Privacy Policy

Cornwick Ltd ("Cornwick", "we", "us", "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store and share your personal information when you visit cornwick.com or contact us directly.

We are registered with the Information Commissioner's Office (ICO) and operate in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as updated by the Data (Use and Access) Act 2025.

1. Who We Are

Data Controller: Cornwick Ltd
Registered Address: Norfolk, UK
Email: info@cornwick.com
Phone: 01603 515299

If you have any questions about how we handle your personal data, please contact us using the details above.

2. What Personal Data We Collect

Depending on how you interact with us, we may collect the following categories of personal data:

Contact and Identity Data

• Full name
• Email address
• Phone number
• Company name (where applicable)

Investor Data

• Investor self-certification status (High Net Worth Individual, Sophisticated Investor, or Restricted Investor — as required by FCA SI 2024/301)
• General investment interests and preferences shared voluntarily in correspondence

Technical and Usage Data

• IP address
• Browser type and version
• Pages visited and time spent on site
• Referring website
• Device information

Communications Data

• Records of any emails, calls or enquiries you send to us
• Appointment booking details (if you schedule a discovery call)

We do not collect any special category data (such as health, race, religion or biometric data) and we do not knowingly collect data from individuals under the age of 18.

3. How We Collect Your Data

We collect personal data in the following ways:

• Contact forms on our website when you make an enquiry
• Appointment booking via our Calendly scheduling tool
• Direct correspondence by email, phone or in person
• Cookies and analytics automatically when you browse our website (see our Cookie Policy)
• Referrals from third parties who have shared your details with your knowledge and consent

4. How We Use Your Data

We use your personal data only for the purposes for which it was collected, including:

• Responding to enquiries and booking discovery calls
• Sending information you've requested
• Sending email updates and investment communications to those who have opted in
• Verifying investor eligibility in accordance with FCA financial promotion rules
• Improving our website and understanding how visitors use it
• Complying with our legal and regulatory obligations

5. Lawful Basis for Processing

Under UK GDPR, we rely on the following lawful bases for processing your personal data:

• Consent — where you have actively opted in to receive marketing communications or agreed to our use of non-essential cookies
• Legitimate interests — to respond to enquiries, manage relationships with prospective investors, and improve our services, where these interests are not overridden by your rights
• Legal obligation — where processing is required to comply with regulatory requirements (e.g. FCA financial promotion compliance, HMRC anti-money laundering obligations)
• Contract — where processing is necessary to take steps at your request prior to entering into an agreement

6. Marketing Communications

We will only send you marketing emails and investment updates if you have explicitly opted in to receive them. You can unsubscribe at any time by clicking the unsubscribe link in any email we send, or by contacting us directly at info@cornwick.com.

We do not sell, rent or trade your personal data to third parties for marketing purposes.

7. Who We Share Your Data With

We may share your personal data with trusted third-party service providers who help us operate our business, including:

• Attio — customer relationship management (CRM) platform, where enquiries submitted through our website forms are stored, along with records of our conversations with you
• Calendly — appointment scheduling (data processed in the USA under Standard Contractual Clauses)
• Vercel / GitHub — website hosting and deployment infrastructure
• Google Analytics — website analytics (anonymised where possible)

All third-party processors are contractually required to handle your data securely and only for the purposes we specify. We do not authorise them to use your data for their own purposes.

We may also disclose your data where required by law — for example, to HMRC, the ICO, or law enforcement agencies.

8. International Data Transfers

Some of our service providers are based outside the UK. Where data is transferred outside the UK, we ensure appropriate safeguards are in place — such as Standard Contractual Clauses approved by the ICO or transfers to countries with an adequacy decision — to protect your data to the same standard as required under UK GDPR.

9. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purposes outlined in this policy:

• Enquiry data — up to 2 years from last contact, unless a business relationship develops
• Investor communication records — up to 6 years in line with financial record-keeping best practice
• Marketing opt-in records — retained for as long as you remain subscribed, plus 1 year after unsubscription
• Website analytics data — in anonymised or aggregated form only, retained for up to 26 months

When data is no longer needed, it is securely deleted or anonymised.

10. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

• Right of access — to request a copy of the data we hold about you
• Right to rectification — to request correction of inaccurate or incomplete data
• Right to erasure — to request deletion of your data in certain circumstances
• Right to restrict processing — to ask us to limit how we use your data
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests or for direct marketing
• Rights related to automated decision-making — we do not carry out automated profiling or decision-making that produces legal or similarly significant effects

To exercise any of these rights, please contact us at info@cornwick.com. We will respond within one month of receiving your request.

11. Complaints

If you believe we have not handled your personal data correctly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

We would, however, appreciate the opportunity to address your concerns directly before you contact the ICO. Please get in touch with us first.

12. Cookies

Our website uses cookies to improve your experience and help us understand how visitors use the site. For full details, please read our Cookie Policy.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our business or legal requirements. The "last updated" date at the top of this page will always show when it was most recently revised. We encourage you to review this policy periodically.

14. Contact Us