1. Introduction
Gore Street Capital Limited, together with its subsidiaries and affiliates (including Gore Street Investment Management Limited) (together, “Gore Street Capital”, “GSC”, “we”, “us” or “our”), is committed to protecting the privacy and security of the personal information we process, and to a consistent, compliant approach to data protection across the group.
This notice explains how we collect, use, share and protect personal information about our clients, investors, prospective investors, suppliers, business contacts and visitors to our websites and offices (together, “you”), and explains your rights in relation to that information. It applies wherever you interact with any Gore Street Capital group company.
We comply with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and the Data (Use and Access) Act 2025, and we abide by the data protection principles set out in that legislation and any other applicable regulation or legislation as amended from time to time.
2. The Personal Information We Collect
Information you give us. This is information about you that you provide by filling in forms, or by corresponding with us by phone, email or otherwise. It may include basic personal information such as your name, address, email address, phone number, title and company. We may request more sensitive information from you, such as financial information and other government identification numbers, where this is appropriate or necessary for conducting business with you.
Information we collect about you. We may supplement the personal information you provide with information we receive from third parties, including business partners, contractors, analytics providers and other service providers. To comply with statutory and regulatory requirements, we carry out Know Your Client (“KYC”) and anti-money laundering checks, often using third parties to perform these checks, and we keep records of them on file as evidence of our compliance. These records will be held in accordance with all appropriate legislative and regulatory rules, including those relating to retention.
We process this personal data for legitimate reasons including to help us improve the accuracy and completeness of our records, to better tailor our interactions with you, and to help us identify and prevent fraud.
3. How We Use Your Personal Information
We use, store and process the personal information we collect to:
- provide the information, products and services you request from us;
- tell you about similar products or services you have previously requested;
- prevent financial crime;
- monitor and improve our existing services; and
- keep a record of your communications with us to help resolve any issues you raise. Depending on where you live, this information may be retained for a reasonable period for future contact with you, or to improve our services, but always in accordance with our obligations in respect of retention.
We may also use or disclose your personal information where we believe in good faith that this is reasonably necessary to comply with the law, to enforce or apply the terms of any of our agreements, or to protect the rights, property or safety of Gore Street Capital, our clients or others. If Gore Street Capital becomes involved in a business divestiture, change of control, sale, merger or acquisition of all or part of its business, we may transfer and disclose your information (on an anonymised basis, where possible) as part of that transaction.
We only use your personal information where the law allows us to. This is usually where it is necessary to perform a contract with you, to comply with a legal obligation, or because it is necessary for our legitimate interests (or those of a third party) and your interests or fundamental rights and freedoms do not override those interests.
4. How We Share Your Personal Information
We may share personal information with:
- our affiliates, business partners, service providers, subsidiaries, vendors and consultants, to perform work on our behalf or to offer or provide related services under agreements signed with us;
- third parties, in response to a request for information, where we determine that disclosure is required or permitted by applicable law or regulation;
- third parties, where we determine that your actions are inconsistent with our agreements or policies, or where we must protect the rights, property or safety of Gore Street Capital or others; and
- another company, in connection with or during negotiation of any merger, sale of company assets, financing or acquisition of all or part of our business.
Whenever we share your data, we first satisfy ourselves that there is a legitimate reason for doing so and that the recipient has appropriate safeguards in respect of your data.
5. International Data Transfers
Where we store or transfer personal information outside the UK, we have procedures and safeguards in place to secure, encrypt and maintain the integrity of that data. These include reliance on UK adequacy regulations, binding corporate rules, the International Data Transfer Agreement/Addendum (or equivalent standard data protection clauses), or approved codes of conduct, together with due diligence on recipients to verify that they have appropriate safeguards, enforceable data subject rights, and effective legal remedies.
Where a transfer does not benefit from a UK adequacy regulation and instead relies on an alternative transfer mechanism such as the above, we carry out a “data protection test” before making the transfer — a risk assessment comparing the data protection standards of the destination country and recipient against the protection provided by the safeguards used — in accordance with the Data (Use and Access) Act 2025.
6. How We Protect Your Personal Information
The security of your personal information is important to us. We use reasonable physical, electronic and procedural safeguards to protect it from loss, theft, misuse, alteration and unauthorised access or destruction, including:
- restricting access to personal data to employees or service providers on a “need to know” basis;
- enforcing policies and procedures for our employees’ handling of personal data; and
- using technologies designed to safeguard data in transit and at rest, such as encryption.
We also employ industry-standard measures and processes for detecting and responding to attempts to breach our systems. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee the absolute security of your information. We encourage you to use caution when disclosing information online and to take care to protect your own login credentials.
7. How Long We Keep Your Personal Information
We retain personal information only for as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, tax, accounting or reporting requirements (for example, applicable FCA and anti-money laundering rules typically require records to be kept for five years after the end of a business relationship, and in some cases longer). Where personal information is no longer required, it is securely deleted or anonymised.
8. Your Rights
As a data subject, you have a number of statutory rights, subject to certain conditions and exceptions.
8.1 Right to be Informed
You have the right to be informed about the collection and use of your personal data. This is achieved by means of this notice.
8.2 Right of Access
You have the right to access and review the personal data we hold about you, to confirm its accuracy. We will make reasonable efforts to comply with such requests within legal frameworks, unless the request is prohibited by law or there is a legitimate business reason to retain the data. We reserve the right to verify your identity before processing any request. Please direct any requests using the contact details set out in this notice by sending the Subject Access Request form.
8.3 Right of Rectification
You have the right to require us to rectify any errors in the data we hold about you.
8.4 Right to Erasure (right to be forgotten)
This is not an absolute right. If we are unable to fully comply with a request for erasure, we will tell you why.
8.5 Right to Data Portability
You have the right to ask us to transfer the data we hold about you to another controller in a machine-readable format. We do not consider this will generally be applicable to the types of data we hold, given the nature of our business.
8.6 Right to Restrict Processing / Right to Object
You have the right to ask us not to process, or to object to, our processing of your data where it is based on: our legitimate interests or the performance of a task in the public interest (including profiling); direct marketing (including profiling); or processing for scientific/historical research and statistics purposes. If you exercise this right, we will stop processing the data unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims. You have an absolute right to stop your data being used for direct marketing.
8.7 Rights Related to Automated Decision-Making Including Profiling
This is not currently applicable, as we do not engage in solely automated decision-making that produces legal or similarly significant effects concerning you. The Data (Use and Access) Act 2025 has relaxed the rules on automated decision-making, subject to enhanced transparency requirements. If this position changes, we will update this notice and provide you with the additional information the law requires before doing so.
9. Complaints
In addition to your other rights set out in this notice, you have the right to make a complaint directly to us if you consider that our processing of your personal data infringes your rights under data protection law. To do so, please email us at dataprotection@gorestreetcap.com. We will acknowledge your complaint within 30 days of receipt and will deal with it without undue delay.
If, having raised a complaint with us, you remain dissatisfied, or if you believe we are otherwise processing your personal data other than in accordance with the law, you also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s independent supervisory authority for data protection, at ico.org.uk.
10. Changes to This Notice
We reserve the right to update or amend this notice at any time, acting at our sole discretion, including where we intend to further process your personal information for a purpose other than that for which it was collected, or where we intend to process new types of personal information. We will issue a new notice when we make significant updates, and may also notify you about the processing of your personal information in other ways.
Contacts
Data Protection
dataprotection@gorestreetcap.com
Telephone +44 (0)20 4551 1382
Gore Street Capital Limited, First Floor, 16-17 Little Portland Street, London, W1W 8BP