Apse Capital LLP (“Apse Capital”) is incorporated in England and Wales. Registration Number OC313785.

Apse Capital LLP has its registered office and principal address at 21 Gloucester Place, London W1U 8HR, England, United Kingdom.

Apse Capital LLP is regulated and authorised by the Financial Conduct Authority in the United Kingdom. Firm Reference Number 441230.

Apse Capital is an independent private equity group. Our products and servics (“Services”) are available at our website www.apsecapital.com (“Website”). For the purposes of this Privacy Policy, “Apse Capital” (and “we” and “us“) shall mean Apse Capital LLP and its related affiliates and its or their partners, members, directors, officers and employees, as the context requires. Please see the “Contact Us” section below for our contact details.

This Privacy Policy explains what personal data (as defined below) we collect through the Services, how we use and share that data, and your choices concerning our data practices.

By providing us with your personal data when using the Services, you consent to the processing of your personal data as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Services.

Personal Data That We Collect

When you interact with our Website, we collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”).

Personal Data You Give Us. When you sign up for or use the Services, you voluntarily give us certain Personal Data, including your name, email address and username.

Information collected automatically. Each time you visit our site we may automatically collect the following information:

  • Technical information including the internet protocol (“IP”) address used to connect your computer to the internet, your log-in information, browser type and version, browser plug-in types and versions, time zone setting, operating system and platform; and
  • Information about your visit, including the Uniform Resource Locators (“URL”) clickstream to, through and from our site (including date and time); items you searched for; page response times; download errors, length of time spent on pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page and any phone number used to call us.

2. How We Use Data

We use the data we collect, described above:

  • To authenticate users, provide the Services and respond to your requests. For users located within the EU, this use is necessary to perform the contract with you.
  • As necessary for certain legitimate business interests, which include the following:
    • To customize the user experience.
    • To better understand how visitors interact with our Website and ensure that our Website is presented in the most effective manner for you, and as part of our efforts to keep our Website, network and information systems secure.
    • To conduct analytics to inform our marketing strategy and enable us to enhance and personalize our communications and the experience we offer to our users.
    • If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.
    • We may anonymize, de-identify and/or aggregate the information that we collect and use such anonymized, de-identified and/or aggregated data for commercial, statistical and market research purposes, including sharing it with affiliates and business partners. 
  • Marketing: We will send you updates and information about our news or upcoming events by email. Where required by law, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data or if doing so under a legitimate interest. You may opt out of receiving such emails by following the instructions contained in each promotional email we send you or by updating your user settings. In addition, if at any time you do not wish to receive future marketing communications, please contact us at dataenquiries@apsecapital.com. We will continue to contact you via email regarding the provision of our Services and to respond to your requests.

3. Sharing And Disclosure

We may share your Personal Data and other information with certain third parties in the following circumstances:

  • Service Providers: To assist us in meeting business operations needs and to perform certain services and functions your Personal Data may be shared with third-party providers of hosting, email communication and customer support services, analytics, marketing, advertising. Following our instructions, these parties may access, process or store Personal Data in the course of performing their duties for us.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of a service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction.
  • Legal Requirements: If required to do so by law, applicable regulation or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Apse Capital, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, or (iv) protect Apse Capital against legal liability.

4. Data Retention

We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so in connection with your account, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

5. Update Your Information

If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may contact us. We will address your request as required by applicable law. You are also able to update your Personal Data yourself from your user settings.

6. Your Rights. You have the following rights in relation to your Personal Data:

  • Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
  • Right to erasure: You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). If we shared your data with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
  • Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
  • Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
    • If we are relying on a legitimate interest (described under the “How We Use Data” section above) to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
    • If we are processing your Personal Data for direct marketing.
  • Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorised to hear those concerns.

Legitimate Interest. “Legitimate interests” means our interests in conducting our business, managing and delivering the best Services to you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

Changes. We will notify you of changes to the data processing activities described in this Privacy Policy by posting a prominent notice on the Website or as otherwise required by law.

7. Publicly Posted Information

This Privacy Policy shall not apply to any information you post to the public areas of the Services. This includes, but is not limited to comments on Apse Capital public forums. Comments posted to public areas may be viewed, accessed, and used by third parties subject to those parties’ privacy practices and policies.

8. Security

We take reasonable administrative and technical steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet is 100% secure. Therefore, while we strive to protect your data, we cannot guarantee its absolute security.

9. Cookies

The Website does not use cookies.

10. Changes To Our Privacy Policy

We may change this Privacy Policy at any time and when we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use the Website or providing us with information after we have posted an updated Privacy Policy or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.

11. Contact Us

If you have any questions about our Privacy Policy or our data practices, please contact us by email at dataenquiries@apsecapital.com or by post at Apse Capital LLP, 21 Gloucester Place, London W1U 8HR.

12. Personal Data Complaint Handling Procedures

Personal data complaints

The UK Data (Use and Access) Act 2025 (“DUAA”) amends, but does not replace, the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 (“DPA 2018”) and the Privacy and Electronic Communications Regulations (“PECR”).

Apse Capital LLP (“Apse Capital”) (the “Firm”) (“we”, “us”, “our”) is required (under section 103 DUAA) to take steps to enable you, the data subject, to make a complaint about how we handle your personal data.

You must first raise your complaint with us, before escalating it to the Information Commissioner’s Office (“ICO”).

We aim to deal with any personal data complaints efficiently and promptly.

We aim to rectify any mistakes that have been made to improve our service to you.

You have the right to complain to us if you think we have not handled your personal data responsibly and in line with best practice.

For example:

  • If you are unhappy with our response to a Subject Access Request (“SAR”), or other rights request;
  • If you have been impacted by a personal data breach by us;
  • If you are unhappy about the way we have used your personal data (for example, where we store your personal data, how long we have kept your personal data for, or its accuracy).

You must only use this service if you have a complaint about how we have dealt with your personal data.

Complaints about our services provided or our business will not be dealt with under these arrangements and are subject to our General Complaints procedures.

How to make a personal data complaint

You must provide us with the following individual information when making a complaint about the handling of your personal data:

  • Your name;
  • Your address where you wish to receive our response:
    • Your email address; and/or
    • Your full residential address (including your postcode).
  • Your telephone number:
    • Your landline number; and/or
    • Your mobile number.

If you work for a company and your complaint is in reference to your personal data with this entity, you must provide us with the following corporate information when making a complaint about the handling of your personal data:

  • The full legal name of the organisation.
  • The department (if known).
  • The address of the organisation where you wish to receive our response:
    • The corporate email address; and/or
    • The full corporate address (including your postcode) of the organisation.
  • Your corporate telephone number:
    • Your corporate landline number; and/or
    • Your corporate mobile number.
  • A Reference Number (if you have one – for example, the SAR Reference Number).
  • Details of the personal data issue you wish to complain about (please provide us with as much clear and simple detail as possible regarding what happened – for example, a data breach (unauthorised access or disclosure; or a SAR issue or delay; or incorrect data being held; or misuse of your personal data; or another matter to do with your personal data).
  • When did the incident or issue occur? (Please provide the exact dates, locations, or the names of our staff you dealt with, and attach any relevant documents or emails).
  • How has this affected you? (Please describe any distress, financial loss, or harm you believe was caused).
  • What is the desired outcome? (Please explain what you would like us to do to resolve this complaint – for example, delete your personal data, amend and update your personal data, provide you with a formal apology, fulfil a SAR, or another outcome).

What are the next steps?

Submit your complaint – you can make a personal data complaint to us in one of the following ways:

  • By using the complaints form – available on request
  • By email – you can email us at ashley.long@apsecapital.com.
  • In writing – please complete the Personal Data Complaints Form in Annex A to these procedures and send the Form directly to our Data Protection Officer (“DPO”) and Compliance Oversight Officer (“CO”), Ashley Long, at Apse Capital LLP, 21 Gloucester Place, London W1U 8HR, United Kingdom
  • By telephone – if you would prefer to make your personal data complaint verbally to us, you can contact us by phone on the following number: +44 (0)20 7292 9333
  • Social media – if you submit your personal data complaint any social media platforms, we will always ask you to provide us with an alternative contact method as use of social media is generally not a secure way to send personal information.

If we receive your personal data complaint electronically (for example, through email or live chat), we will either send you an automatic response (such as auto-acknowledgement email) or you will receive an electronic response from our DPO and CO.

If we receive your personal data complaint through social media, we will ask you promptly for an alternative contact method as the use of social media is generally not a secure way to send personal information.

If we receive your personal data complaint in writing (for example, by post), we will send you an acknowledgement letter to the address you have provided.

If we receive your personal data complaint verbally (for example, over the phone or face-to-face), we will acknowledge this verbally to you.

On receipt of your verbal personal data complaint, we will also summarise your personal data complaint back to you, so that you know that we have understood the issue.

We will ask you for your preferred contact method for receiving updates and obtain your contact details.

We will endeavour to provide you with your personal data complaint reference number (where applicable) and confirm that someone will be in touch to provide updates.

We follow this up in writing (even if we have acknowledged your personal data complaint verbally).

How long do I have to wait for a response?

In line with ICO Guidance, we will:

  • Acknowledge the receipt of your personal data complaint within 30 calendar days of receiving it or at the time of receiving your verbal personal data complaint.
  • Where your personal data complaint is complex, unclear and/or multiple issues have been raised, we may ask you to agree the scope of the complaint.

Please note, complex personal data complaints may take longer to investigate.

  • We will investigate your personal data complaint without undue delay.
  • We will take appropriate steps to respond to your personal data complaint, including making appropriate enquiries based on the circumstances of your personal data complaint.
  • We will keep you informed and updated on the progress of our investigation of your personal data complaint.

What if I am unhappy with the response?

The ICO is the UK supervisory authority responsible for making sure we comply with the UK GDPR and the DPA 2018.

If you are not happy with our response or do not receive a satisfactory response, or if we take longer than the 30 calendar days without a valid reason, you can escalate your complaint and complain directly to the ICO.

For more information on how to make a complaint to the ICO about how we have used your personal information, please see ICO Make a Data Protection Complaint.

The ICO will investigate your complaint further.