PRIVACY POLICY

Cotswolds Capital takes the privacy of all individuals who interact with the firm seriously. This Privacy Policy explains what personal data the firm collects, how it is used, on what legal basis, and the rights available to individuals in respect of their personal data.

This policy applies to personal data collected through this Site, through direct correspondence with the firm, and in the course of client and counterparty relationships. It should be read alongside the Legal Notice and Terms of Use set out above.

For individuals in the United Kingdom and European Economic Area, the data controller is Cotswolds Capital Advisors Limited, registered at 128 City Road, London, EC1V 2NX, United Kingdom.

For individuals in the United States, the data controller is Cotswolds Capital Inc., registered at 1430 Broadway, New York, NY 10018, USA.

For individuals in the United Arab Emirates, the data controller is Cotswolds Capital Consulting L.L.C., registered at Tajer 9051, Downtown, Dubai, United Arab Emirates.

The firm may collect the following categories of personal data.

Identity and contact data includes name, title, employer, job title, email address, telephone number, and correspondence address, where provided directly through the Site's contact form, by email, or in the course of an engagement.

Communication data includes the content of any enquiries, correspondence, or communications sent to the firm.

Technical data includes IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology details on the devices used to access the Site, collected automatically through standard server log files and analytics tools.

Usage data includes information about how the Site is used, including pages visited and time spent on the Site.

The firm does not collect sensitive personal data as defined under applicable data protection legislation and does not knowingly collect data from individuals under the age of 18.

Personal data is collected through the following means. Direct correspondence includes enquiries submitted through the Site's contact form, emails sent to the firm, and telephone conversations. Automatic technical collection occurs through the Site's standard analytics and server infrastructure. In the course of the firm's advisory and engagement activities, data may be provided by clients, counterparties, or intermediaries.

The firm uses personal data for the following purposes and on the following legal bases.

To respond to enquiries and manage correspondence, the legal basis is the legitimate interests of the firm in managing communications and assessing potential engagements.

To perform and manage engagements, the legal basis is performance of a contract, or steps taken prior to entering into a contract, at the request of the data subject.

To maintain records and comply with legal and regulatory obligations, the legal basis is compliance with a legal obligation.

To improve and maintain the Site, the legal basis is the legitimate interests of the firm in understanding how the Site is used and ensuring its proper operation.

To protect the firm's legal rights, the legal basis is the legitimate interests of the firm in establishing, exercising, or defending legal claims.

The firm does not use personal data for marketing purposes and does not send unsolicited marketing communications.

The firm does not sell, rent, or trade personal data. Personal data may be shared in the following limited circumstances. With professional advisers including lawyers and accountants where necessary in the course of the firm's business. With service providers who process data on the firm's behalf, including IT infrastructure and communications providers, subject to appropriate data processing agreements. With counterparties, intermediaries, or other parties where necessary in the course of a specific mandate, subject to the firm's confidentiality obligations. Where required by law, court order, or regulatory authority.

Where personal data is transferred outside the United Kingdom or the European Economic Area, the firm takes appropriate steps to ensure that such transfers are subject to adequate safeguards in accordance with applicable data protection law.

The firm retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law or regulation. For enquiries that do not result in an engagement, personal data is typically retained for a period of two years from the date of last contact. For engagement-related data, retention periods are determined by applicable legal and regulatory requirements and the firm's legitimate business interests.

The Site uses cookies and similar tracking technologies to support its operation and to collect usage data as described in section 03 above. The firm uses analytics tools to understand how the Site is used in aggregate. Cookies used for these purposes do not identify individual users.

By continuing to use the Site, you consent to the use of cookies as described in this section. You may disable cookies through your browser settings, although this may affect the functionality of the Site.

Subject to applicable data protection law, individuals whose personal data is held by the firm have the following rights. The right to be informed about how their personal data is used. The right to access personal data held about them. The right to request correction of inaccurate or incomplete personal data. The right to request erasure of personal data in certain circumstances. The right to restrict processing of personal data in certain circumstances. The right to object to processing based on legitimate interests. The right to data portability in certain circumstances.

To exercise any of these rights, or to raise any concern about the firm's handling of personal data, please contact the firm directly using the contact details on this Site. The firm will respond to all requests within the timeframe required by applicable law.

Individuals in the United Kingdom have the right to lodge a complaint with the Information Commissioner's Office at ico.org.uk. Individuals in other jurisdictions may have equivalent rights to complain to their local data protection authority.

All queries relating to this Legal Notice, Terms of Use, or Privacy Policy should be directed to the firm through the contact details set out on the Contact page of this Site, or in writing to the registered address of the relevant entity as set out in section 02 above.

Cotswolds Capital is the trading name of Cotswolds Capital Advisors Limited (CRN 16873557), Cotswolds Capital Inc. (EIN 61-2316210), and Cotswolds Capital Consulting L.L.C. (MLN 1562611).

© Cotswolds Capital 2026. All rights reserved.