This Privacy Notice for Mount Capital Limited (“we”, “us”, or “our”) applies to visitors to this website (the “Site”), and clients, investors or other contacts who interact with us, or, where such client, investor or other contact is not an individual, their individual directors, officers, employees and/or owners (“you”, or “your”). This Privacy Notice is intended to provide you with information about how we process your personal data. By “personal data” we mean information about you which could identify you such as your name and contact details, but this does not include data where you can no longer be identified from it such as anonymised aggregated data.

We will be the “data controller” of personal data processed in connection with this Privacy Notice. This means that we are responsible for deciding how we hold and use personal data about you. We may process your personal data ourselves or through others acting as data processors on our behalf.

We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why your personal data is being used. These supplemental notices should be read together with this Privacy Notice.

If you provide us with personal data of others, for instance, other representatives of an investor, please provide those persons with a copy of this Privacy Notice.

Should you have any questions about this Privacy Notice you can contact us on the details set forth at the end of this Privacy Notice.

What information do we collect about you and what do we use it for?

We typically collect information about you when you provide information to us or others acting on our behalf when communicating or transacting with us in writing, electronically, or by phone. For instance, applications, requests for product documentation or other forms of literature, or forms on our Site. In addition, we may receive information about you from third parties and public sources, such as:

• public sources or information vendors;
• your bank;
• your legal, financial, tax or other professional advisers;
• introducers or other intermediaries who market or provide services to you.

Personal data held by us or on our behalf depends on the context of your relationship or interaction with us but may include, but is not necessarily limited to, your name, residential address, place of business, email address, other contact details, corporate contact information, signature, nationality, country of residence, place of birth, date of birth, tax identification, tax jurisdiction, employment and job history, education details, regulatory status, credit history, correspondence records, call recordings, passport number, bank account details, certain financial information contained within KYC documents, and source of funds and details relating to your investment activity or preferences.

We may also automatically collect certain information when you interact with our Site such as information about how you use our Site (including the content you view and features you access, when you access it and the duration of your engagement) and other technical data (such as your IP address, login data for our web portal, browser type and version, internal service provider domain name, time zone setting and location). We collect this information by using cookies and similar technologies. For more information see the “Cookies and Similar Technologies” section below.

The purposes for which we may collect, store and use personal data about you and the ‘lawful basis’ for processing such data are set out in the table below. The law specifies certain ‘lawful bases’ for which we are allowed to use your personal data.

Purpose	Lawful basis for processing
To correspond with you.	Our legitimate interests in responding to your enquiry or otherwise communicating with you in the course of our business.
Where you are a client or investor in an investment product associated with us, to undertake pre-investment steps, including, but not limited to: – determining your eligibility to invest or hold a managed account as applicable; – required due diligence; – ascertaining your investment preferences.	In order to take steps prior to your client or investor contract being entered into, compliance with applicable legal obligations and our legitimate interests in establishing your preferred investment strategies and complying with our legal and regulatory obligations.
To undertake business development and marketing activities in relation to making suggestions and recommendations to you about products or services that may be of interest to you. This may include direct electronic marketing.	Our legitimate interests in promoting our products and services and growing our business. We only send direct electronic marketing where individuals have consented to this or as otherwise permitted by the law. Individuals can opt-out of receiving such messages at any time by using the opt-out mechanisms that may be available in those messages or by contacting us.
Where you are a client or investor in an investment product associated with us, to facilitate the opening of your account, the management and administration of your account on an on-going basis as considered necessary or appropriate for the performance of your client or investment contract, including without limitation the processing of subscription, redemption, conversion and transfer requests and the payment of distributions.	The performance of your client or investment contract.
To carry out anti-money laundering checks and related actions considered appropriate to meet any legal obligations relating to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and 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 our anti-money laundering procedures.	Compliance with applicable legal obligations and our legitimate interests in complying with law and regulation applicable to us and our processors.
To report tax related information to tax authorities.	Compliance with applicable legal obligations and our legitimate interests in complying with our legal and regulatory obligations.
To process and verify instructions, undertake quality and business analysis, comply with applicable laws and regulations, and maintain our rights and responsibilities directly or through third party delegates. In doing so, we record and monitor calls and other communications.	Our legitimate interests in maintaining relations with our clients and in conducting our business in a proper manner. Compliance with applicable legal obligations and our legitimate interests in complying with our legal and regulatory obligations.
To maintain our records and carry out fee calculations.	The performance of your client or investment contract. Our legitimate interests in maintaining relations with our contacts and in conducting our business in a proper manner.
To provide client relations in respect of your account including provision of periodic reporting, seeking consents for changes to terms and for other corporate governance purposes.	The performance of your client or investment contract. Compliance with applicable legal obligations and our legitimate interests in complying with our legal and regulatory obligations.
To administer and maintain our Site and record, monitor and analyse your use of our Site and whether you open emails we have sent to you.	Either your consent (for example, when we require your consent for the optional cookies that we use) or our legitimate interests in studying how our Site is used, keeping our Site updated and relevant, and to develop our business and inform our marketing strategy.

In addition to the uses above, please note that we may also process your information where required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

We also collect, use and share aggregated data such as statistical data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data itself as it can no longer identify you. For example, we may aggregate your investment data to calculate the percentage of our investors investing in a specific sector.

Special categories of personal data

There are more limited bases for processing special category personal data. This is personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation. Similarly, there are fewer bases for processing criminal convictions and offences data

We do not intend to actively collect any such data about you. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally. For example, where:

• you volunteer such data to us or one of our processors, such as if you send us an email containing such data;
• documents gathered for legal / regulatory purposes containing such data, such as a passport copy which references ethnic origin or a due diligence search from public sources which includes such data.

What if you do not provide the personal data requested?
Unless and until you decide to engage in a transaction with or invest in an investment product associated with us, you are not required to provide us with any information. If you do wish to engage in a transaction with or invest in an investment product associated with us, in some circumstances, if you do not provide us with certain information when requested, we may be limited or restricted in our ability to deal with you and may in some cases be prevented from complying with our legal obligations. Where we require your personal information to comply with anti-money laundering or other legal requirements, failure to provide this information means you may not be accepted or retained as a client or investor. We will let you know if any particular data is required when we request it. Please also note that our Site may automatically collect certain technical data as explained above.

Change of purpose
We will only use your personal data for the purposes for which we collected it (as identified above in the ‘Purpose’ column above), unless we reasonably consider that we need to use it for another reason which 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.

Who will we share your information with?

We may share your information with a third party for the purposes described above where this is required by law, where it is necessary to perform our contract with you, where we have another legitimate interest in doing so, or otherwise with your consent.

We may need to share your personal data with:

• other entities within our group as part of our regular reporting activities in company performance, in the context of a business reorganisation or group restructuring exercise or for assistance in relation to marketing and business development;
• introducers, distributors or other intermediaries who market or provide services to you;
• professional advisers including lawyers, bankers, auditors and insurers to the extent such information is relevant to their performance of their services;
• regulators;
• tax authorities;
• fund service providers including administrators and custodians/depositaries;
• trading counterparties;
• providers of cloud storage, web analytics, advertising, email distribution and other services;
• parties undertaking anti-money laundering checks; and
• any of our service providers where such information is relevant to their performance of such services.

We may share your personal data with third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

We may transfer the personal data we collect about you to countries outside of the UK where the parties listed above are based for the purposes outlined in the table above. Those countries may not have the same standard of data protection laws as the UK.

Where this is the case and where required, we will (or we will require a processor to) put in place appropriate safeguards such as approved standard contractual clauses. If you require further information about this you can contact us.

Cookies and similar technologies

We and service providers or partners we engage may use cookies, web beacons, tracking pixels and other similar technologies to understand usage of and improve our Site. Cookies are bits of text that are placed on your computer’s hard drive. Some of these technologies that we use are “strictly necessary” or “required” for the Site to function. We also use analytics tools, such as to help us measure traffic and usage trends for our Site. Such analytics tools may provide data, such as information about your engagement with our Site which may be used to provide content, analysis or functionality or to measure and analyse engagement.

Our Site may use Google Analytics, a web analytics service offered by Google. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at http://www.google.com/policies/privacy/partners.

Your Choices.
For more information about the cookies we use and for instructions on how to manage your cookie preferences and choices you may have, please see our Cookie Policy.

You can also generally manage your cookie preferences through your web browser. Most web browsers will tell you how to stop accepting new cookies and how to disable existing cookies. For more information regarding how to manage your preferences, please consult the information made available by your particular browser or visit www.allaboutcookies.org.

With respect to Google Analytics, you can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout. Please note that if you choose not to accept cookies, you may miss out on certain features of our Site.

How long will your information be retained?

We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. This will normally include any period during which we are dealing or expect to deal with you and what we consider to be a suitable period thereafter for our internal record-keeping purposes. In doing this we will have regard to the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we will keep information relevant to our dealings with you for 7 years following full redemption or the last date of activity or longer as required by applicable law or regulation.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data and we will use such information for any purpose without further notice to you. Otherwise, once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data in accordance with applicable laws and regulations.

Accuracy of information

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data which we hold changes during your relationship with us.

Your rights in relation to your personal data

You have rights as an individual which you may be entitled to exercise in relation to the personal data we hold about you under certain circumstances and subject to certain exemptions and conditions under applicable law. These rights are to:

• request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
• request rectification of your personal data;
• request the erasure of your personal data;
• request the restriction of processing of your personal data;
• object to the processing of your personal data; and
• request the transfer of your personal data to another party.

In exercising your rights above, you may be required to redeem or withdraw from your investment product where applicable.

If you want to exercise one of these rights please contact us. We will do our best to accommodate your request or objection but please note that not all rights are absolute.

You also have the right to make a complaint at any time to a supervisory authority for data protection issues.

Fees

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (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.

Right to withdraw consent

In the 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. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.

Changes to this privacy notice

We reserve the right to update this Privacy Notice at any time, and will make an updated copy of such Privacy Notice available to you and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

Further information and contacting us

This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please do not hesitate to contact us on [email protected].

This Privacy Notice was last updated on 26 May 2026.