Privacy Notice
At Cedar capital, we understand that your privacy is important. We collect and use your personal data as described in this Privacy Notice (the “Notice”) as a permitted by relevant data protection legislation.
The purpose of this Notice is to explain how and why we collect information from you, who has access to it and what your rights are. Please read this Notice carefully to ensure that you understand it.
1. Who we are and how to contact us
Cedar Capital Partners (“the Company”, “we”, “us”) is the controller of your personal data. This means we decide why and how it is used.
For the purpose of the data protection legislation, we are the data controllers under the UK Data Protection Act/ UK GDPR. We are responsible for determining the purposes and means of how your data is processed.
| Address | 45 Albemarle Street, London W1S 4JL |
| Data Protection Lead Contact Details | info@cedarcp.com |
2. Who this notice is for
This notice applies if you deal with us in any of the following ways, or if we hold your details because of a relationship with a person or organisation that does:
- you are, or are considering becoming, an investor in or client of the Company or any fund or data vehicle we manage or advise, or you are a representative, director, partner or beneficial owner of one;
- you work for, or are a shareholder or director of, a business we have invested in or are considering investing in;
- you are an adviser, intermediary, supplier, service provider, introducer or other business contact (or work for one);
- you subscribe to our updates, attend our events or contact us with an enquiry;
- you visit our offices; or
- you visit or use our website.
3. What personal data we collect
| Category | Examples | Who it relates to |
|---|---|---|
| Identity and contact | Name, job title, employer, business and personal address, email, telephone, date of birth, nationality, signature. | Everyone |
| Due diligence and verification | Passport and driving licence, proof of address, source of funds and wealth, ownership and control information, tax residency and tax identification numbers, sanctions, politically exposed person (PEP) and adverse media screening results. | Investors, clients and their beneficial owners and representatives; some counterparties |
| Investment and financial | Bank details, investor classification, investment history and holdings, subscription and transaction records. | Investors and clients |
| Relationship and communications | Emails, meeting notes (include AI meeting minutes), correspondence, feedback and complaints, contract documents. | Everyone we deal with |
| Marketing and events | Subscriptions and preferences, event attendance, dietary and accessibility needs (which may reveal health information). | Subscribers and event attendees |
| Website and technical | IP address, device and browser information, pages visited. | Website visitors |
| Premises | Visitor log entries and CCTV images. | Visitors to our offices |
Screening for money laundering and sanctions can involve special category data (for example, political opinions inferred from PEP status) and criminal offence data (such as allegations or convictions revealed by screening). We process this only where the law allows, as explained below.
4. Where we get your data from
- directly from you, or from the person or organisation you represent or work for;
- from intermediaries, introducers, advisers, fund administrators and custodians;
- from verification, sanctions, PEP and adverse media screening providers;
- from public sources such as Companies House, the Financial Conduct Authority register, company websites, professional networking sites and the press; and
- from our website and systems, for example through cookies and security logs.
5. Why we use your data and our lawful bases
| What we use your data for | Lawful basis (Article 6) |
|---|---|
| Onboarding and managing investors and clients; providing and administering our services; processing subscriptions and payments | Contract (or steps at your request before a contract); legitimate interests where the contract is with an organisation you represent |
| Customer due diligence, anti-money laundering, sanctions and tax checks and reporting (including FATCA and CRS), and other legal and regulatory duties | Legal obligation (including the Money Laundering Regulations 2017, tax legislation and, where applicable, FCA rules) |
| Preventing and detecting fraud, financial crime and other unlawful acts | Legal obligation; legitimate interests |
| Developing and maintaining business relationships; identifying and assessing investment opportunities; communicating about our business and funds | Legitimate interests (running and promoting our business) |
| Sending marketing and updates by email | Consent, or legitimate interests where PECR allows (for example, corporate subscribers); you can opt out at any time |
| Running events and handling enquiries | Legitimate interests; consent for any health-related information such as accessibility needs |
| Operating, securing and improving our website and IT systems; securing our premises (visitor logs, CCTV) | Legitimate interests; consent for non-essential cookies |
| Record-keeping, audit, insurance, legal advice and establishing or defending legal claims; business planning, and any sale or restructure of the business | Legitimate interests; legal obligation |
Where we use special category or criminal offence data, we do so under the conditions in Schedule 1 DPA 2018 for preventing or detecting unlawful acts, preventing fraud, and suspicion of terrorist financing or money laundering, or (for health information about event needs) with your explicit consent. Legitimate interests mean we balance our interests against your rights; you can ask us for details of that assessment.
Marketing
We send marketing only where permitted. Every message includes an easy way to unsubscribe, and you can also tell us at any time that you do not want to receive it. We keep a record of your objection so that we do not contact you again.
If you do not give us your data
We are legally required to carry out checks before we can accept some clients and investors, so if you do not provide the information we ask for we may not be able to work with you or process your transactions.
6. Who we share your data with
- fund administrators, custodians, banks, registrars, transfer agents and other service providers involved in investments;
- verification, screening and KYC providers;
- our lawyers, accountants, auditors, tax advisers and insurers;
- IT, email, CRM, cloud, security and marketing platform providers;
- regulators and public authorities, such as the FCA, HMRC, the National Crime Agency and law enforcement, and courts, where required or permitted by law;
- other parties to a transaction or relationship, such as co-investors, counterparties, and portfolio companies, to the extent necessary; and
- prospective buyers or investors and their advisers in a sale, merger or restructure of our business.
Where a supplier handles your data on our behalf, it does so under a written contract and on our instructions. We do not sell your personal data.
7. International transfers
We do not routinely transfer your personal data outside the UK.If we do transfer data outside the UK, we make sure it is protected by UK adequacy regulations, the ICO’s International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses (with a documented risk assessment), or another lawful mechanism under UK GDPR. You can ask us for details of the safeguards.
8. Cookies and website data
Our website uses cookies and similar technologies. Strictly necessary cookies are always active. For any others, we ask for your consent where the law requires it, and you can change your preferences at any time.
9. Automated decisions
We do not make decisions about you based solely on automated processing that have a legal or similarly significant effect If this changes we will tell you and you will have the right to human review and to challenge the decision.
10. How long we keep your data
We keep your data only for as long as we need it for the purposes above, including to meet legal, accounting and regulatory requirements and to deal with possible claims. The main periods are set out below:
| Record | How long we keep it |
|---|---|
| Due diligence and anti-money laundering records | 5 years after the end of the business relationship (or completion of the transaction), as required by the Money Laundering Regulations 2017 |
| Investor and client agreements and files | 6 years after the relationship ends (12 years if executed as a deed) |
| Communications with investors and clients | 6 years after the relationship ends |
| Tax reporting self-certifications (FATCA/CRS) | 6 years after the end of the reporting year |
| Prospective investors and business contacts | 24 months after our last meaningful contact, unless you ask us to stay in touch |
| Marketing preferences and unsubscribes | While you are subscribed; we then keep a minimal suppression record so we do not contact you again |
| CCTV | CCTV footage is retained for 30 days, unless needed for an investigation |
If a legal claim, investigation or regulatory request is under way we may keep relevant records for longer, and when the period ends we securely delete or anonymise the data.
11. Keeping your data secure
We protect your personal data with appropriate technical and organisational measures, including access controls, encryption, multi-factor authentication, staff training and contracts with suppliers who handle data for us. If a breach affecting your data is likely to result in a high risk to you, we will tell you without undue delay.
12. Your rights
Under data protection law you have the following rights. Some apply only in certain circumstances. You can ask verbally or in writing and you do not need to use a form. Unless we tell you otherwise, we respond within one month, and we can extend this by up to two further months for complex or multiple requests (we will tell you why). We may ask for proof of identity.
| Your right | What it means | How to exercise it |
|---|---|---|
| Right to access and receive a copy of the personal data we hold about you. | To receive a copy of your personal data and information about how we use it. | Email the Data Protection Lead at info@cedarcp.com or ask your usual contact. It is generally free for you to request access to your personal data. We only refuse or charge a fee if a request is manifestly unfounded or excessive. We carry out reasonable and proportionate searches. |
| Rectification | To have inaccurate or incomplete data corrected. | Email the Data Protection Lead or tell your usual contact. Tell us what is wrong and what it should say. |
| Erasure | To ask us to delete your data, for example if we no longer need it or you withdraw consent. | Email the Data Protection Lead. We may need to keep some data to meet legal duties such as anti-money laundering rules, and we will explain if so. |
| Restriction | To ask us to pause our use of your data, for example while we check its accuracy. | Email the Data Protection Lead and say which data and why. You can ask us to lift the restriction later. |
| Portability | To receive certain data you gave us in a structured, machine-readable format, or have it sent to another organisation. | Email the Data Protection Lead describing the data, who should receive it and how. |
| Objection | To object to processing based on our legitimate interests, and to object at any time to direct marketing. | Email the Data Protection Lead. To stop marketing, use the unsubscribe link in any message or email us. We act on marketing objections promptly. |
| Automated decisions | Not to be subject to certain decisions based solely on automated processing (we do not currently make any). | Email the Data Protection Lead. |
| Withdrawing consent | Where we rely on your consent, to withdraw it at any time. This does not affect processing carried out before you withdrew it. | Use the unsubscribe or preferences link or email the Data Protection Lead. |
13. Complaints
If you are unhappy with how we have handled your personal data, please tell us first so that we can put it right. You can complain to the Data Protection Lead:
- by email to info@cedarcp.com
- by post to Data Protection Lead, Cedar Capital Partners, 45 Albemarle Street, London W1S 4JL;
- by telephone on 0207 484 3560, or in person or via any member of staff.
We will acknowledge your complaint within 30 days of receiving it (we aim to do so within five working days), investigate it without undue delay and to an appropriate extent, keep you informed of progress, and tell you the outcome. You do not have to complain to us first. You also have the right to complain to the Information Commissioner’s Office (ICO) at any time:
- Website: ico.org.uk/make-a-complaint
- Telephone: 0303 123 1113
- Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
You may also have the right to take legal action.
14. Changes to this notice
We may update this notice from time to time. The current version is always on our website. If we make significant changes, we will tell you in an appropriate way.
15. Any Questions
If you have any questions or comments about this Notice, want to know more about how we use your data, or want more information on your rights, please contact us at info@cedarcp.com or 45 Albermarle Street, London, W1S 4JL.
Cedar Capital Partners | Privacy Notice | Last updated October 2026
