Data protection privacy notice

We are committed to protecting your personal information and ensuring we respect your privacy. This Privacy Notice explains how we will look after and use any personal information that we collect and/or receive about you.

What is personal information?

Personal information means any information about you from which you can be identified. Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and e-mail address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie.

Who we are

The Ingenious Capital Management Holdings Limited and Ingenious Media Holdings Limited group companies, are listed below. Ingenious Capital Management Limited will usually be the controller of your personal data, though in some cases you will have an agreement with another Ingenious company listed below, which will be the controller.

Ingenious companies:

  • Freeshire Limited aka Ingenious Media Limited
  • Ingenious (IEP Cover) Limited
  • IFP1 Corporate Partner Limited
  • IFP2 Corporate Partner Limited
  • Ingenious Capital Management Limited
  • Ingenious Collections Limited
  • Cradgrove Limited aka Ingenious Film Partners 2 Limited
  • Barnsdale Hills Limited aka Ingenious Film Partners 3 Limited
  • Langreave Limited aka Ingenious Film Partners Limited
  • Granleaf Square Limited aka Ingenious Films Limited
  • Goldwoodshire Limited aka Ingenious Media Investments Limited
  • Glasine Limited aka Ingenious Media Services Limited
  • Enghamshire Limited aka Ingenious Resources Limited
  • Burguard Limited aka Ingenious Ventures Limited
  • Ingenious Real Estate Finance LLP
  • Ingenious Real Estate Finance 2 LLP
  • IRE Security Limited

This Privacy Notice is issued on behalf of all Ingenious companies listed above so when we mention “Ingenious”, “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant Ingenious company responsible for processing your data.

If you have any questions about this Privacy Notice or the information we hold about you please contact our Data Protection Officer using the details set out below:

Name of the DPO for Ingenious: Dane Persson

Email address:

Postal address: Ingenious Capital Management Limited, Parcels Building, 14 Bird St, London, W1U 1BU

Contact telephone numbers: 0207 319 4086

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to this Privacy Notice and duty to inform us of changes

We keep our Privacy Notice under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

What types of information do we use?

We collect information in the course of providing our financial services to you. The information about you, which we may collect, use, and store is:

  • Payment information (bank account, credit card or other details);
  • Employment or work history/background;
  • Information on trading or other financial activity;
  • Contractual/contact information i.e., our ‘history’ together – services provided or discussed;
  • Instructions or requests;
  • Financial information such as financial position and history;
  • Documentary data (things can include passport or drivers’ licence or other forms of identification);
  • Credit history; and
  • Tax information

We may collect the following information from you, which is referred to as “special categories of personal data” or “criminal offence data” because it is sensitive information about you and will require special protections. The information we collect is in relation to your:

  • Health data.
  • Criminal record.

We are able to process this information because you have explicitly consented to the processing of this data in relation to one of our products. This is set out in our investor application forms, or other relevant legal agreement. 

Consequences of not providing some types of information

Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the products and services you asked for. In this case we may have to cancel the product or services, but we will tell you if this is the case.

How do we collect information about you?

Typically, we will collect information from you when you contact us directly or provide information in order for us to provide our products and services. We collect information from and about you in the following ways:

Through direct interactions when you, or someone that you have authorised to, give us your personal information by filling in forms or during correspondence with us. This includes when you:

  • Apply for our products and/or services;
  • Create an account;
  • Complete questionnaires, for example to give us feedback;
  • Speak to us over the telephone;
  • Are a stakeholder (such as a director, member, shareholder or partner) in a business and the business applies for our products and/or services or enters into an agreement with us. In such circumstances, we may obtain personal data about you to carry out our due diligence and know your customer checks on that business;
  • Are providing a personal guarantee in favour of a business who applies for our products and/or services or enters into an agreement with us; and/or
  • Provide us with any services and/or products that we have requested (for example, where you are an employee of a surveyor or valuer that we have instructed and you provide us with a signed report and/or valuation).

Through using our website when we collect information using cookies or similar technologies which tell us about your equipment, browsing actions and patterns. 

Through third parties such as fraud and money laundering prevention agencies. We may also receive personal information from other companies and organisations such as independent financial advisers.  The third parties which we receive personal information from are as follows:

  • Credit assessment and anti-financial crime screening service providers;
  • Recruitment agencies;
  • Independent financial advisers; and
  • Marketing data providers.

How we will use your personal information

We only obtain, use and keep personal information where we need it for a specific purpose. We set out in the table below the ways in which we plan to use your personal information. We are only able to use your personal information if we have a proper legal reason or basis for doing so. This is called a legal basis and the data protection laws require that we have a legal basis for processing your personal information so that your privacy is protected. Most commonly we will use your information in the following ways:

  • Where we need to perform a contract we are about to enter into or have entered into with you. For example, we have agreed to manage investments for you and have a contractual agreement with you to do this.
  • Where we need to comply with a legal obligation. We may need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example, this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information so you understand the risk of the financial services we can provide.
  • Where it is necessary for our, or a third party’s, legitimate interests and your interests and fundamental right do not override those interests. For example, processing your information to provide investment management services to you.

We set out in the table below all the ways we plan to use your personal information and the legal bases we rely on to do so. We also explain what our legitimate interests are where appropriate.

PurposeLawful basis for processing including our legitimate interests
To on-board you as a new customerTo fulfil our contract with you
To manage your accountTo fulfil our contract with you
To monitor your investment on an on-going basisTo fulfil our contract with you
To meet our regulatory obligations to provide you with regular information about your investmentTo fulfil our legal obligations
To conduct customer due diligenceTo fulfil our legal obligations to prevent financial crime
To acquire an asset from you or enable you to purchase an asset we are seeking to dispose ofNecessary for our legitimate interests – to manage our clients’ investment portfolios
We hold some historic data on past investments in the event that any issues arise in relation to these investmentsNecessary for our legitimate interests – to resolve issues that arise in relation to historic investments
To make a decision as to whether to provide our products and/or services to our customersNecessary for our legitimate interests – to provide our products and/or services to our customers
To facilitate our internal business operationsNecessary for our legitimate interests – to manage our business and financial affairs in order to ensure that we can continue operating as a business

We will only use your personal information for the reason for which we collected it. We will only use it for another reason if we believe that new reason is compatible with the original purpose.


We may use your personal information to send you communications if we believe that we have a ‘legitimate interest’. We are required to make an assessment with regards to the benefits weighed against how appropriate it is to contact you in this way and whether it would be unfair to you. We believe that as a commercial enterprise we do have a legitimate interest in contacting you about our products or services, but we will only do so if we believe it would be of interest or beneficial for you. You are free to change your mind about receiving communications from us by selecting the email preferences link which you will find at the bottom of all marketing communications or by emailing our Business Development team at

Who we share your information with

We may need to provide your personal information to third parties for a variety of reasons, for example, we may need to provide information to assist in the detection or prevention of crime or for the purpose of safeguarding national security. Please refer to the table above in the section ‘How we will use your personal information’ which explains how we use your data. The third parties we share your information with for the purposes set out in the table above are as follows:

  • Custodians
  • Depositories
  • Fund administration and services companies
  • Anti-financial crime service providers
  • Professional advisors, including law firms
  • Company registrars
  • Payment services providers
  • Debt collection agencies
  • Credit reference and fraud prevention agencies
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice
  • Institutional funding lines and equity providers in accordance with our contractual obligations
  • Third party agents and/or contractor (including, but not limited to, the providers of our electronic data storage services, auditors, solicitors or valuers) for the purposes of providing services to us
  • Government bodies and agencies in the UK.

We may also share your personal information with other Ingenious companies for the purposes set out in the table above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Sending your information outside of the UK

We may share your personal data with third parties based outside the UK for the purposes set out in the table above so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, for example the European Economic Area.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Storing your information

As a financial services provider we will typically have a contract with you and will need to keep your personal information (updated to ensure accuracy) to fulfil our contract. We also need to comply with UK law, which often requires us to keep certain records – which will include certain personal information – for several years or indefinitely for certain types of services i.e. in relation to life policies.

We will ensure that all records are safely destroyed if we no longer need to retain them. We review our retention periods for personal information on a regular basis. 

When we decide how long we will retain your personal information, we will take into account the amount, nature, sensitivity of your information and how we want to use it as well as the potential risk of harm being caused from unauthorised use or disclosure.

Your rights

You are provided with a number of different rights under the data protection laws in relation to your personal information. These allow you:

  • To access your information;
  • To request we correct your information;
  • To request that we erase your information;
  • To object to the processing of your information;
  • To request a restriction in the processing of your information;
  • To request a transfer of your information; and
  • To withdraw your consent.

If you wish to exercise any of these rights please contact us via email

Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.


We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required to do so.