ASP Private Capital
Trading name of ASP Consulting Partners Ltd
Last Updated: 27 October 2026

1. Introduction

ASP Private Capital (“ASP”, “we”, “us” or “our”) is the trading name of ASP Consulting Partners Ltd, a company registered in England and Wales under company number 09641362.

Our registered address is:

86–90 Paul Street
City of London
London
EC2A 4NE
United Kingdom

We are committed to handling personal information responsibly, transparently and securely. This Privacy Policy explains how we collect, use, store and share personal information when you visit our website, submit an enquiry, express an interest in investment opportunities or communicate with us in a professional capacity.

This policy is intended to explain our approach in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and other applicable data protection and privacy legislation, including the Privacy and Electronic Communications Regulations 2003 (“PECR”), where relevant.

Please read this policy carefully to understand how your information is handled and the rights available to you.

2. Who is responsible for your personal information?

ASP Consulting Partners Ltd, trading as ASP Private Capital, is the organisation responsible for determining how and why personal information is processed in connection with our business activities, where we act as the data controller.

You can contact us about this policy or the handling of your personal information at:

Email: info@aspinvest.co.uk
Website: https://www.aspinvest.co.uk

We have not identified a separately appointed Data Protection Officer (DPO) for the purposes of this policy. We will provide the contact details of a DPO if one is appointed and required to be identified.

3. What personal information do we collect?

The information we collect depends on how you interact with ASP and the nature of your enquiry.

3.1 Personal and contact information

When you contact us or submit a form, we may collect:

• Full name.

• Business email address.

• Telephone number.

• Business or professional affiliation, where provided.

• The contents of your enquiry and subsequent correspondence.

3.2 Investor classification and eligibility information

Where relevant to an enquiry, we may collect information concerning your stated investor classification, professional capacity or potential eligibility to access private-market opportunities.

This may include whether you identify as a High Net Worth Individual, Sophisticated Investor, Family Office representative, Wealth Manager or Professional Introducer.

We may also collect information concerning your investment interests, preferences, indicative investment range and intended timeframe, where you choose to provide it.

Information supplied through an initial enquiry is not, by itself, formal verification of investor status or eligibility.

3.3 Website and technical information

When you visit our website, certain technical information may be collected through the website infrastructure, server logs, analytics technologies or cookies, depending on the services and settings in operation.

This may include:

• IP address and general device or browser information.

• Pages visited and interactions with the website.

• Referring websites and approximate usage information.

• Cookie identifiers and related technical data, where applicable.

The precise information collected will depend on the website configuration and the technologies enabled at the time of your visit.

3.4 Information you provide voluntarily

You may choose to provide additional information in messages or correspondence. Please avoid sending sensitive personal information or detailed financial documents through general website forms or ordinary email unless we have specifically requested the information through an appropriate process.

We do not intend to collect more personal information than is reasonably necessary for the relevant purpose.

4. How do we collect your information?

We primarily collect personal information directly from you when you:

• Complete a contact or investor enquiry form.

• Contact us by email or telephone.

• Arrange a meeting or consultation.

• Communicate with us regarding a potential investment introduction.

• Visit or interact with our website.

We may subsequently generate records of communications, meetings, enquiries and actions taken in connection with our relationship with you.

If our collection practices change to include information from third-party introducers, investment providers or publicly available sources, this policy will be updated as appropriate.

5. Why do we use your personal information?

We use personal information for the following purposes, where applicable:

5.1 Responding to enquiries

To acknowledge, assess and respond to your enquiry, communicate with you and determine the appropriate next steps.

5.2 Understanding investor requirements

To understand your stated investor classification, investment interests and general requirements so that we can determine whether an enquiry is appropriate to progress within our role as a capital introducer.

This does not constitute personal investment advice, a recommendation that an investment is suitable for you, or a guarantee that you will qualify for or be accepted by an investment provider.

5.3 Facilitating introductions

Where appropriate, to communicate with relevant investment providers and coordinate the exchange of information necessary to progress a potential introduction.

We will share personal information for this purpose only where there is an appropriate basis to do so and in accordance with applicable data protection requirements.

Investment providers remain responsible for their own acceptance procedures, investment agreements, payment instructions and any due diligence they are required to conduct.

5.4 Managing professional relationships

To maintain records of enquiries, correspondence, meetings and ongoing business relationships, and to provide appropriate follow-up communications relating to an existing enquiry or relationship.

5.5 Operating and improving our website

To maintain website functionality, address technical issues, protect our systems and understand website usage where relevant analytics technologies are enabled.

Non-essential cookies or similar technologies will be used in accordance with applicable consent requirements.

5.6 Legal obligations and the protection of our rights

To comply with applicable legal obligations, respond to lawful requests, establish or defend legal claims, and maintain records where reasonably necessary.

6. What are our lawful bases for processing?

Under the UK GDPR, personal information must be processed on an appropriate lawful basis. The basis depends on the information concerned and the purpose for which it is used.

Our intended lawful bases include the following, subject to confirmation against our actual processing activities.

Legitimate interests

We may rely on legitimate interests where processing is necessary for our legitimate business activities, such as responding to professional enquiries, maintaining business relationships, coordinating introductions and keeping appropriate records.

Where we rely on this basis, we must consider our interests against your rights and freedoms and ensure that the processing is necessary and proportionate.

Steps taken at your request before entering into a contract

Where you request that we take specific steps before entering into a contract with you, we may rely on this basis where the relevant legal requirements are met.

This basis will not automatically apply to every enquiry, particularly where no contract with you is contemplated.

Legal obligation

We may process information where necessary to comply with a legal obligation applicable to us.

Consent

Where required by law, we will seek your consent before carrying out the relevant processing. This may include certain non-essential cookies or electronic marketing activities where consent is the appropriate legal basis.

Where processing relies on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

The lawful basis applicable to each processing activity must be confirmed and documented by ASP. Where we rely on legitimate interests, the relevant interests should be recorded internally.

7. Who do we share your information with?

We do not sell personal information to third parties.

We may share personal information with the following categories of recipients where necessary and appropriate.

7.1 Investment providers

Where you express an interest in an opportunity and an introduction is appropriate, we may share relevant contact details and information about your stated interests or eligibility with the relevant investment provider.

We will seek to limit the information shared to what is reasonably necessary for the purpose of the introduction.

An investment provider may act as an independent data controller for its subsequent processing of your information. Its own privacy notice and procedures may apply.

7.2 Technology and service providers

We use business systems to manage communications, enquiries, meetings and website operations. These include:

• HubSpot — customer relationship management and enquiry records.

• Framer — website hosting and website functionality.

• Google Workspace services — email, calendar and online meetings, including Gmail, Google Calendar and Google Meet.

• Cal.com — meeting scheduling.

• Amazon Web Services (AWS) — infrastructure or hosting services, where used in our systems.

These providers may process personal information on our behalf, depending on the specific service and configuration. Their roles, access to information and contractual data protection arrangements will depend on the service in question.

We take steps to ensure that appropriate contractual and technical arrangements are in place where required.

7.3 Professional advisers and authorities

We may disclose information to legal, accounting, compliance or other professional advisers where reasonably necessary, or to public authorities, regulators, courts or law enforcement bodies where required or permitted by law.

7.4 Corporate transactions

If our business undergoes a restructuring, sale or transfer, personal information may be disclosed where necessary for that transaction, subject to applicable confidentiality and data protection requirements.

We do not share information with third parties simply because they may have a commercial interest in it.

8. International transfers

Some of the technology providers we use may process information, or make it accessible, outside the United Kingdom.

The locations in which personal information is processed, the relevant provider entities and the applicable transfer mechanisms have not yet been fully confirmed for all services used by ASP.

Before relying on any international transfer arrangement, we will identify the relevant data flows and ensure that any restricted transfer is covered by an applicable UK adequacy regulation, appropriate safeguards or a valid statutory exception, as required by law.

Where appropriate safeguards are used, these may include the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with any required transfer risk assessment or data protection test.

Further information about relevant safeguards will be made available where required.

This section must be reviewed and completed once ASP has confirmed the locations, contractual arrangements and transfer mechanisms applicable to its technology providers.

9. How long do we keep personal information?

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including managing enquiries and relationships, facilitating introductions, maintaining appropriate records and meeting applicable legal obligations.

Retention periods may vary depending on the nature of the information, the stage of an enquiry, whether an introduction has progressed and whether information must be retained for legal or evidential purposes.

We may retain information for longer where necessary to establish, exercise or defend legal claims or to comply with an applicable legal obligation.

When information is no longer required, we will take appropriate steps to delete it or securely dispose of it, subject to applicable legal and operational requirements.

ASP does not yet have a confirmed retention schedule reflected in this policy. We will establish and maintain appropriate retention periods for enquiry records, investor information, correspondence, meeting records and technical data.

10. How do we protect your information?

We take the handling of personal information seriously and seek to apply appropriate technical and organisational measures to protect it against unauthorised access, accidental loss, destruction, alteration or disclosure.

Depending on the systems and processing involved, these measures may include access controls, account security, appropriate permissions, secure service-provider arrangements and the careful handling of information shared with investment providers.

Access to personal information should be limited to those who require it for legitimate business purposes.

No method of electronic transmission or storage can be guaranteed to be completely secure. We therefore cannot promise absolute security, but we will take appropriate measures in accordance with our legal obligations.

11. Cookies and website analytics

Our website may use cookies or similar technologies to support essential functionality, understand website usage or provide other technical services.

The precise cookies, analytics technologies and tracking mechanisms currently enabled on the ASP website have not yet been confirmed for this policy.

Where applicable, we will:

• Explain the purposes of cookies and similar technologies.

• Obtain consent before using non-essential cookies or technologies where required by law.

• Allow visitors to manage or withdraw their consent where applicable.

• Provide relevant information about the technologies used and their providers.

Strictly necessary technologies may be used where they fall within an applicable legal exemption.

Please note that a statement in this Privacy Policy does not, by itself, constitute a valid cookie consent mechanism. The website must implement any required consent controls and ensure that non-essential technologies do not operate before the necessary consent is obtained.

A separate Cookie Policy or cookie information page may be provided where appropriate.

12. Marketing and communications

ASP uses personal information to respond to enquiries and manage communications relating to an existing or prospective professional relationship.

We do not currently intend to use enquiry information for unrelated bulk marketing campaigns under this policy.

If our communications practices change, we will assess the applicable requirements before sending marketing communications. This includes the rules governing electronic marketing under PECR and the UK GDPR, where applicable.

You may ask us to stop sending non-essential relationship-related communications at any time by emailing info@aspinvest.co.uk.

Where a communication is necessary to respond to an active enquiry or manage a matter you have requested, we may continue to provide relevant information even if you ask to stop other communications.

13. Your data protection rights

Subject to applicable law and the circumstances of the processing, you may have the following rights in relation to your personal information.

Right of access

You can request a copy of the personal information we hold about you and information about how we use it.

Right to rectification

You can ask us to correct inaccurate or incomplete personal information.

Right to erasure

You can ask us to delete personal information where the legal conditions for erasure are met.

Right to restriction

You can ask us to restrict the processing of your personal information in certain circumstances.

Right to data portability

Where the relevant legal conditions apply, you can request personal information you have provided to us in a structured, commonly used and machine-readable format, or ask us to transmit it to another organisation where technically feasible.

Right to object

You can object to processing based on our legitimate interests where the applicable legal conditions are met. We will assess the objection in accordance with the law.

Rights relating to consent

Where processing is based on consent, you can withdraw your consent at any time.

Rights relating to automated decision-making

You may have rights where decisions are made solely by automated means and have legal or similarly significant effects on you. ASP does not intend to use the information collected through its ordinary website enquiry process to make such decisions.

These rights are not absolute in every circumstance, and exceptions may apply.

To exercise a right, contact us at info@aspinvest.co.uk. We may need to verify your identity before responding.

We will respond within the time limits required by applicable data protection law. Requests will generally be handled without charge, although the law permits certain exceptions.

14. Complaints

If you have concerns about how ASP handles your personal information, please contact us first at:

Email: info@aspinvest.co.uk

We will consider your concerns and seek to address them appropriately.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO), the independent authority responsible for upholding information rights in the United Kingdom.

Website: https://ico.org.uk/
Telephone: 0303 123 1113

You may contact the ICO if you believe that your personal information has been handled in breach of applicable data protection law.

15. Third-party websites and services

Our website or communications may contain links to third-party websites or services.

Those websites operate under their own privacy policies and terms. ASP is not responsible for the privacy practices of third-party websites that it does not control.

We recommend reviewing the relevant privacy information before submitting personal information to another organisation.

16. Children

ASP's services are directed towards qualifying investors, professional intermediaries and other relevant business contacts rather than children.

Our website and services are not intended to solicit personal information from children. If we become aware that personal information has been collected inappropriately from a child, we will assess the circumstances and take appropriate steps in accordance with applicable law.

17. Changes to this Privacy Policy

We may update this policy from time to time to reflect changes in our business activities, website functionality, technology providers or applicable legal requirements.

The current version will be published on our website with its latest revision date.

Where required by law, we will provide additional information or notify affected individuals of material changes.

18. Contact us

For questions about this Privacy Policy, requests concerning your personal information or other data protection matters, please contact:

ASP Private Capital
Trading name of ASP Consulting Partners Ltd
Company number: 09641362

86–90 Paul Street
City of London
London
EC2A 4NE
United Kingdom

Email: info@aspinvest.co.uk
Website: https://www.aspinvest.co.uk