Saratoga Capital Partners Limited – Privacy Policy
Purpose and Regulatory Framework
This policy outlines how Saratoga Capital Partners Limited collects, processes, stores, and protects personal data in compliance with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and applicable national data protection legislation.
We are committed to upholding the highest standards of privacy, confidentiality, and data security, and to ensuring that personal data is processed lawfully, fairly, and transparently. This policy applies to all personal data collected in the context of our investment, advisory, employment, and operational activities.
Scope of Data Processing
Saratoga Capital collects and processes personal data from a broad range of individuals in the course of its business, including:
- Professional investors within the European Economic Area (EEA) and beyond.
- Individuals associated with investors, including beneficial owners, legal representatives, and authorised signatories.
- Personnel of corporate clients or counterparties considering investment opportunities or partnerships.
- Current and prospective employees, job applicants, and former staff.
- Service providers, advisers, and other professional associates.
The collection and processing of personal data is limited to what is necessary for legitimate business purposes, compliance obligations, or to facilitate the provision of our services.
Categories of Personal Data
The types of personal data we process may include, without limitation:
- Personal identifiers such as name, date and place of birth, residential address, email, telephone number, identification documents (e.g., passports, ID cards), and signatures.
- Due diligence, Know Your Customer (KYC), and anti-money laundering documentation.
- Professional and employment information, including academic qualifications, work history, and relevant experience.
- Financial information, including banking and payment details, transaction history, and investment records.
- Correspondence and communications with the firm, whether electronic, written, or verbal.
Principles of Data Processing
Saratoga Capital is committed to processing personal data in accordance with the core principles of GDPR. This includes ensuring that data is:
- Processed lawfully, fairly, and in a transparent manner.
- Collected for specific, explicit, and legitimate purposes.
- Adequate, relevant, and limited to what is necessary.
- Accurate and kept up-to-date.
- Retained only for as long as necessary for the purposes for which it is processed.
- Protected by appropriate technical and organisational security measures against unauthorised or unlawful processing, accidental loss, destruction, or damage.
Data Subject Rights
Individuals whose personal data is processed by Saratoga Capital are entitled to exercise their rights under GDPR, including:
- The right to access personal data we hold.
- The right to request rectification of inaccurate or incomplete data.
- The right to request erasure of personal data where permitted.
- The right to restrict or object to certain processing activities.
- The right to data portability where applicable.
- The right to lodge a complaint with a supervisory authority.
Requests regarding the exercise of these rights, or any questions about our data processing practices, may be directed to info@saratoga-capital.com. We are committed to responding promptly, transparently, and in accordance with applicable regulatory timelines.
Data Security and Confidentiality
Saratoga Capital implements robust organisational, administrative, and technical measures to safeguard personal data against unauthorised access, misuse, loss, or disclosure. Access to personal data is restricted to employees, contractors, and service providers who require it to perform their professional duties, and who are bound by confidentiality obligations.
Retention and Disposal of Personal Data
Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, or enforce contractual rights. When personal data is no longer required, it is securely deleted or anonymised in accordance with industry best practices and regulatory requirements.
International Transfers of Data
Where personal data is transferred outside the EEA, Saratoga Capital ensures that appropriate safeguards are in place, including contractual protections and adherence to recognised legal mechanisms, to maintain compliance with GDPR.
Pre-Contractual and Operational Disclosures
Offering documents, agreements, and pre-contractual materials may include details on how personal data is processed in relation to investment services, client onboarding, and compliance requirements. Any processing deemed irrelevant will be clearly explained to ensure transparency.
Review and Updates
Saratoga Capital regularly reviews and updates its privacy practices to reflect changes in regulatory requirements, business operations, and industry best practice. This policy will be revised as necessary to ensure ongoing compliance and transparency.
Contact Information
For questions, concerns, or requests relating to this privacy policy or our data processing practices, please contact:
Saratoga Capital Partners Limited
Email: info@saratoga-capital.com
Last Updated: 1 January 2026.