Introduction

Klay Capital Limited ("we", "our", or "us") is regulated by the Financial Conduct Authority (FCA) in the United Kingdom with Firm Reference Number: 992341. 

We are a data controller and are committed to protecting your privacy and handling your personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other relevant UK legislation. 

We are registered with the Information Commissioner’s Office (ICO) under registration number ZB510749. 

This Privacy Statement (“Statement”) sets out how we collect, use, share, and protect personal data in the course of operating our website (https://uk.klaygroup.com/), managing client relationships, providing investment services, and carrying out our business operations. This includes information collected via our website, through communications, during in-person meetings, and as part of our service delivery.

1. Whose Data Do We Collect?
We collect and process personal data relating to:
• Professional clients and prospective clients 
• Ultimate beneficial owners (UBOs), directors, and other representatives of corporate clients
• Investment counterparties, custodians, and service providers
• Employees, job applicants, and contractors
• Website visitors and subscribers to our communications
• Visitors to our premises

2. Types of Data We Collect
Depending on your relationship with us, the data we may collect includes:
• Identification and contact information: Name, job title, employer, address, email, and telephone numbers
• Know Your Client (KYC) and Anti-Money Laundering (AML) data: Date of birth, passport or ID numbers, nationality, source of wealth, bank account details
• Professional information: Role, investment mandate, business interests
• Transaction data: Portfolio transactions, trading activity, performance data.
• Financial data: Bank account details, investment preferences, transaction histories
• Technical information (website visitors): IP address, browser type, pages visited, and cookie preferences

3. How We Collect Your Personal Data
We collect personal data through various channels, including:
• Directly from you (e.g., through meetings, correspondence, forms, and online interactions)
• From publicly available sources (e.g., Companies House, regulatory filings, LinkedIn)
• From intermediaries such as custodian banks, financial advisers, consultants, and placement agents
• From service providers assisting in compliance, onboarding, or investment execution
• Our website (through cookies, analytics)

4. Legal Bases for Processing
We process personal data under the following legal bases:
• Contractual necessity: To establish and manage client relationships and provide investment services
• Legal obligation: For regulatory compliance, including KYC, AML, and record-keeping requirements
• Legitimate interests: For marketing to professional contacts, managing operations, business development, and service improvement
• Consent: For marketing to individuals where required, and for certain uses of cookies
• Vital interest: Where necessary to protect individuals’ safety or wellbeing (in exceptional cases)

5. How We Use Your Personal Data
We may use your personal data to:
• Provide and manage discretionary or advisory investment services
• Carry out AML, KYC, and other due diligence checks
• Administer and manage our contractual relationship with you
• Meet regulatory and legal obligations
• Communicate with you regarding our services and investment opportunities
• Provide updates, market insights, and invitations to events (subject to your preferences)
• Improve our website and understand user behaviour

6 .Sharing Your Personal Data
We may share personal data with the following categories of recipients:
• Custodians, fund administrators, brokers, and other financial intermediaries
• Legal, tax, compliance, and financial advisers
• Service providers, such as IT support, cloud hosting, CRM platforms, email
• Regulatory authorities, law enforcement bodies, or courts where required
• Affiliates or group companies in the context of business operations
• Third parties involved in the acquisition, sale, or reorganisation of our business
We do not sell personal data under any circumstances.
All third parties are required to protect your data and only process it in accordance with our instructions.

7. International Transfers
We may transfer your personal data outside the UK or EEA, including to countries that may not provide the same level of data protection. In such cases, we ensure appropriate safeguards are in place (e.g. UK IDTA, EU Standard Contractual Clauses) to protect your data in accordance with applicable data protection laws.

8. Data Retention
We retain personal data only as long as necessary for the purposes for which it was collected or to meet legal, regulatory, or operational requirements. Retention periods vary depending on the type of data and the applicable laws, but generally, we retain:
• Client and transaction data: at least 7 years after the end of the business relationship
• Marketing preferences and communications: until you opt out
• Recruitment data: up to 6 months from application if unsuccessful
When your data is no longer needed, we will securely delete or anonymise it.

9. Security of Your Data
We maintain appropriate technical and organisational measures to safeguard your personal data from unauthorised access, disclosure, loss, or misuse and to ensure data integrity and availability. These include encryption, access controls, internal policies, and staff training. We regularly review and improve security practices.

10. Your Rights
Under data protection law, you have the following rights:
• To access the personal data, we hold about you
• To correct inaccurate or incomplete data
• To request erasure or restriction of processing (in some cases)
• To object to processing based on legitimate interests or direct marketing
• To data portability, where applicable
• To withdraw consent, where we rely on it
• To lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk); Helpline: 0303 123 1113
To exercise your rights, please contact us using the details below.

11. Cookies and Website Analytics
We use cookies to improve your experience on our website, analyse usage, and ensure its security. Where required, we ask for your consent before using non-essential cookies. You can manage your preferences via our cookie banner or your browser settings. Please refer to our Cookie Policy for more information about how we use cookies and how you can manage them.

12 .Contact Us
If you have any questions about this Statement or how we handle your personal data, please contact:
Klay Capital Limited
1st Floor, Berkeley Square House,Berkeley Street, United Kingdom W1J 6BD 
Email: uk.operations@klaygroup.com 
Phone: +44 (0)161 521 6660 

13. Updates to This Statement
We may update this Statement periodically. Any changes will be posted on our website with an updated effective date. Please check regularly for the most recent version.