1. Introduction and who we are
Preservation Capital Partners Limited (“PCP”, “we”, “us”) is committed to handling personal data lawfully, fairly and securely.
This privacy notice is provided under applicable data protection laws, including the UK GDPR and Data Protection Act 2018 and, where relevant, the EU GDPR (together, “Data Protection Laws”). It explains how we collect, use and share personal data, organised by category of individual.
Preservation Capital Partners Limited is the controller of personal data processed for its own business purposes and is legally responsible for deciding how and why that data is used. Preservation Capital Partners Limited is a UK company authorised and regulated by the Financial Conduct Authority (FRN 846103) and registered with the Information Commissioner’s Office under registration number ZC204728. Other entities within the PCP group may have access to personal data where necessary for the purposes described in this notice. Depending on the relevant activity, they may act on our instructions or as separate controllers.
Communications using PCP systems, including email and approved messaging platforms, may be subject to automated security scanning, retention and proportionate review where necessary for security, record-keeping, legal or regulatory compliance, or the investigation of suspected misconduct.
2. Changes to this document
We may update this document from time to time; when we do, we will revise the “last updated” date above.
3. Sources of personal data
- Directly from you: for example when you correspond with us, complete subscription or contractual documents, apply to work with us, attend our events or offices, or use our website.
- Automatically generated: through your use of our website or investor data rooms, including via cookies (see section 14).
- From third parties and public sources: including screening and identity verification providers, recruitment agencies, referees, your representatives or advisers, placement agents, fund administrators, and public registers and media.
4. Job applicants
This section applies when you apply to work at PCP. If you become an employee, you will be provided with a separate employee privacy notice.
What we collect
- Personal details such as your name, address, date of birth, country of residence and contact details.
- Identity and right-to-work documents, such as a copy of your passport (collected only if we offer you a role).
- Information relevant to the recruitment process: your CV or cover letter, current role, references, interview notes and anything else you or our search agents share with us.
Purposes and lawful bases
| Purpose | Lawful basis |
| Assessing suitability, conducting interviews and determining terms of any offer | Taking steps to enter into a contract with you |
| Checking entitlement to work and carrying out proportionate pre-employment checks | Compliance with a legal obligation for right-to-work checks; legitimate interests for proportionate references and other pre-employment checks; an additional statutory condition where criminal-offence data is processed |
| Record-keeping and general correspondence | Legitimate interests (recruitment administration) |
5. Business contacts, event attendees and office visitors
If you have interacted with PCP (by email, in a meeting, at an event we host, by visiting our offices, or otherwise) we may keep limited personal data: your name and contact details; professional details such as job title, employer and role; dietary or access requirements where you attend an event we host; visitor records where you attend our offices; and information captured in correspondence.
Purposes and lawful bases
| Purpose | Lawful basis |
| Maintaining a list of contacts and corresponding with you | Legitimate interests (running and promoting our business) |
| Providing business updates and invitations to events | Legitimate interests (maintaining professional relationships), or consent where applicable electronic-marketing law requires it |
| Organising events, including catering for dietary requirements | Legitimate interests (running our events); explicit consent where a requirement reveals health or belief information |
| Maintaining safety and security at our offices, including visitor records | Legitimate interests (the security of our premises, staff and visitors) |
6. Management teams of portfolio and target companies
If you are involved in a transaction that PCP or the funds it advises enters into or is contemplating, we may keep limited personal data: information relating to your financial status and dealings, your CV and employment history, your nationality (including copies of identity documents such as a passport), references from third parties, and the results of due diligence we conduct. We obtain this directly from you, from your representatives, staff or advisers, and in limited circumstances from other third parties such as diligence providers or referees.
Purposes and lawful bases
| Purpose | Lawful basis |
| Evaluating actual or potential transactions and keeping records of investments | Legitimate interests (reviewing potential transactions and managing investments made by the funds we advise) |
| Verifying identity and conducting KYC / AML checks | Compliance with a legal obligation; legitimate interests (protecting PCP, the funds and third parties against financial crime) |
| Administering transactions we are involved in | Legitimate interests (administering transactions and providing advisory services); performance of a contract where the individual is personally party to the relevant contract |
| Safeguarding our legal rights | Legitimate interests (establishing, exercising or defending legal claims) |
7. Suppliers and professional advisers
We hold limited personal data about individuals at our suppliers and professional advisers: name, business contact details, job title, employer and qualifications; bank and billing details; information obtained in onboarding checks; and information captured in correspondence.
Purposes and lawful bases
| Purpose | Lawful basis |
| Onboarding, administering and paying suppliers, and managing advice received | Legitimate interests (administering and procuring services); performance of a contract where the supplier is an individual personally party to the contract |
| Meeting legal, tax, accounting and regulatory obligations | Compliance with a legal obligation |
| General business management, planning and audit | Legitimate interests (running our business effectively) |
8. Investors
This section applies to individual investors in the funds we advise and to individuals connected with institutional investors (directors, officers, trustees, beneficial owners, employees and authorised representatives) whose data we receive during onboarding and the life of the fund, including through subscription documents and correspondence (which may be recorded).
What we collect
- Name, date of birth, nationality and contact details.
- Financial information, including commitment amounts, source of funds and wealth, bank account details for distributions, and transaction history with the funds we advise.
- Proof of identification and address, tax residency information and identifiers (including for FATCA/CRS reporting), and beneficial ownership information.
- Information contained in subscription documents, side letters, limited partnership agreements and investor questionnaires.
- Login and usage data for any investor portal or data room we provide.
Purposes and lawful bases
| Purpose | Lawful basis |
| Processing applications and subscriptions, and evaluating whether to accept investments | Taking steps to enter into, or performance of, a contract where the investor is an individual; legitimate interests for individuals connected with institutional investors and for operating the funds we advise |
| Verifying identity and undertaking KYC / AML / sanctions checks | Compliance with a legal obligation; legitimate interests (preventing financial crime) |
| Administering investments, capital calls, distributions and reporting under fund documents | Performance of a contract where the investor is an individual; legitimate interests for individuals connected with institutional investors and for administering investments and providing services |
| Complying with legal, tax (including FATCA/CRS), accounting, regulatory and reporting obligations, and responding to lawful requests from authorities | Compliance with a legal obligation |
| Corresponding with you, providing access to data rooms, and sending updates | Legitimate interests (managing investor relationships), or consent where applicable electronic-marketing law requires it |
| Protecting our legal rights or defending claims | Legitimate interests (defending legal claims) |
9. Website users
We collect information you choose to provide through the site (such as your name, contact details and the nature of your enquiry), and technical information such as IP address and device data collected through cookies (see section 14).
| Purpose | Lawful basis |
| Responding to enquiries raised via the website | Legitimate interests (responding to you) |
| Improving the content and functioning of the website | Legitimate interests (providing a functioning site); consent for non-essential analytics |
10. Special category and criminal conviction data
We do not ordinarily request special category data (information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, or data concerning health, sex life or sexual orientation) and ask that you do not provide it unless requested. Such information may nevertheless be revealed through screening, due diligence or information you provide to us. We process special category data only where we have an applicable lawful basis under Article 6 of the UK GDPR and an additional condition under Article 9. This may include explicit consent, where you provide health or belief information relating to dietary or access requirements, or processing necessary for substantial public interest reasons or to establish, exercise or defend legal claims, as applicable.
We may also process information relating to alleged or proven criminal offences where it is identified through proportionate recruitment, compliance, screening or transaction due diligence. We do so only where we have an applicable lawful basis and official authority or an appropriate condition under the Data Protection Act 2018. We limit access to this information and retain it only for as long as necessary.
You are not required to provide personal information when requested; however, if you do not, we may not be able to enter into or continue a business relationship with you, and we will inform you where this is the case.
11. Who we share your personal data with
We share personal data in accordance with Data Protection Laws and our internal security standards. We may disclose it to:
- our legal and other professional advisers, auditors and consultants;
- fund administrators, depositaries, custodians and banks;
- identity verification agencies and anti-money laundering screening providers;
- governmental, regulatory and tax authorities in the UK and overseas (including the FCA, HMRC, the Guernsey Financial Services Commission and overseas tax authorities), where required or permitted by law or to respond to a lawful request;
- service providers under contract, such as IT, hosting, document storage and other back-office providers, and placement agents;
- companies within the PCP group, for administration of our services and compliance; and
- buyers or successor managers of a fund and their professional representatives, and prospective parties and their advisers, in connection with any actual or potential restructuring, sale or similar transaction.
Our processors may use personal data only for the purposes covered by their contracts with us. Other recipients, including fund entities, administrators, professional advisers and public authorities, may act as separate controllers where they determine their own purposes and means of processing. We do not share personal data with other organisations for their own marketing purposes.
12. International transfers
Some third parties with whom we share personal data may be located, or have servers, outside the UK or EEA, in countries with different data protection laws. We make such transfers in compliance with applicable Data Protection Laws, including by relying on adequacy regulations or decisions, approved contractual safeguards or another lawful transfer mechanism. You may contact us for details of the transfer mechanism used in a particular case and, where applicable, a copy of the relevant safeguards (subject to redactions).
13. How long we keep your personal data
We keep personal data for no longer than reasonably necessary to fulfil the purposes set out in this notice, unless a longer period is required or permitted by law, regulation, applicable fund or contractual documentation, or relevant limitation periods. Retention periods vary by category. In determining the appropriate period, we consider the amount, nature and sensitivity of the data, the risks associated with unauthorised use or disclosure, the relevant purposes and applicable legal and regulatory requirements. When the applicable period expires, personal data is securely deleted or anonymised.
14. Cookies, links and social media
Our website may use cookies and similar technologies. Strictly necessary cookies are used where required to operate the website. We use non-essential cookies only with your consent, obtained through our cookie-management tool, where you can change or withdraw it at any time. You can also block or delete cookies in your browser settings, although this may affect website functionality.
Our website may include links to third party websites, plug-ins and applications, and we maintain a presence on platforms such as LinkedIn. We do not control these and are not responsible for their content or privacy practices; we encourage you to read their privacy notices.
15. Data security
We maintain appropriate administrative, technical and physical safeguards designed to protect personal data against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. We limit access to personal data to personnel and service providers who need it for an authorised purpose and who are subject to appropriate confidentiality obligations.
16. Automated decision-making
We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. Automated tools may assist our personnel with identity verification and screening, but any potentially adverse outcome is reviewed by a member of staff before a decision is taken. If this changes, we will update this notice and inform you of your rights, including the right to human intervention. Meetings and calls may be recorded, transcribed or summarised, including using AI-assisted notetaking tools, based on our legitimate interests in maintaining accurate business records.
17. Your rights
Not all rights are absolute: where we cannot comply with a request (for example, because it would conflict with a legal obligation), we will tell you why. Exercising some rights (such as erasure, restriction or withdrawal of consent) may mean we can no longer provide services to you; we will inform you of the consequences at the time. Your rights under applicable Data Protection Laws are:
- Access: to a copy of the personal data we hold about you and details of how we use it.
- Rectification: to have inaccurate or incomplete data corrected. Please notify us if your details change.
- Erasure: to ask us to erase personal data in certain circumstances. We may be required or permitted to retain certain data despite an erasure request, including to comply with a legal obligation or for legal claims.
- Restriction: to ask us to stop using your data in certain circumstances.
- Portability: where applicable, to receive certain personal data you provided to us in a machine-readable format, or have it transferred to a third party.
- Objection: to processing based on legitimate interests. Where you object, we will stop the relevant processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is required for legal claims. You have an absolute right to object to direct marketing, exercisable through any unsubscribe link or by contacting us.
- Withdrawal of consent: at any time, where processing is based on consent, without affecting prior processing.
- Automated decisions: not to be subject to a solely automated decision producing legal or similarly significant effects.
To exercise any of these rights, contact us at info@preservationcp.com. We will respond within one month of receiving your request, extendable by up to two further months for complex or numerous requests, in which case we will tell you within the first month. We may need to verify your identity before acting on a request.
You have the right to make a complaint to us if you consider that our processing of your personal data infringes applicable Data Protection Laws. Complaints may be submitted to info@preservationcp.com. We will acknowledge receipt within 30 days, investigate, and inform you of the outcome without undue delay. You may also make a complaint to the Information Commissioner’s Office (ico.org.uk; helpline +44 303 123 1113).
18. Contact us
For any question, concern or complaint in relation to this document, or to exercise your rights, contact: Preservation Capital Partners Limited, 25 Golden Square, London, W1F 9LU, or by email at info@preservationcp.com.