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Appian Capital Advisory – Website Privacy Policy

This Privacy Policy sets out how Appian Capital Advisory LLP (“Appian”, “we”, “us”) collects, uses and protects personal data in connection with your use of our website at appiancapitaladvisory.com (the “Website”) and in the ordinary course of our business as an investment advisory firm authorised and regulated by the Financial Conduct Authority. This policy is issued in accordance with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018 (“DPA 2018”). Appian Capital Advisory LLP is the data controller in respect of any personal data processed pursuant to this policy.

PERSONAL DATA WE COLLECT THROUGH THE WEBSITE

This Website uses a limited number of cookies. A strictly necessary security cookie (__cf_bm) is set by our content-delivery and security provider, Cloudflare, to protect the Website against malicious traffic; this cookie is exempt from consent requirements. With your consent, we also use analytics cookies (Google Analytics and Metricool) to collect aggregated statistics on how visitors use the Website, which help us improve its performance and content. Analytics cookies are set only if you accept them via the cookie banner, and you may withdraw your consent at any time through the cookie settings on the Website. We do not use cookies or similar technologies for advertising or behavioural profiling purposes. In addition, limited technical data (such as IP addresses) may be processed by our hosting and content-delivery and security providers for security and network-integrity purposes.

The Website contains a link to our contact email address, which can be used to send investment proposals and other enquiries to us. If you choose to email us, you may provide us with personal data including your name, email address and other personal information contained in your email or any attachments. We will use the information you send only to deal with your request or to evaluate any investment proposal you submit, and we will not use it for any other purpose without your consent.

We do not sell, rent or otherwise transfer your personal data to third parties for their own marketing or commercial purposes.

PERSONAL DATA WE COLLECT IN THE COURSE OF OUR BUSINESS

In addition to personal data received through the Website, Appian collects and processes personal data in the ordinary course of its business. This includes personal data relating to: investors and prospective investors in the funds Appian advises, and their directors, officers, beneficial owners and authorised representatives; directors, officers and representatives of portfolio companies, counterparties, intermediaries, suppliers and service providers; individuals in respect of whom Appian conducts know-your-customer, anti-money laundering, sanctions or other background screening; and individuals who apply for employment or engagement with Appian.

We collect this personal data directly from the individuals concerned, from the organisations they represent, and from third-party sources including publicly available registers, sanctions and screening databases, the media and professional advisers. The categories of personal data processed typically include identity and contact details, professional information and, where required to meet our legal and regulatory obligations, identification and verification documentation, financial information and, in limited cases, information relating to criminal convictions and offences.

LEGAL BASIS FOR PROCESSING

Where we process personal data received via email, we do so on the basis of our legitimate interests (Article 6(1)(f) UK GDPR) in evaluating investment opportunities and responding to enquiries, or, where applicable, on the basis of taking steps at your request prior to entering into a contract (Article 6(1)(b) UK GDPR). We will not process your data for purposes incompatible with those for which it was collected. Where we set analytics cookies on the Website, we do so on the basis of your consent (Article 6(1)(a) UK GDPR); you may withdraw your consent at any time via the cookie settings on the Website.

We also process personal data where necessary to comply with our legal and regulatory obligations (Article 6(1)(c) UK GDPR), including under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and the rules of the Financial Conduct Authority, and where necessary for our legitimate interests in operating, managing and developing our business, provided those interests are not overridden by your interests and fundamental rights. Where we process special category personal data or personal data relating to criminal convictions and offences in connection with these obligations, we do so in accordance with Articles 9 and 10 UK GDPR and Schedule 1 to the DPA 2018.

DATA RETENTION

We will retain personal data received via email only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. Where an investment proposal is not pursued, personal data will ordinarily be deleted or anonymized within 24 months of the decision not to proceed, unless a longer retention period is required by law or regulation or is necessary to establish, exercise or defend legal claims or to manage conflicts of interest. Where personal data is processed to comply with our anti-money laundering obligations, we retain it for at least five years following the end of the relevant business relationship or the completion of the relevant transaction, in accordance with the Money Laundering Regulations 2017.

DATA SECURITY

We have put in place appropriate technical and organisational security measures to protect personal data against accidental loss, unauthorised access, use, alteration or disclosure. Access to personal data is restricted to those members of our team who have a legitimate need to process it, and all such individuals are subject to confidentiality obligations.

Where we engage third-party service providers who process personal data on our behalf (for example, IT infrastructure providers), we ensure that appropriate data processing agreements are in place in accordance with Article 28 UK GDPR.

INTERNATIONAL TRANSFERS

Appian operates internationally, with offices in London, New York, Dubai and Abu Dhabi, and personal data may be accessed by, or shared with, Appian group entities and service providers including analytics providers, located outside the UK. Where personal data is transferred outside the UK or European Economic Area, we ensure that appropriate safeguards are in place (such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or reliance on UK adequacy regulations) to protect your data to a standard equivalent to that required under UK GDPR.

DISCLOSURES OF PERSONAL DATA

We may share personal data with: other Appian group entities for the purposes described in this Privacy Policy; our professional advisers, auditors, insurers, fund administrators, banks and IT and other service providers; regulators, tax authorities, law enforcement agencies and other public bodies where we are required or permitted to do so by law (including the Financial Conduct Authority and the overseas regulators of Appian group entities); and prospective purchasers, investors or their advisers in connection with any actual or proposed reorganisation, merger or sale of all or part of our business. We require all third parties who process personal data on our behalf to respect the security of personal data and to treat it in accordance with the law.

YOUR RIGHTS

Under UK GDPR and the DPA 2018, you have the following rights in respect of your personal data:

  • The right to access the personal data we hold about you;
  • The right to rectification of inaccurate or incomplete personal data;
  • The right to erasure (right to be forgotten, Article 17 UK GDPR) in certain circumstances;
  • The right to restriction of processing in certain circumstances;
  • The right to data portability in certain circumstances;
  • The right to withdraw consent at any time, where processing is based on your consent;
  • The right to object to processing based on legitimate interests; and
  • The right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk.

To exercise any of the above rights, please contact us at: [email protected].

THIRD PARTY LINKS

This Website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

Third-party websites linked from this Website are not operated by Appian and this Privacy Policy does not apply to them.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Any updated version will be posted on this page with a revised effective date. We encourage you to review this policy periodically. This policy was last updated on 13 July 2026.

CONTACT US

If you have any questions about this Privacy Policy or our data protection practices, or if you wish to exercise any of your rights, please contact us at:

Appian Capital Advisory LLP, Attn: Chief Operating Officer and General Counsel (Data Privacy Lead) 45 Pall Mall, 5th Floor, London SW1Y 5JG Email: [email protected];  Telephone: +44 (0) 207 004 0951.

You also have the right to make a complaint at any time to the ICO (ico.org.uk). We would, however, appreciate the opportunity to address your concerns before you approach the ICO, and ask that you contact us in the first instance.

 

Page last updated: 13 July 2026