Privacy Policy

Version last revised: September 2026

1. Privacy Notice

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We, Paloma Capital, LLP, (“Paloma Capital”, "we", “us”) are committed to protecting the privacy and security of personal data concerning you and protecting and upholding your data privacy rights.

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This privacy notice describes how we use personal data concerning you in the course of your interaction with the website at www.palomacapital.com(the “Website”) in accordance with the applicable data privacy laws including the Data Protection Act 2018 and the UK GDPR.

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It applies to all visitors to the Website, and allkinds of interaction, including viewing, browsing and registering with the Website.  It also covers certain processing for the purposes of communicating with you where that applies.  What processing of your personal data we carry out depends on the nature of your interaction, as set out below.

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2. Important Contact Information

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Controller Name: Paloma Capital LLP

Controller Address: Henry Wood House, 4-5 Langham Place, London W1B 3DG

GDPR Contact: info@palomacapital.com

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3. Terms used in this Privacy Notice

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• Controller – means the person or entity that determines how your personal data is processed and for what purposes.  As the Controller we have primary responsibility for ensuring that nothing is done with your personal data that breaches the data privacy laws and/or your rights.
• Personal Data – means any information relating to you where you can be identified.  This includes information where you are not identified from the information, but where you can be identified by referring to other information.
• Processing – means any operation performed on personal data or on sets of personal data, including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, transmission, making available, erasure or destruction.
• Processor – means another person or entity who processes personal data on our behalf.

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4. How we obtain your personal data

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We collect personal data concerning you in a variety of ways depending on how you interact with us and the Website and associated services, this includes personal data collected:

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• Directly from you when you provide it to us, such as when you register for an account, sign up to receive communications from us, or contact us by phone, email, or otherwise.
• Automatically through the use of cookies, server logs, and other similar technologies when you interact with the Website.
• From other sources, including, for example, other websites you visit, our affiliates, business partners, service providers, and other third parties, or from publicly available sources.

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5. Types of personal data we process, purpose of processing and lawful basis

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The following sets out the type of personal data we collect in a variety of contexts, the purpose for which we process that personal data, and the lawful basis for that processing under the UK GDPR.  In most cases the primary lawful basis of processing personal data in connection with the Website is our legitimate business interests and the interests of our personnel and affiliates pursuant to Art. 6 (1) (f) UK GDPR.

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Context, Types of data and purpose of processing and Lawful basis of processing

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Website  interactions

We use  technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our search function. This may also include information about your device or browser.

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We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to provide a tailored experience. We also have a legitimate interest in detecting and preventing fraud.

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Web logs

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the  internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

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We have a legitimate interest in monitoring our networks and the visitors to the Website. Among other things, it helps us understand which parts of the Website or our services is the most popular.

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Mailing List

When you sign up for one of our mailing lists we will collect your email address or postal address.  

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We share information about our products and services with individuals that consent to  receive such information. We also have a legitimate interest in sharing information about our products or services.

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Mobile Devices

We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or mobile application.

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We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.

6. Other purposes of processing

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In addition to the purposes and uses described above, we use information in the following ways:

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• To identify you when you visit our website or mobile application.
• To provide personalized content suggestions.
• To improve our services and product offerings.
• To conduct analytics.
• To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback.
• To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
• To debug, identify and repair errors that impair existing intended functionality of our website and services.
• To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
• For internal administrative purposes, as well as to manage our relationships.
• For such other purposes as you may consent (from time to time).

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Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.

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7. Cookies

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The website uses cookies to distinguish you from other users. A cookie is a small file that is stored by your browser. Cookies help us to provide you with a good experience when you browse the website and also allows us to tailor your experience and make improvements.

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We use thefollowing types of cookies:

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• Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

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Other than Strictly Necessary Cookies, you can choose which cookies we can set by clicking on the relevant buttons in the cookie banner that appears when you first access the Website.

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However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website.

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To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

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8. Protection and security of your Personal Data

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We have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk presented by the processing we carry out to protect the confidentiality, integrity and availability of your personal data and to protect against unauthorised or unlawful processing and accidental loss, destruction or damage.

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No method of transmission over the internet, or method of electronic storage, can be 100% secure. While we use appropriate efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal data and you should always apply reasonable precautions when sharing your personal data online.

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9. Duration of Processing

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We will only process your personal data for as long as the purpose for which it was collected remains applicable. In general we will retain your personal data for only as long as necessary to fulfil the purposes outlined in this Privacy Notice, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

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If you have concerns about how long we are storing your personal data,you may contact us to exercise one of your rights set out below.

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10. International Data Transfers

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We do not generally need to transfer any personal data we process in connection with the Website outside the UK or EEA.  

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Where it is or becomes necessary to transfer any personal data to a country outside UK or EEA and that country is not the subject of an adequacy decision of the UK Government (or EU Commission as applicable), we ensure that adequate safeguards are in place.

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That includes, where necessary, taking steps to evaluate the risks raised by the transfers in countries that do not offer an adequate level of protection. We rely primarily on the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum to facilitate the international and onward transfer of your personal data.

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11. Disclosure of Your Information

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In addition to the specific situations discussed elsewhere in this Privacy Notice, we may disclose personal data in the following situations:

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• Acquisitions. If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
• Public. If the Websites provides the opportunity to post comments in a public forum. Any personal data you submit on these pages may become publicly available.
• Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, provide technical support, process payments, and assist in the fulfillment of orders.
• Other Disclosures. We may disclose information in response to court orders, or in connection with any legal proceedings, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.

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We do not “sell” your personal data or “share” your personal data for the purposes of cross-context behavioural advertising or targeted advertising.

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12. Changes to this Privacy Notice

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We may need to update this Privacy Notice to reflect changes to our data processing practices. If we do this and the changes are material and affect you, we will endeavour to notify you in advance. You can see the date this Privacy Notice was last revised at the top of the page.

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13. Your Rights

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The applicable data protection law in the UK gives you certain specific rights in relation to your personal data which are set out below.  

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1. Access – In all circumstances you have the right to access your personal data and certain information about how and why we are processing it, including, in most cases copies of personal data that we process
2. Rectification – In all circumstances you have the right to have any inaccurate or incomplete personal data rectified without undue delay
   
   The following rights do not apply in all circumstances.  However, you are always welcome to contact us with any request relating to processing of your personal data and, even if we are not obliged by law to comply with your request, we will try to accommodate your wishes.
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3. Erasure – sometimes called the ‘right to be forgotten’, in certain circumstances, you have the right to have your personal data erased without undue delay;
4. Restriction - in certain circumstances, you have the right to have our processing of your personal data restricted;
5. Data portability - in certain limited circumstances, you have the right to receive the personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance; and
6. Objection - in circumstances where we are processing personal data that concerns you on the lawful basis of legitimate interest only, you have the right to object to the processing.

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14. Contact Us

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If you would like further information on anything in this Privacy Notice, for all questions or concerns you have about your personal data, or if you think you would like to exercise any of your rights as a data subject, please contact us using the contact details at the top of this Privacy Notice.

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15. Making A Complaint

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If you think we have not complied with the requirements of the Data Protection Laws as they apply to your personal data, you have a right to lodge a complaint through Paloma Capital’s internal complaints procedure and we will take appropriate steps and inform you of the outcome without undue delay.  

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If you are not satisfied that we have adequately addressed your complaint, once our complaints procedure is complete, you have the right to complain to the Information Commissioner’s Office (ICO) in the UK: casework@ico.org.uk or 0303 123 1113 / +44 1625 545 700; www.ico.org.uk.

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