GuardCap - Guardian Capital

Long-term thinking, hallmark of our approach

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Regulatory

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Conflicts of Interest Policy

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Order Execution Policy

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MIFIDPRU 8 Disclosure

Financial Statements

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GuardCap UCITS Funds PLC – Annual Reports and Audited Financial Statements – 2025

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GuardCap Asset Management Limited – Audited Financial Statements – 2025

UK Reporting Fund Status

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GuardCap UCITS Funds PLC

Privacy and Cookies Policy

GUARDCAP ASSET MANAGEMENT LIMITED

GuardCap Asset Management Limited (the “Firm“, “we“, “us” or “our“) is committed to protecting the privacy of individuals whose data it processes (“you” or “your“).

1.         IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy aims to give you information on how the Firm collects and processes your personal data as a controller.

In addition, it outlines your data protection rights under applicable data protection laws in the UK, including the retained UK law version of the General Data Protection Regulation (“UK GDPR“), the UK Data Protection Act 2018 and other applicable UK data protection legislation.

This website is not intended for children and we do not knowingly collect data relating to children.

Due to the nature of its business, the Firm has determined that it is not required to appoint a Data Protection Officer under applicable UK data protection law. However, the Firm’s Compliance Team is responsible for overseeing the implementation of this policy and for monitoring compliance with applicable data protection requirements.

2.         CATEGORIES OF DATA SUBJECTS

(A)       CLIENTS AND INVESTORS

The following section of this policy sets out how the Firm, as controller of personal data supplied by, and collected in relation to, clients as well as shareholders and potential investors in the funds we manage (“Funds“) and other persons whose information is provided to us by or on behalf of the clients or Funds, will process such personal data.

Types of information we may hold

We may hold personal data about clients (and those working for clients) as well as investors in the Funds which is provided to us by you directly as a result of your being a client and/or holding an investment in a Fund. Information may be obtained by (i) correspondence in respect of the services we provide; and/or (ii) completing and submitting application forms for the Fund(s), and/or through our website, recorded and monitored telephone calls, collation of due diligence as a result of holding your investment and/or you corresponding with us. It also may be collated or provided to us by third parties for credit and money laundering checks and compliance purposes, such as screening. We may also process personal data about individuals that are connected with our clients and the Funds and/or you as an investor (for example directors, trustees, employees, representatives, beneficiaries, shareholders, investors, clients, beneficial owners or agents).

We may collect, store, and use some or all of the following categories of personal information about you: contact details (including name, title, address, telephone number, personal email address), your date of birth, copies of passport, driving licences and utility bills, bank account details and details relating to your investment activity and personal identifiers such as your social security number, national insurance number, tax file number and IP address.

In limited cases, we may also process special category personal data, such as information revealing political opinions, and criminal offence data, including information concerning actual or alleged criminal convictions or offences. This may arise, for example, in connection with anti-money laundering, sanctions, financial crime and fraud prevention checks. We will only process such information where permitted by applicable data protection law.

You are not obliged to provide us with your information where it is requested but we may be unable to provide certain products and services or proceed with our business relationship with you if you do not do so. Where this is the case, we will make you aware.

How we will use information about you

Your personal data may be processed by the Firm or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

  • to administer your investment in accordance with your instructions and/or in order to perform a contract we have entered into;
  • to allow us to administer and manage investments (including fee calculations and the payment of dividends and other corporate actions) which are necessary for the Firm to comply with applicable laws and/or are in its legitimate interest to allow us to provide our services to the clients and Funds we manage;
  • to update and maintain records for the Firm, including maintaining statutory registers, which is necessary to comply with the Firm’s legal obligations;
  • to carry out anti-money laundering checks and other actions in an attempt to detect, prevent, investigate and prosecute fraud and crime and verify your identity, in order to comply with the Firm’s legal obligations, for the performance of a task being carried out in the public interest and/or to pursue the Firm’s legitimate interests (including for the prevention of fraud, money laundering, sanctions, terrorist financing, bribery, corruption and tax evasion);
  • to scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems to pursue our legitimate interests including for document retention purposes; and
  • such other actions as are necessary to manage the activities and/or to comply with the legal obligations of the Firm, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and enforcing or defending the rights and/or interests of the Firm, in order to comply with the Firm’s legal obligations and/or to pursue the Firm’s legitimate interests such as use in connection with the Firm’s internal management and reporting, to administer, operate, facilitate and manage your account(s) with us and your use of our services and products, to facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements and to pursue the legitimate interests of the Firm in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions.

To the extent that such personal data contains special category data or criminal offence data, we will only process such information where the relevant requirements of applicable UK data protection law are satisfied. This may include processing necessary to comply with legal or regulatory obligations, including requirements relating to anti-money laundering, sanctions and financial crime prevention.

Some of the above grounds of processing may overlap and there may be several grounds which justify how we use your personal data.

The Firm does not anticipate being required to obtain your consent for the processing of your personal data as listed above. If the Firm wishes to use your personal data for other purposes which do require your consent, the Firm will contact you to request this.

 (B)      VISITORS TO OUR WEBSITE

The following section of this policy sets out how the Firm may process personal data (as a controller) about visitors to its website and/or individuals who contact the Firm using the contact information provided on the website.

Types of information we may hold

We may collect, use, store and transfer different kinds of personal data about you which you provide to us through our website, such as your name, address, email address, telephone numbers, technical data (including internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website).

We do not collect any special categories of personal data about you through our website.

How we collect your data

We use different methods to collect data from and about you including through direct interactions when you contact us using our contact details provided on the website, and through cookies, server logs, pixel tags and other similar technologies (which we may use to collect technical data about your equipment, browsing actions and patterns).

How we will use information about you

Your personal data may be processed by the Firm or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

  • to provide you with any information that you have requested, in order to perform a contract with you;
  • to send you updates on the performance of the Firm, newsletters, invitations to events and other marketing communications which we will do only with your consent;
  • to use data analytics to understand and improve our website, marketing and user experience, where permitted by law and, where required, with your consent to the use of relevant cookies or similar technologies;
  • to comply with legal or regulatory requirements;
  • to scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems to pursue our legitimate interests including for document retention purposes; and
  • such other actions as are necessary to manage the activities of the Firm, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and enforcing or defending the rights and/or interests of the Firm, in order to comply with its legal obligations and/or to pursue its legitimate interests.

If we consider it necessary to obtain your consent in relation to the use of your personal data (such as for sending emails to individuals that have not invested in the Firm), we will contact you to request this consent. Details of how to withdraw your consent are set out below.

Processing on the basis of legitimate interests

Where such processing is being carried out on the basis that it is necessary to pursue the Firm’s legitimate interests, such legitimate interests should not override your interests, fundamental rights and freedoms.

Links to websites

Where the website provides links to other websites, the Firm is not responsible for the data protection/privacy/cookie usage policies of such other websites, and you should check these policies on such other websites if you have any concerns about them. You should always exercise caution and review the privacy policy applicable to the website in question.

Cookies

We use cookies and similar technologies on our website to enable its operation and functionality and, with your consent where required, to understand how visitors interact with the website and for other analytics, performance or advertising purposes.

When you first visit our website, you can manage your preferences through our cookie consent tool. Cookies that are strictly necessary for the operation of the website may be used without consent where permitted by law. Other cookies and similar technologies requiring consent will only be used where you have provided that consent.

You can accept or reject non-essential cookies, select individual preferences and change your choices at any time using the cookie preferences tool available on our website.

Further information about the categories of cookies used, their purposes and, where applicable, the relevant third parties is available through the cookie preferences tool.

Further information about cookies (including how to turn them off) can be found at www.allaboutcookies.org.

3.         DISCLOSURES OF YOUR PERSONAL DATA

We may disclose personal data we hold about you:

  • to other entities within our group;
  • to providers of investment products or services, including fund administrators, registrars, printers and similar service providers;
  • to service providers and other organisations that support our business operations, including providers of IT, investment operations, trading, settlement, client reporting, administration and other professional or operational services;
  • to our professional advisers;
  • in the event that we sell or transfer any business or assets, in which case we may disclose personal data we hold about you to the prospective and actual buyer of such business or assets; and/or
  • if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party (including without limitation to any of our regulators).

4.         DATA RETENTION

We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including to comply with legal, regulatory, and accounting requirements.

The retention periods for financial data are as follows:

  • Client Records & Financial Transactions – Retained for at least 6 years from the end of the client relationship.
  • Anti-Money Laundering (AML) & Fraud Prevention Data – Retained for 5 years from the date of the last transaction or the termination of the business relationship.
  • Marketing & Communications Data – Retained until consent is withdrawn or for a maximum of 2 years of inactivity.

After the relevant retention period, we will securely delete data unless there is a legitimate reason or legal obligation to retain it for longer.

5.         INTERNATIONAL TRANSFERS

Some of the organisations with whom we share personal data may be located outside the United Kingdom or may access personal data from outside the United Kingdom. This may involve a restricted transfer of personal data under UK data protection law.

Where we make a restricted transfer, we will ensure that an appropriate transfer mechanism is in place in accordance with applicable UK data protection law. This may include reliance on UK adequacy regulations, appropriate safeguards such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or approved Binding Corporate Rules, or an applicable exception where permitted by law.

Where required, we will undertake the applicable assessment and implement any additional measures necessary to protect personal data.

Please contact us if you would like further information about the safeguards or transfer mechanisms applicable to your personal data.

6.         DATA SECURITY

The Firm has put in place appropriate technical and organisational measures designed to protect personal data against accidental or unlawful loss, alteration, disclosure or access. Access to personal data is limited to employees, agents, contractors and other third parties who have a legitimate business need to know and who are subject to appropriate confidentiality and security obligations.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required or consider it appropriate to do so.

7.         YOUR LEGAL RIGHTS

In certain circumstances, by law you have the right to:

  • request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
  • request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
  • object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
  • where applicable, request that certain personal data you have provided to us is provided to you, or transmitted to another controller, in a structured, commonly used and machine-readable format;
  • withdraw your consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw such consent at any time. Withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent or to opt out of receiving marketing communication, please contact us at UKComplianceTeam@guardiancapital.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you wish to exercise any of the rights set out above, please contact the Compliance Team at UKComplianceTeam@guardiancapital.com.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). In certain circumstances permitted by law, we may charge a reasonable fee or refuse to act on a request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

8.         CHANGES TO THIS PRIVACY NOTICE

We may update this privacy notice from time to time, and will communicate such updates through our website. We may also notify you from time to time about the processing of your data.

9.         QUERIES AND COMPLAINTS

If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please first contact your GuardCap relationship manager. If you would like to escalate any matter, you can also contact our Compliance Team at UKComplianceTeam@guardiancapital.com or write to us at 11 Charles II Street, St James’, London, SW1Y 4NS, marking your letter for the attention of the Compliance Team.

We will acknowledge receipt of a data protection complaint within 30 days and will investigate and respond without undue delay in accordance with applicable data protection requirements.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) if you consider that our processing of your personal data infringes applicable data protection law. We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance by emailing UKComplianceTeam@guardiancapital.com.

© 2026 GuardCap Asset Management Limited. All rights reserved.

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