01 — Who we are

Colebrooke Partners IM Limited is a UK-based investment management firm (“Colebrooke Partners”, “we”, “us”, or “our”). We are committed to protecting the personal information of our clients, prospective clients, investors, website visitors, and other individuals we interact with in the course of our business.

Colebrooke Partners IM Limited is an appointed representative of Eschler Asset Management LLP, which is authorised and regulated by the Financial Conduct Authority (FCA). As an appointed representative, Colebrooke Partners IM Limited carries on regulated activities under the FCA authorisation of Eschler Asset Management LLP, which accepts responsibility for the conduct of Colebrooke Partners IM Limited in carrying on those regulated activities.

Regulatory status: Appointed Representative of Eschler Asset Management LLP. Principal firm: Eschler Asset Management LLP, authorised and regulated by the Financial Conduct Authority (fca.org.uk). Regulator: Financial Conduct Authority. Data protection framework: UK GDPR and the Data Protection Act 2018.

This Privacy Policy explains how we collect, use, store, and share personal data obtained through this website, and describes the rights available to you under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Colebrooke Partners IM Limited acts as data controller in respect of personal data collected through this website.

02 — Information we collect

Through this website, we only collect the information you voluntarily provide and technical data generated by your visit. We may collect and process the following categories of personal data via our website:

• First name — provided when you complete a contact or enquiry form.
• Email address — provided when you submit a form, sign up for updates, or make an enquiry.
• Technical / cookie data — information automatically collected when you browse our website, including IP address, browser type and version, device identifiers, operating system, pages visited, and session duration. See Section 10 for full details on our use of cookies.

We do not ask for, or collect through this website, any financial data, identity documents, tax information, or other sensitive personal information. Such information, where required for an investment or client relationship, is collected through separate, dedicated onboarding processes.

03 — How we use your information

We use the personal data collected through this website for the following purposes:

• Responding to enquiries and communications submitted via our website forms.
• Sending market commentary, investment updates, or firm news where you have requested or consented to receive these.
• Operating, maintaining, and improving the performance and security of our website.
• Analysing how visitors use our website in order to improve content and user experience.
• Complying with applicable legal and regulatory obligations, including those arising from our status as an appointed representative of Eschler Asset Management LLP and the FCA’s regulatory framework.

04 — Legal basis for processing

Under the UK GDPR, we rely on the following legal bases for processing personal data collected through this website:

• Consent (Article 6(1)(a) UK GDPR) — where you have voluntarily provided your first name and email address, or where you have accepted non-essential cookies. You may withdraw consent at any time by contacting us or adjusting your cookie settings.
• Legitimate interests (Article 6(1)(f) UK GDPR) — for website analytics, security monitoring, and improving our online services, where those interests are not overridden by your data protection rights.
• Legal obligation (Article 6(1)(c) UK GDPR) — where processing is necessary to comply with applicable laws or FCA regulatory requirements.

05 — Sharing your information

We may share your personal data with:

• Eschler Asset Management LLP — our principal firm under the FCA appointed representative arrangement, where sharing is required for regulatory oversight, compliance monitoring, or the performance of regulated activities.
• Technology and service providers — IT, data hosting, cybersecurity, email delivery, and website analytics providers who process data on our behalf under appropriate contractual safeguards, including UK GDPR-compliant data processing agreements.
• Regulatory and government authorities — including the FCA, the ICO, HMRC, and other public bodies where required or permitted by law.

We do not sell personal data to third parties. We do not share your personal data with advertising agencies or use it for third-party advertising purposes.

06 — International transfers

Our primary operations are based in the United Kingdom and personal data collected through this website is processed in accordance with UK GDPR. Some of our third-party service providers are based outside the UK. Where we transfer personal data to recipients outside the UK, we ensure that appropriate safeguards are in place, including:

• Transfers to countries covered by UK adequacy regulations.
• UK International Data Transfer Agreements (IDTAs) or the UK Addendum to EU Standard Contractual Clauses where no adequacy decision applies.

07 — Data retention

We retain personal data collected through this website for as long as necessary to fulfil the purposes described in this Policy:

• Contact enquiry data (first name and email) is retained for up to 24 months from the date of last contact, unless a longer period is required by law or you have an ongoing relationship with us.
• Cookie and technical data is retained in accordance with the specific cookie lifespans set out in our cookie consent settings, typically ranging from session-length to 13 months.

You may request deletion of your data at any time by contacting us using the details in Section 12.

08 — Your rights

Under the UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal data:

• Access (Article 15) — to request a copy of the personal data we hold about you.
• Rectification (Article 16) — to request correction of inaccurate or incomplete data.
• Erasure (Article 17) — to request deletion of your personal data in certain circumstances.
• Restriction (Article 18) — to request that we restrict the processing of your data in certain circumstances.
• Portability (Article 20) — to receive your data in a structured, machine-readable format.
• Objection (Article 21) — to object to processing based on legitimate interests or for direct marketing.
• Withdraw consent — at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us using the details in Section 12. We will respond within one calendar month as required by UK GDPR and may need to verify your identity before processing your request.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) — the UK’s supervisory authority for data protection. You can contact the ICO at ico.org.uk or by calling 0303 123 1113.

09 — Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, or disclosure, in accordance with our obligations under UK GDPR. These measures include encryption in transit and access controls.

Although we take all reasonable precautions, no system is entirely secure. If you have reason to believe your interaction with us is no longer secure, please notify us immediately.

10 — Cookies

Our website uses cookies and similar tracking technologies in accordance with the UK Privacy and Electronic Communications Regulations (PECR) and UK GDPR. We use:

• Strictly necessary cookies — essential for the website to function correctly. These cannot be disabled.
• Analytics cookies — to understand how visitors interact with our site. These are only set with your consent.
• Preference cookies — to remember your settings and choices. These are only set with your consent.

We do not use advertising or tracking cookies for third-party marketing purposes. You can manage your cookie preferences via our cookie consent banner or by adjusting your browser settings.

11 — Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal and regulatory requirements. We encourage you to review this Policy periodically if required.

12 — Contact us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to report a privacy concern, please contact us:

Firm: Colebrooke Partners IM Limited
Email: jp@colebrookepartners.com
Registered address: 2 Kensington Place, London, England, N10 3BY

If you are not satisfied with our response, you may lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.

This policy governs personal data collected through the Colebrooke Partners IM Limited website only. Colebrooke Partners IM Limited is an appointed representative of Eschler Asset Management LLP, which is authorised and regulated by the Financial Conduct Authority. Clients and investors who engage with us directly are subject to supplemental privacy notices provided at the time of onboarding. This document does not constitute legal advice.