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Codex Capital Data Protection Statement

The terms set out in this Data Protection Statement apply to any information you give Codex Capital Partners Limited and/or any affiliated entity or member of the Codex Group of companies from time to time. It will also apply to any information you have already provided.


We may revise or supplement our Data Protection Statement from time to time for any of the following reasons:

  • to provide for the introduction of new or improved systems, methods of operation, services or facilities;

  • to reflect an actual or expected change in market conditions or general market practice;

  • to comply with or anticipate any changes in any legal or regulatory requirement;

  • to ensure that our business is run prudently;

  • to make our Data Protection Statement clearer or more favourable to you; or

  • to rectify any mistake that might be discovered from time to time.


You must not send us personal information about someone else without first getting his or her consent for it to be used and disclosed in the ways set out in our Data Protection Statement. This is because we will assume he or she has consented, although we may still ask for confirmation from them. Where you do give us information about someone else, or someone else discloses a connection with you, that information may be taken into account with your other personal information.


We treat your privacy very seriously and we understand that you will wish to know how we will use the information we collect from or about you. We use your personal information in accordance with our Data Protection Statement and will fully comply with all applicable UK data protection legislation (including the General Data Protection Regulation 2018). It is important that you take all necessary and appropriate steps to protect your data yourself (for example, by ensuring that all passwords and access codes are kept secure).


Codex Group consists of Codex Capital Partners Limited and Codex Capital Partners (UK) Limited and any direct or indirect subsidiaries of those two companies. Codex Land is affiliated to the Codex Group.


Information which we may collect about you

We may collect and process the following information about you:

  • Information you provide (either directly or through an agent such as a solicitor, independent financial advisor or introducer) by completing an application for our products and services, whether in writing, on our website, over the telephone or by some other means. This information may include your name, address, contact details, date of birth, bank details, details about your employment and financial information.

  • Records of any correspondence from you or anyone acting on your behalf.

  • Details of transactions you carry out with us.

Purpose of collecting the information

We may process, transfer and disclose your information for the purposes of:

  • providing you with services, monitoring your investments and complying with your instructions;

  • verifying your identity;

  • detecting and preventing fraud;

  • complying with laws and regulations (including the rules of any regulatory authority) and public duties;

  • in the interests of security and crime prevention;

  • analysis in order to assess and improve our business or the business of Codex Group and the services Codex Group offers;

  • where you have a contract with you to do so or you have provided explicit consent, we may contact you from time to time for regarding product and services available marketing purposes.


We will act proportionately and responsibly when we process, transfer or disclose your information and we will act strictly in accordance with the General Data Protection Regulation Act 2018. We will not process any of the above information.


We may at any time search your record with a fraud prevention agency. If at any time you give us or procure the giving of false or inaccurate information and we suspect fraud we will record this. The fraud prevention agency will use information recorded for statistical analysis about fraud and will also share it with other organisations who will use it to prevent fraud and to help make decisions on motor, household, credit, life and other insurance proposals and claims by you, members of your household or any other businesses associated with you.


We may from time to time contact you about products and services available from Codex Group which we believe may be of interest to you. We may do this by post or by phone unless you have told us in writing not to; and by e-mail, text or other electronic means if you have provided us with explicit consent that we can. You can tell us in writing at any time if you change your mind and wish to withdraw consent.


Disclosure of your information

Your personal information may be passed to and used by companies within Codex Group and our agents and sub-contractors who administer or process the information on our behalf Most of our sub-contractors and administrators are based in the UK or EEA, however, one in particular is based in Gibraltar. Please contact Tracey Rowe at Codex Capital Partners Limited, 49 Upper Brook Street, London W1K 2BR for an up-to-date list of the current members of Codex Group and detail of any agent or sub-contractors we use from time to time.


We may also disclose your personal information to third parties in the following circumstances:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer.

  • If Codex Capital Partners Limited or Codex Capital Partners (UK) Limited or substantially all of one or both of their assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.


If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of the Codex Group, our customers, or others.


International transfer

We may on occasion transfer your personal information outside the European Economic Area (EEA) to countries which may not offer the same level of data protection as the United Kingdom.


In particular, your information may be sent to Gibraltar, which is where one of our company administrators is based, and the USA and any other jurisdiction in which our IT providers, an agent or a sub-contractor carries on business. If this happens, we will ensure that anyone to whom we pass your information agrees to treat your information with the same level of protection as if we were dealing with it.


Access to your information and correction

Subject to some exceptions, you have a right to access personal data that is held about you. To obtain a copy of the personal information we hold, you should write to Kate Osborne at Codex Capital Partners Limited, 49 Upper Brook Street, London W1K 2BR or email We will respond to you within one month of receipt of the request. We will provide a copy of the information held free of charge however we may charge a reasonable fee to comply with requests for further copies of the same information.  You may also request from us details of the fraud prevention agencies with which we may have carried out searches. If there are any inaccuracies in the information we hold about you, please notify us of this in order that we may correct the information we hold about you.


How to contact us

If you have any comments or questions about our Data Protection Statement please contact Kate Osborne, our Data Protection Officer at 49 Upper Brook Street, London W1K 2BR or email

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