Privacy Policy

This Privacy Policy explains how Bluewater Capital Limited and Bluewater Trustees Limited (together referred to in this policy as “we”, “our”, “us” or “Bluewater”) collect, use and protect personal information about individuals who visit our website, engage with us as clients or prospective clients, or are connected to transactions in which we are engaged by a client.

We are committed to protecting the privacy and security of your personal information and to complying with our obligations under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are

Bluewater Capital Limited and Bluewater Trustees Limited are two separate legal entities which operate from the same registered office. For the purposes of this Privacy Policy, each entity acts as an independent data controller in respect of the personal information it collects and processes in the course of its own activities.

Where this policy refers to “we” or “Bluewater”, it applies to both entities except where the context makes clear that a reference is to one entity only.

If you have any questions about this Privacy Policy or about how we handle your personal information, please contact:

Data Protection Contact: Henry Porter
Email: info@bluewatercapital.co.uk
Post: Quadrant Court, 49 Calthorpe Road, Edgbaston, Birmingham, B15 1TH

2. Personal Information We Collect

2.1 Website Visitors

When you visit our website, we may collect:

• Your IP address and device information, recorded in our hosting provider's standard server logs. We also use Plausible Analytics, a privacy-friendly, cookieless tool that collects only aggregate, anonymous usage statistics and sets no cookies or personal data. Please see our Cookie Policy for further details.
• Information you provide if you complete a contact form, send us an email, or reach out through our social media channels — including your name, email address, telephone number and the content of your message.
• Publicly available information if you contact us through a social media platform.

2.2 Clients and Prospective Clients

When you engage with us as a client, or in the course of pre-contractual discussions, we may collect:

• Name, job title, business address, telephone number and email address.
• Date of birth and proof of identity and address (for KYC and AML compliance purposes).
• Financial information, including bank details, where relevant to the services being provided.
• Information obtained from third-party due diligence sources, including adverse media checks, sanctions screening, Disclosure and Barring Service (DBS) checks where applicable, and anti-money laundering and counter-terrorism financing checks.
• Information about company officers, directors and beneficial owners of client organisations obtained in the course of our due diligence processes.

2.3 Third Parties Connected to Transactions

Where we are engaged by a client in connection with a transaction and you are a third party connected to that transaction, such as a lender, investor or other party with an interest in the relevant structure, we may collect:

• Name, contact details, date of birth and proof of identity and address.
• Financial information, including bank details and relevant amounts, for the purpose of administering our engagement and making any payments or distributions.
• KYC and AML information as required by applicable law and the terms of our engagement.

2.4 Marketing Contacts

If you have asked to receive information about our services, publications or market commentary, we will hold your name and contact details for that purpose.

3. How and Why We Use Your Personal Information

3.1 Website Enquiries

We use the information you provide through our website contact form or by email to respond to your enquiry and provide you with the information you have requested.

Our lawful basis for this processing is our legitimate interests: it is necessary for us to use your contact details in order to respond to an enquiry you have chosen to send to us, and that use is within your reasonable expectations.

3.2 Cookies and Website Analytics

We use essential and, where you have given your consent, non-essential cookies on our website. Our lawful basis for placing non-essential cookies is your consent. You may withdraw your consent at any time by adjusting your cookie preferences. Please see our Cookie Policy for full details of the cookies we use and how to manage them.

3.3 Client and Prospective Client Onboarding

We use personal information collected during the onboarding process to:

• Negotiate and conclude contracts for our services.
• Carry out KYC, AML, sanctions, adverse media, anti-bribery and fraud checks as required by law and our own compliance framework.
• Comply with our obligations under the Proceeds of Crime Act 2002, the Terrorism Act 2000, the UK Bribery Act 2010, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and other applicable legislation.

Our lawful bases for this processing are: (a) legitimate interests, for onboarding and pre-contractual activity; and (b) compliance with a legal obligation, for AML, KYC, sanctions and related checks.

3.4 Providing Our Services

Once a client or transaction is onboarded, we use personal information to:

• Fulfil our contractual obligations to our client.
• Manage and administer the ongoing relationship, including communications with key stakeholders.
• Take any steps required in connection with our engagement, including enforcement activity, distributions or other actions as directed by our client.
• Correspond with third parties connected to a transaction in connection with events affecting their interests, where required or permitted by the terms of our engagement.

Our lawful basis for this processing is the performance of a contract, or our legitimate interests where we are acting in a capacity that does not give rise to a direct contractual relationship with the individual concerned.

3.5 Marketing

Where you have agreed that we may send you marketing, or where you are an existing client contact and we are marketing the same or similar services, we will use your contact details to send you information about our services, publications and market commentary.

Our lawful bases for marketing are: (a) your consent, where you are not an existing client; or (b) our legitimate interests, where you are an existing client contact. You may unsubscribe at any time by contacting us at info@bluewatercapital.co.uk or by using the unsubscribe link in any marketing email.

4. How Long We Keep Your Personal Information

We will not keep your personal information for longer than is necessary for the purposes described in this policy. In practice:

• Client and third-party contact information is retained for five years following the end of our relationship.
• Prospective client information where no engagement results is retained for twelve months.
• Records held to satisfy AML, KYC and other regulatory due diligence obligations are retained for five years from the end of the relevant relationship, in accordance with the Money Laundering Regulations 2017.
• Personal information held in or evidenced by a deed is retained for twelve years from the end of the relevant relationship.

If a dispute arises, we may retain your personal information for longer as necessary to respond to and resolve that dispute. When we no longer need your personal information, we will securely delete or anonymise it.

5. Who We Share Your Personal Information With

We will only share your personal information where there is a lawful basis to do so. We may share it with:

• Regulatory and law enforcement bodies, including the FCA, HMRC, the National Crime Agency and other relevant authorities, where we are required to do so by law or in connection with our AML, sanctions obligations.
• Third-party KYC, AML and due diligence providers who carry out checks on our behalf.
• IT systems and hosting providers who support our operations and who process personal information only on our instructions and subject to confidentiality obligations.
• Professional advisers, including lawyers and accountants, where necessary to obtain advice or to enforce our agreements.
• A purchaser or successor entity in the event of a sale or merger of our business, on the basis of our legitimate interests in completing that transaction.

We do not sell personal information to third parties.

6. International Transfers

We currently store and process all personal information within the United Kingdom. If this changes we will update this policy and put in place appropriate safeguards as required by UK data protection law before any transfer takes place.

7. How We Keep Your Personal Information Secure

We maintain appropriate technical and organisational security measures to protect your personal information against accidental loss, unauthorised access, disclosure, alteration or destruction. Access to personal information is restricted to those who have a legitimate business need for it, and those individuals are subject to duties of confidentiality.

We have procedures in place to respond to any suspected personal data breach and will notify you and the Information Commissioner’s Office (ICO) where we are legally required to do so.

8. Automated Decision-Making

We do not make decisions about you based solely on automated processing. All material decisions in our business involve human review.

9. Your Rights

Under UK data protection law, you have the following rights in respect of your personal information:

• Right of access: to ask us what personal information we hold about you and to receive a copy of it.
• Right to rectification: to ask us to correct any inaccuracies in your personal information.
• Right to erasure: to ask us to delete your personal information in certain circumstances.
• Right to restriction: to ask us to restrict the way we use your personal information in certain circumstances.
• Right to data portability: to ask us to provide your personal information in a structured, machine-readable format, or to transfer it to another controller, where processing is based on consent or contract and is carried out by automated means.
• Right to object: to object to processing based on our legitimate interests, and to object to direct marketing at any time.
• Right to withdraw consent: where processing is based on your consent, to withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us at info@bluewatercapital.co.uk or by post at Quadrant Court, 49 Calthorpe Road, Edgbaston, Birmingham, B15 1TH.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at any time. We would welcome the opportunity to address your concerns directly before you contact the ICO. The ICO can be contacted at www.ico.org.uk or by telephone on 0303 123 1113.

10. Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and we recommend that you read their privacy policies before providing any personal information to them.

11. Changes to This Privacy Policy

We keep this Privacy Policy under regular review. Any updates will be posted on this page with a revised “Last updated” date. Where changes are material and affect the way we use your personal information, we will notify you by email where we hold your email address.

This Privacy Policy was last updated in May 2026.

12. Contact Us

If you have any questions about this Privacy Policy or the way we handle your personal information, please contact:

Data Protection Contact: Henry Porter
Email: info@bluewatercapital.co.uk
Post: Quadrant Court, 49 Calthorpe Road, Edgbaston, Birmingham, B15 1TH