Privacy Policy

1. Who We Are & Scope

Harp + Partners means Harp + Partners Capital Ltd. This Privacy Policy applies to personal data collected:

• Through our website(s);
• Through direct contact, forms, or communications;
• Through business interactions (with clients, consultants, partners, or suppliers).

We are the data controller of your personal data.

2. Data Protection Principles

We adhere to key data protection principles:

1. Lawful, fair, and transparent processing
2. Purpose limitation – collected for specific, explicit, and legitimate purposes
3. Data minimisation – adequate and relevant only
4. Accuracy and up-to-date records
5. Retention only as long as necessary
6. Security of personal data

3. Types of Personal Data We Collect

“Personal Data” is information that identifies you or from which you can be identified. We may collect:

• Identity data: names, job title, business affiliation;
• Contact data: postal address, email address, phone numbers;
• Professional data: CVs, qualifications, company details;
• Technical & Usage data: IP address, device/browser information, analytics;
• Marketing/Preference data: communication preferences;
• Sensitive data (rare): identification documents, health or other sensitive categories, only where necessary and lawful.

4. How We Collect Personal Data

We collect personal data by:

1. Direct interactions: forms, email, phone, event registrations;
2. Automated technologies: cookies and analytics (see Section 11);
3. Third-party sources: publicly available data, partner referrals, consultants.

5. Legal Bases for Processing

We process personal data only where lawful, including when:

• Necessary for a contract (e.g., to provide services);
• Legal obligation (e.g., compliance with regulatory requirements);
• Legitimate interests (e.g., business operations, relationship building, analytics) where such interests are not overridden by your rights;
• Consent has been given for specific purposes (e.g., marketing).

6. How We Use Your Personal Data

We may use personal data for:

• Website operations & improvements: analytics, service optimization;
• Service delivery: fulfilling contracts and client engagements;
• Communication: responding to enquiries, invoicing, updates;
• Marketing: newsletters, events, where consent exists;
• Security: premises access, fraud detection;
• Legal compliance and risk management.

7. Sharing Personal Data

We may share personal data with:

• Service providers (IT, hosting, communications, analytics);
• Professional advisors (legal, accounting);
• Partners and group entities for operational purposes;
• Regulators and authorities where lawfully required.

All third parties are required to protect your personal data to appropriate standards and only process it for specified purposes.

8. International Transfers

Personal data may be transferred to countries outside your jurisdiction (e.g., outside the EU/UK). We ensure proper safeguards (such as standard contractual clauses or consent) are in place to protect your data.

9. Data Security & Storage

We use appropriate technical and organisational measures to protect personal data from unauthorised access, loss, or misuse. However, internet data transmission is inherently insecure; any transmission is at your own risk.

10. Data Retention

We retain personal data only as long as necessary for the purposes collected, to satisfy legal, contractual, accounting, or auditing requirements, or to defend legal claims. When data is no longer needed, it will be securely deleted or anonymised.

11. Cookies & Tracking Technologies

We use cookies and similar technologies on our websites to improve functionality and analytics. Details are set out in our separate Cookie Policy.

12. Your Rights

Subject to applicable law, you have the right to:

• Access your personal data
• Correct inaccurate data
• Request erasure or restriction of processing
• Object to processing based on legitimate interests
• Withdraw consent (where applicable)
• Request data portability

To exercise these rights, contact us using the details below. We may ask for proof of identity before acting on requests.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect legal, operational, or technological changes. The updated version will be published with a revised “Last Updated” date.

14. Contact Information

For privacy requests or questions, contact:

You may also lodge a complaint with your local data protection authority if you believe your rights have been violated.