Disclaimers & Privacy Notice

Who We Are

We are Somerston Capital Limited, a UK company with registration no. 04477364 and our registered office at 5th Floor 86 Jermyn Street, London, England, SW1Y 6JD (“Somerston” “we”, “our”, “us”). Our parent company is Somerston Group Limited, which is located at 45 Esplanade, St. Helier, Jersey JE2 3QB. The following legal notices relate to your use of www.somerstoncapital.com (our “Website”, “Site”)

Legal notice

Please read the following information carefully. By accessing this Website, you agree to be bound by the following terms and conditions:

No offer: This Website is available for information purposes only. Nothing on this Website is intended to constitute an offer or solicitation to invest or sell of any nature in any jurisdiction, or to recommend any investment or transaction. Nothing contained in or presented on this Website forms part of any contract.

No reliance: The content of this Website is provided for information purposes only. No reliance may be placed for any purpose whatsoever on the completeness, accuracy or fairness of the information or opinions contained on this Website. Nothing contained in, or presented on, this Website constitutes or shall be construed to constitute investment, legal, tax or other advice or any commitment or recommendation of any kind, nor is it to be relied upon in relation to making an investment or any other decision or as forming the basis of (or any part of) any such decision. The information contained in or presented on this Website may be changed, varied or updated at any time without notice.

No warranty and limitations of liability: No undertaking, representation, warranty or other assurance, express or implied, is made or given by or on behalf of us, our parent company or any of its affiliates, directors, officers or employees or any other person as to the accuracy, completeness or fairness of the information or opinions contained in or presented on this Website. We will not accept any liability whatsoever (save in the case of fraud) and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential loss or damage) from your use of this Website, including any loss, damage or expense arising from, but not limited to, any defect, error, viruses, imperfection, fault, omission, mistake or inaccuracy on this Website, its contents or associated services, or due to any unavailability of the Website or any part thereof or any contents or associated services.

Copyright: The content of this site is the property of Somerston and is protected by the laws of copyright with all rights reserved where applicable. You may download or print out hard copies of individual pages and/or sections of the Website provided that you do not remove any copyright or other proprietary notices. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use the Website for any public or commercial purpose without the prior written consent of Somerston.

Privacy Notice

This Privacy Notice gives you information about how Somerston collect, use and disclose your personal data, and your rights in relation to the personal data it holds.

Controller

Somerston is the controller and responsible for your personal data.
We are subject to the UK GDPR and Data Protection Act 2018 (the “Data Protection Legislation”).
References to “you” include all individuals whose personal information we collect, hold and process in the course of operating our businesses and our Website.

Contact Details

If you have any questions about this privacy notice or about the use of your personal data, including any requests to exercise your legal rights, please email us at dataprotection@somerston.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

Your Legal Rights

Under the Data Protection Legislation you have the following rights:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To require that we cease processing your personal data if the processing is causing you damage or distress;
  • To require us not to send you marketing communications;
  • To ask us to erase your personal data if it is no longer necessary in relation to the purposes for which we collected it.;
    • To require us to restrict our data processing activities;
    • To receive from us the personal data we hold about you which you have provided to us, in a structured, commonly-used electronic format specified by you, including for the purpose of you transmitting that personal data to a third party;
    • To require us to correct the personal data we hold about you if it is incorrect; and
    • Where we process your personal data with your consent, to withdraw your consent at any time.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

You can find out more about your rights at https://ico.org.uk/your-data-matters/.
If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact us using the details under ‘Contact Details’ above.

How we collect your data

We collect your personal data in a number of ways, for example:

  • From the information you provide to us when you meet us;
  • From information about you provided to us by your company or an intermediary;
  • When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor record and store any such communication;
  • When you complete (or we complete on your behalf) client on-boarding or application or other forms;
  • From your agents, advisers, intermediaries, and custodians of your assets;
  • From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.
  • From automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns using cookies, server logs and similar technologies. Please see our cookie policy below for further details.

The categories of personal data we collect

Personal data means any information about an individual from which that person can be identified.

  • We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  • Your name and contact details, including your home or business address, email address, telephone number and/or IP address;
  • Biographical information to verify your identity, such as your date of birth, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality;
  • We may collect your IP (Internet Protocol) address to help diagnose technical issues and administer our Site. Your IP address may also be used to identify you during a session and to gather general demographic data;
  • Information relating to your financial circumstances, including income, assets, liabilities, sources of wealth and bank account details;
  • Information about your knowledge and experience in investment matters;
  • Information about your goals and objectives in relation to our services;
  • Basic information about your employment, education or personal circumstances, where relevant; and
  • Information to help us carry out required background checks

We may hold personal data about you in one, several or all of the above categories.

We will only collect and process special category data (such as information about racial or ethnic origin, political opinions, religious beliefs, health or criminal records) where we are permitted or required to do so

  • Under applicable laws (for example for the purposes of our anti-money laundering checks);
  • In connection with legal claims or court proceedings, or for the purpose of obtaining legal advice or otherwise establishing or defending legal rights; or
  • Because it is necessary to protect your vital interests, or the vital interests of a third party, and you are unable to give consent or we cannot reasonably obtain your consent.

The basis for processing your personal data (other than with your consent), how we use that personal data and whom we share it with –

(i) Performance of a contract with you

We process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract with you.

In this respect, we use your personal data for the following activities:

  • To prepare a proposal for you regarding the services we offer;
  • To provide you with the services as set out in a Client agreement with you or as otherwise agreed with you from time to time;
  • To deal with any complaints or feedback you may have;
  • For any other purpose for which you provide us with your personal data.

In this respect, we may share your personal data with or transfer it to the following:

  • Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
  • Other corporate entities in the same corporate group to the entity in which you hold office, and where that entity is the one we have a contractual arrangement with;
  • Third parties whom we engage to assist in delivering the services to you;
  • Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
  • Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you; and
  • Our data storage providers.

(ii) Legitimate interests

We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person. In each case, we will only process your personal data as long as your interests do not override our own. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

In this respect, we use your personal data for the following:

  • Marketing to you. In this respect, see the separate section on Marketing below;
  • Training our staff or monitoring their performance;
  • Furthering our business interests;
  • Seeking advice on our rights and obligations, such as where we require our own legal advice;
  • In this respect we will share your personal data with the following:
  • Our advisers or agents where it is necessary for us to obtain their advice or assistance; and
  • With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.
    (iii) Legal obligations
    We also process your personal data for our compliance with a legal obligation which we are under.
    In this respect, we will use your personal data for the following:
  • To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws; and
  • As required by tax authorities or any competent court or legal authority.
    In this respect, we will share your personal data with the following:
  • Our advisers where it is necessary for us to obtain their advice or assistance;
  • Our auditors where it is necessary as part of their auditing functions;
  • With third parties who assist us in conducting background checks; and
  • With relevant regulators or law enforcement agencies where we are required to do so.

Marketing

We will send you information about our activities, such as newsletters, factsheets and invitations to attend investment events, but only if you give consent. We may communicate with you in a number of ways including by post, telephone, email, SMS or other digital channels.

Opting out of marketing

  • You can ask us to stop sending you marketing communications at any time by contacting us at dataprotection@somerston.com or by following the opt-out links within any marketing communication sent to you.
  • If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes (for example relating to your account, service confirmations, important updates to our terms and conditions, or regulatory communications).

Social Networking

The views and opinions of our Directors and employees, as published on social networking websites such as, but not limited to LinkedIn, Twitter and Facebook, do not necessarily reflect our own. Social networking website posts are not intended as legal or financial advice and should not be relied on as such.

Reference to any specific commercial products, processes, or services by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement or recommendation by Somerston, nor shall any information or statements contained on social networking websites be used for the purposes of advertising, or to imply an endorsement or recommendation.

With respect to any documents available from social networking websites, neither Somerston nor any of its employees make any warranty, express or implied, including but not limited to the warranties of merchantability and fitness for a particular purpose. Further, neither Somerston nor any of its employees assume any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product or process disclosed; nor do they represent that its use would not infringe privately owned rights.

Transfer and processing of your personal data outside the United Kingdom

When sharing your personal data with third parties as set out in this Privacy Notice, it may be transferred outside the UK. In these circumstances, your personal data will only be transferred on one of the following bases:

  • The country that we send the personal data to is approved by the UK Government as providing an adequate level of protection for personal data;
  • The recipient has entered into UK approved International Data Transfer Agreements (IDTA) or International Data Transfer Addendum to the European Commission standard contractual clauses with us;
  • The recipient is a corporate body in the Somerston Group, and there are binding corporate rules or intra group agreements in place providing appropriate safeguards; or
  • You have explicitly consented to the same.

To find out more about transfers by us of your personal data outside the United Kingdom and the countries concerned please contact us using the details under ‘Contact Details’ above..

Retention of your data

We will only retain your personal data for as long as we have a lawful reason to do so. In particular:

  • Where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that personal data for at least ten years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings; or
  • Otherwise, we will in most cases retain your personal data for a period of six years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.

Cookies

Cookies contain information that is transferred to your computer. Some of the Cookies we use are essential for the web-site to operate. Some Cookies allow us to recognise and count the number of visitors and to see how visitors move around the site when they’re using it. This helps us to improve the way our website works and deliver a better and more personalised service, for example, by making sure users are finding what they need easily. We may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer.

You may choose to block Cookies by clicking on the relevant button on the Cookie banner.

We use the following Cookies:

Cookie Title
Purpose
Lawful Basis

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Analytics & User Identification: Assigns a persistent, pseudonymized identifier to distinguish unique visitors. Used to generate aggregated statistical data on website usage and marketing effectiveness without identifying individuals.
Legitimate Interest

_gid

Session Behavior Mapping: Distinguishes users on a short-term basis (24 hours) to understand user journey flows and page-level engagement within a single visit.
Legitimate Interest

_gat

Technical Traffic Management: A performance cookie used to throttle the request rate and limit data collection on high-traffic pages to maintain site stability.
Strictly Necessary

For further information please see Google Analytics https://bit.ly/1dm9wka.

Your acceptance of this policy

    • We keep our privacy notice under regular review. This version was last updated on 3rd February 2026
    • It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example if you change your address or email address.
  • We may notify you of changes to this privacy notice by email or through a notice on our website. Where appropriate, we will notify you of significant changes and may seek your consent where required by law.

Your continued use of our website following the posting of changes to this privacy notice means you accept these changes.