related party of an investment or prospective investment of any of the Ravenscroft entities;
• related party of an investment or a prospective investment of any client of the Ravenscroft entities, or of a prospective client of the Ravenscroft entities; 
• counterparty of any of the Ravenscroft entities, or of any client of the Ravenscroft entities;
• corporate finance contact of RCFL;
• shareholder or beneficial owner of the Ravenscroft entities;
• browser of our website, ravenscroftcapital.com (the Website).

3. HOW DO WE COLLECT PERSONAL DATA

3.1 We collect personal data when you or someone acting on your behalf sends us documentation or corresponds with us by phone, email or otherwise. We may collect additional personal information during the course of service-related activities throughout the period of providing services to you or to a client of which you are a related party. The personal data that we collect, process and retain will vary depending on the nature of the relationship between the Ravenscroft entities and you, or the entity of which you are a related party.

4. WHAT PERSONAL DATA DO WE COLLECT? 

4.1 Clients and prospective clients

RCFL is required to collect, process and retain personal data relating to individuals associated with clients and prospective clients in order to satisfy its legal and regulatory obligations. Where appropriate, RCFL collects names, dates of birth, residential addresses, email addresses and any other relevant information.

It is the responsibility of the client or prospective client to ensure that the individuals to whom the personal data relates have been notified of its collection, processing and retention by RCFL.

4.2 Investments or prospective investments

On behalf of its clients that are funds or other investment vehicles, RCFL undertakes risk screening and countering financial crime due diligence in respect of investee companies and potential investee companies and their controllers. It also carries out the same in respect of buyers of assets from, or sellers of assets to, such funds or investment vehicles. Where appropriate, RCFL collects names, dates of birth, residential address, email address and any other relevant information.

4.3 Corporate finance contacts

Where you have entered into an agreement with RCFL to be treated as a corporate finance contact, we will collect, process and retain personal data (including where appropriate your name, email address, telephone number and any other relevant information that you provide to us or that we collect) for the purpose of communicating with you regarding prospective or actual investments and related events.

In addition, if you are invested in, or have agreed to invest in, a client of RCFL we may collect, process and retain your personal data (including proof of identity and proof of residential address documentation) to fulfil our legal and regulatory obligations (see 4.1 above).

Where we hold such personal data (which may also include information regarding the size of your investment) we may share this with service providers to the entity in which you are invested or have agreed to invest.

4.4 Counterparties

The Ravenscroft entities may utilise the services of consultants and outsource providers and may enter into business relationships with other parties. In this case, the Ravenscroft entities are required to collect, process and retain personal data relating to individuals associated with such parties in order to satisfy their legal and regulatory obligations or to manage their reputational and other risks.

4.5 Service providers

The Ravenscroft entities will collect personal data (including names and email addresses) in relation to third party service providers to its clients for the purposes of maintaining those relationships and fulfilling duties under contract to the relevant client.

The Ravenscroft entities may collect personal data (including names and email addresses) in relation to service providers engaged by the Ravenscroft entities or the landlord of any building occupied by any of the Ravenscroft entities for the purposes of maintaining communication regarding the provision of services.

4.6 Shareholders

In addition to the requirements under law for the Ravenscroft entities to maintain records of their shareholders, we may collect, retain and process personal data (including where appropriate your name, postal address, email address, nationality and national identification numbers, tax status and tax identification numbers, bank account details and any other relevant information that you or your representatives provide to us or that we collect) for:

• the processing and payment of dividends and associated reporting;
• the issuance of circulars to shareholders; and
• routine correspondence and administration purposes.

5. WHY WE COLLECT YOUR PERSONAL DATA 

5.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to comply with an agreement that we have entered into with you.
• Where we need to comply with a contractual, legal or regulatory obligation. 
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

5.2 We may also use your personal data in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else’s interests). 
• Where it is needed in the public interest, including to prevent fraud.
• Where we have obtained your consent.

5.3 The situations in which we will process your personal data are listed below:

• Carrying out any contract that we have entered into with you or with a party to which you are related.
• Complying with a valid order by a court or other governmental body or applicable law. Satisfying any legal or regulatory obligation. 
• Business management and planning, including accounting and auditing.
• Making arrangements for the termination of a commercial relationship or contract.
• Dealing with legal disputes involving you.
• To prevent fraud, criminal activity or market abuse. 
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• To undertake the staff recruitment and onboarding process.

Some of the grounds for processing described above will overlap and there may be several grounds which justify our use of your personal data.

5.4 The Ravenscroft entities may process your Personal Data for the following purposes:

• RCFL will itself (or through a third party) process certain information about you or your directors, officers and employees and your beneficial owners (if applicable) in order to carry out countering financial crime checks and related actions which RCFL considers appropriate to meet any legal obligations imposed on it or its clients relating to the prevention of financial crime and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with RCFL's countering financial crime procedures;
• to provide services to you or to a client to which you are related and/or for Ravenscroft's internal administration;
• to monitor and record calls and electronic communications, as well as the use of CCTV in limited areas of our office, for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution, and to enforce or defend the Ravenscroft entities’ and their affiliates' rights, itself or through third parties to whom it delegates such responsibilities or rights in order to comply with a legal obligation imposed on the Ravenscroft entities;
• and to monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of the Ravenscroft entities to improve their service delivery, and which are necessary to comply with a legal obligation and/or which are necessary for Ravenscroft's legitimate interests indicated above.

5.5 If you fail to provide certain personal data when requested, we may not be able to comply with the agreement we have entered into with you (if applicable) or we may be prevented from complying with our legal obligations.

5.6 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5.7 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. HOW WE USE SPECIAL CATEGORY DATA

6.1 Special category data is a sub-set of personal data which is considered more sensitive and therefore needs greater protection around its use. We need to have further justification for collecting, storing and using this type of personal data. We may process special category data in the following circumstances:

• In limited circumstances, with your explicit written consent.
• Where we need to comply with our legal or regulatory obligations and in line with our data protection policy.
• Where it is needed in the public interest, such as to prevent fraud, and in line with our data protection policy.

6.2 Less commonly, we may process this type of data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

6.3 Save where you have given explicit consent, we may only use data relating to the commission or alleged commission of a criminal offence by an individual where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and where we do so in line with our data protection policy. 

7. AUTOMATED DECISION MAKING

We do not envisage that any decisions will be taken about you using automated means to process your data, but we will notify you in writing if this position changes.

8. DATA SHARING

8.1 We may have to share your personal data with third parties, including third party service providers to the Ravenscroft entities and third party service providers to clients. We require third parties to respect the security of your data and to treat it in accordance with the law. 

8.2 We will share your personal data with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. 

8.3 “Third parties” includes third party service providers to the Ravenscroft entities (including contractors and designated agents). The following activities are carried out by third party service providers:

• IT system management
• banking
• sanctions, PEP and adverse media screening
• compliance 

8.4 We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business.

8.5 We may also need to share your personal data with a court, regulator, government body, applicable authority, enforcement agency or to otherwise comply with the law. 

8.6 For the purpose of the sharing of personal data, Guernsey’s Office of the Data Protection Authority has defined an Authorised Jurisdiction as:

• the Bailiwick of Guernsey
• a Member State of the European Union
• any country, any sector within a country, or any international organisation that the (European) Commission has determined ensures an adequate level of protection within the meaning of Article 45(2) of the GDPR and for which the determination is still in force a designation jurisdiction (by Ordinance)

8.7 We may transfer the personal data we collect about you to an Authorised Jurisdiction.

8.8 Save as permitted by law we will not transfer the personal data we collect about you to unauthorised jurisdictions. 

9. STORAGE AND SECURITY OF YOUR PERSONAL DATA

9.1 The Ravenscroft entities will collect and process personal data in accordance with this Privacy Notice, our data protection policy and the law.

9.2 The Ravenscroft entities have implemented proportionate organisational and technical measures to protect your personal data. These measures include policies and procedures, physical and software security and an employee training programme.

9.3 Whilst we have taken measures to protect your personal data, the transmission of data over the internet or other networks cannot be guaranteed as being secure. The Ravenscroft entities do not make any warranties, express or implied, about the security of your personal data in this regard.

9.4 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 

10. DATA RETENTION 

10.1 Your personal data will be retained for as long as required:

• for the purposes for which the personal data was collected;
• in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or
• as required by data protection laws and any other applicable laws or regulatory requirements. We will ensure that the personal data we hold is subject to appropriate security measures.

11. RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION

11.1 It is important to us that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

11.2 Under certain circumstances, by law you have the:

• Right of access to your personal data (commonly known as a "data subject access request"). This entitles you to ask what data we hold about you and why.
• Right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes or if data were being processed on grounds of public interest or for historical or scientific purposes.
• Right to rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Right to erasure of your personal data, enabling you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing. 
• Right to the restriction of processing of your personal data enabling you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Right to be notified of rectification, erasure and restrictions.
• Right not to be subject to decisions based on automated processing.
• Right to data portability: right to request the transfer of your personal data to another party.

11.3 If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data or request that we transfer a copy of your personal data to another party, please contact us in writing. 

11.4 You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if a repeated request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. 11.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access the data you have requested (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

11.6 In limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us in writing.

11.7 Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

12. LINKS TO OTHER WEBSITES

12.1 This Privacy Notice does not cover any third-party websites reached via links on our Website. You are advised to read the data collection statements on the other websites you visit.

13. ENQUIRIES AND COMPLAINTS

13.1 If you have any questions relating to this Privacy Notice or the personal data which we hold on you please contact us.

13.2 Should you wish to exercise any of your rights under the data protection law or wish to submit a complaint regarding our compliance with the exercise of such rights, please contact us in writing.

13.3 If you are dissatisfied with the way in which we have dealt with or handled your complaint, you have the right to refer your complaint to your local data protection authority, and to appeal the outcome of your complaint.

14. CHANGES TO OUR PRIVACY NOTICE

14.1 Please read this Privacy Notice carefully and revisit the relevant sections of it each time you visit our Website or provide us with any personal data. Changes may be made to this Privacy Notice at any time and without notice.

14.2 This Privacy Notice was last updated 1 May 2025.