Privacy Policy

Ruffena Capital Limited Privacy Policy

Ruffena Capital Ltd is a private limited company registered in England and Wales with company number 08474248 and whose registered office is 3 Manor Farm Cottages, Dummer, Basingstoke, Hampshire, England, RG25 2EU. Ruffena Capital Ltd is an Appointed Representative of Ashberg Limited a company authorised and regulated by the Financial Conduct Authority and provides all regulatory functions on behalf of Ruffena.

Scope and purpose

This Privacy Notice applies to Ruffena Capital Limited and its respective affiliated and related entities and and related websites (the “Website”) (together “Ruffena”, “we”, “us”, “our”). It explains how Ruffena collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with us.

Ruffena provides investment intermediary or other services to a number of companies and funds and to the extent that Personal Data is provided to these companies and funds and not Ruffena, separate privacy notices will apply. Should you have any questions about this Privacy Notice you can contact us at the address of Portman House, 2 Portman Street, London W1H 6DU or by telephone on +44 3333 441 066 or by email at

We may provide supplemental privacy notices on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. Those supplemental notices should be read together with this Privacy Notice.

Personal Data

The term “Personal Data” as used in this Privacy Notice means any information which relates to a living individual who can be identified from that data such as name, contact details, bank account details etc. Personal Data does not include data from which you can no longer be identified such as anonymised aggregate data.

The kinds of Personal Data we may collect include your contact details (such as your address, email address and telephone number) and information such as your job title which we will request from you. In addition, we collect the Personal Data you choose to provide to us, e.g. if you contact us by letter, telephone, email or any other means of electronic or personal communication including through the Website. The Website uses cookies to distinguish you from other users of our sites. This helps us to give you the best possible experience when you browse our sites, and also allows us to improve the design, layout and function aspects of our sites. By continuing to browse our sites, you’re agreeing to our use of cookies. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy.

We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so.

We will therefore process your Personal Data only:

  • if you have consented to us doing so;
  • if we need it to perform the contract we have entered into with you;
  • if we need it to comply with a legal obligation; or
  • if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests will be the provision of services by us, or administrative or operational processes within Ruffena, and direct marketing.

We will use your Personal Data to deliver our services to you or the company/business you work or act for. We may also use your Personal Data to inform you about our services and our marketing and events.

Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

Accuracy of information

It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.

Security of information

We implement appropriate technical and organisational measures in order to protect your Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and measures adopted to protect your Personal Data are appropriate for the risks presented by the nature and use of your Personal Data. We follow recognised industry practices for protecting our IT environment and physical facilities.

What if you do not provide the personal data we request?

It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to accept an engagement from you, to provide all or some of our services, to enter into a contract with you or to send you requested marketing or other information.

Change of purpose, anonymisation

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

With whom will we share your information?

When using your Personal Data for the purposes and on the legal basis described above we may share your Personal Data with services providers we work with. We may also have to share your Personal Data with regulators, public institutions, courts or other third parties.

For the purposes described above we may have to transfer your Personal Data from the UK to a jurisdiction not not being subject to an adequacy decision of the UK courts. We will always ensure that there is a legal basis and a relevant safeguard method for such data transfer so that your Personal Data is treated in a manner that is consistent with, and respects the EU laws and other applicable laws and regulations on data protection.

Your rights in relation to your information

You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

  • request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing
  • request rectification of your Personal Data
  • request the erasure of your Personal Data
  • request the restriction of processing of your Personal Data
  • object to the processing of your Personal Data

If you want to exercise one of these rights please contact us at

Right to withdraw consent

In case you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. To withdraw your consent, please contact Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. In case we processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such marketing purposes.

How long will we retain your information?

We will cease to process your Personal Data either on your request or when we deem that we are no longer in contact with you.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

After we cease to process your Personal Data, we will securely destroy it in accordance with applicable laws and regulations.


You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Notice. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will make an updated copy of such privacy notice available on the Website.

Further information

If you have any concerns or require any further information, you can contact us at the address above, by telephone on +44 3333 441 066 or by email at