Data Processing Policy

Last updated: 19 November, 2025

Overview

This Data Processing Policy is applicable to North Capital Management Ltd’s (NCM) core discretionary investment management function. This policy should be read in conjunction with the Firm’s standard terms of business. The Chief Operating Officer is responsible for this policy.

Introduction

Changes to UK data privacy law came into effect on the 25th of May 2018. The new regulation passed by the European Parliament is the General Data Protection Regulation (GDPR). This Privacy Notice explains how we use your personal data, describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the regulatory requirements.

At NCM, we take your privacy and the protection of your personal data very seriously. We have reviewed our internal systems, processes and third parties that hold your data and are satisfied that it is secure and GDPR compliant. You can find out more here about your privacy rights and how we gather, use and share your personal information.

Summary

Who we are

North Capital Management Ltd, of Weymss House, 6 – 8 Weymss Place, Edinburgh EH3 6DH acts as a data controller for personal information relating to yourself.

Your rights

You have the right to object to how we process your personal information. You also have the right to access, correct, restrict and sometimes delete the personal information we use. In addition, you have a right to complain to us and to the data protection regulator. Contact details are shown here.

Your privacy rights are detailed on the UK Information Commissioner website pages.

North Capital will not share your information with any other party, except as indicated in this Privacy Policy Statement, or where required to do so by any statutory, governmental or regulatory body for legitimate purposes.