Privacy Policy

Bolingbroke Capital Management Ltd

Last updated: 18 July 2026

1. Who we are

Bolingbroke Capital Management Ltd ("Bolingbroke", "we", "us") is registered in England and Wales (company number 12374978) with its registered office at Little Cottage, 67 High Street, Cricklade, Swindon SN6 6DA. Bolingbroke is an appointed representative of Capricorn Fund Managers Limited ("Capricorn"), which is authorised and regulated by the Financial Conduct Authority (FRN 505252). For the purposes of UK data protection law (the UK GDPR and the Data Protection Act 2018), Bolingbroke is the controller of the personal information described in this policy. Questions or requests relating to this policy should be sent to AP@BolingbrokeCapital.com.

2. What this policy covers

This policy explains how we collect, use, share and protect personal information provided through this website — in particular through our investor qualification form — and in our subsequent dealings with prospective and actual investors.

3. Information we collect

Identity and contact details: your name, email address, telephone number, postal address and the organisation you represent.
Client categorisation information: details of your professional experience, financial circumstances, investment activity and knowledge, and any certifications or declarations you make, which we need to assess your client categorisation under the rules of the Financial Conduct Authority.
Anti-money-laundering and identity verification information: where you proceed towards an investment, identification documents (such as a passport), proof of address, and information on source of funds and source of wealth.
Correspondence: records of your communications with us.
Technical data: limited information collected automatically when you use this website, such as IP address, browser type and pages visited, which we use to operate and secure the site. Our website may use cookies or similar technologies for functionality and basic analytics; you can control cookies through your browser settings.

4. How we use your information, and our lawful bases

To assess and record your client categorisation under FCA rules — on the basis of our legitimate interests in offering the fund only to eligible investors, and compliance with our legal and regulatory obligations.
To provide you with fund materials and communicate with you about the fund once your categorisation is complete — on the basis of our legitimate interests and, where applicable, steps taken at your request prior to entering into a contract.
To conduct anti-money-laundering, sanctions and other regulatory checks — on the basis of compliance with our legal obligations.
To maintain records required by applicable law and regulation — on the basis of compliance with our legal obligations.
Where you have given consent (for example, by ticking the consent box on our qualification form), we also rely on that consent for the processing it describes. You may withdraw consent at any time by contacting us; this will not affect processing already carried out, and we may still process your information where another lawful basis applies.

5. Who we share your information with

Capricorn Fund Managers Limited, as our regulatory principal, for oversight, approval and compliance purposes.
The fund's service providers, where necessary in connection with your qualification or investment — including the fund administrator (for subscription processing and AML verification), auditors and legal counsel.
Regulators and law-enforcement or tax authorities, where we are required or permitted to do so by law, including the Financial Conduct Authority and the Cayman Islands Monetary Authority.
Our IT and professional-services providers, who process information on our behalf under appropriate contractual safeguards.

We do not sell your personal information, and we do not share it with third parties for their own marketing purposes.

6. International transfers

Because the fund structure includes entities in the Cayman Islands and the United States, your information may be transferred outside the United Kingdom. Where we transfer personal information internationally, we do so using safeguards recognised under UK data protection law, such as the UK International Data Transfer Agreement or addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.

7. How long we keep your information

We keep personal information only for as long as necessary for the purposes described above. Where you become an investor, or where records are required for regulatory purposes, we retain information for the periods required by applicable law and regulation (typically at least five to six years after the end of the relevant relationship or transaction). Where your qualification does not proceed, we retain your information only as long as reasonably necessary to document our assessment and comply with our obligations.

8. Security

We apply appropriate technical and organisational measures to protect personal information against unauthorised access, loss or misuse, and we limit access to those who need it for the purposes described in this policy.

9. Your rights

Subject to conditions and exemptions under UK data protection law, you have the right to: request access to your personal information; request that inaccurate information be corrected; request erasure; object to, or request restriction of, certain processing; request a copy of information you have provided to us in a portable format; and withdraw any consent you have given. To exercise any of these rights, contact AP@BolingbrokeCapital.com. You also have the right to complain to the Information Commissioner's Office (ico.org.uk), although we would welcome the chance to address any concern first.

10. Automated decision-making

We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects. Client categorisation assessments are reviewed by a person.

11. Changes to this policy

We may update this policy from time to time. The date at the top of this page shows when it was last revised. Material changes will be reflected on this page.

Privacy Policy

Bolingbroke Capital Management Ltd

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Last updated: 18 July 2026

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1. Who we are

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2. What this policy covers

This policy explains how we collect, use, share and protect personal information provided through this website — in particular through our investor qualification form — and in our subsequent dealings with prospective and actual investors.

​

​

3. Information we collect

Identity and contact details: your name, email address, telephone number, postal address and the organisation you represent.

Client categorisation information: details of your professional experience, financial circumstances, investment activity and knowledge, and any certifications or declarations you make, which we need to assess your client categorisation under the rules of the Financial Conduct Authority.

Anti-money-laundering and identity verification information: where you proceed towards an investment, identification documents (such as a passport), proof of address, and information on source of funds and source of wealth.

Correspondence: records of your communications with us.

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​

4. How we use your information, and our lawful bases

To assess and record your client categorisation under FCA rules — on the basis of our legitimate interests in offering the fund only to eligible investors, and compliance with our legal and regulatory obligations.

To provide you with fund materials and communicate with you about the fund once your categorisation is complete — on the basis of our legitimate interests and, where applicable, steps taken at your request prior to entering into a contract.

To conduct anti-money-laundering, sanctions and other regulatory checks — on the basis of compliance with our legal obligations.

To maintain records required by applicable law and regulation — on the basis of compliance with our legal obligations.

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​

5. Who we share your information with

Capricorn Fund Managers Limited, as our regulatory principal, for oversight, approval and compliance purposes.

The fund's service providers, where necessary in connection with your qualification or investment — including the fund administrator (for subscription processing and AML verification), auditors and legal counsel.

Regulators and law-enforcement or tax authorities, where we are required or permitted to do so by law, including the Financial Conduct Authority and the Cayman Islands Monetary Authority.

Our IT and professional-services providers, who process information on our behalf under appropriate contractual safeguards.

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We do not sell your personal information, and we do not share it with third parties for their own marketing purposes.

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​

6. International transfers

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7. How long we keep your information

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8. Security

We apply appropriate technical and organisational measures to protect personal information against unauthorised access, loss or misuse, and we limit access to those who need it for the purposes described in this policy.

​

​

9. Your rights

​

​

10. Automated decision-making

We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects. Client categorisation assessments are reviewed by a person.

​

​

11. Changes to this policy

We may update this policy from time to time. The date at the top of this page shows when it was last revised. Material changes will be reflected on this page.