1. Who we are and scope
Culross Global Management Limited (“Culross”, “we”, “us” or “our”) is a company incorporated in England and Wales under company number 02736036, with registered office at 8–10 Hill Street, London, England, W1J 5NG. This Privacy Policy explains how we process personal data obtained through this website, email, telephone and other business communications.
For UK data protection purposes, Culross Global Management Limited acts as a controller where it determines why and how personal data is processed. In specific investment, administration or group arrangements, another entity may act as controller or joint controller; the relevant engagement documentation will identify that entity.
2. Personal information we may collect
Depending on the nature of your relationship with us, we may process:
- identity and contact information, including name, title, postal address, email address and telephone number;
- professional information such as employer, role, adviser, trustee or representative details;
- information needed to assess client classification, eligibility or suitability where applicable;
- identification, address verification, source-of-funds, tax and anti-money laundering information where required by law or regulation;
- account, portfolio or service information provided in connection with an engagement;
- correspondence, enquiries, complaints and records of our communications;
- technical information such as browser type, device information, security logs and IP address where captured by our hosting or security provider.
This static website does not intentionally collect special-category data through public forms. Please do not send sensitive documents to the general administrative mailbox unless specifically requested through an appropriate secure process.
3. Lawful bases for processing
We process personal data where one or more lawful bases apply, including performance of a contract or steps at your request before entering one, compliance with legal and regulatory obligations, our legitimate interests in operating and protecting the business, and consent where consent is the appropriate basis.
4. How we use personal information
- to respond to enquiries and communicate with investors, counterparties, advisers and service providers;
- to assess and administer professional relationships and provide agreed services;
- to comply with anti-money laundering, sanctions, fraud prevention, tax, record-keeping and other legal or regulatory requirements;
- to maintain corporate, compliance, risk and audit records;
- to protect our systems, personnel, clients and business from misuse, fraud or security threats;
- to establish, exercise or defend legal claims;
- to provide service updates or professional communications where permitted by law.
5. Sharing and international transfers
We may share personal information with professional advisers, banks and custodians, administrators, technology and hosting providers, auditors, insurers, regulators, law-enforcement authorities and other parties where necessary for a legitimate business, legal or regulatory purpose.
Where information is transferred outside the United Kingdom, we seek to use an appropriate legal transfer mechanism and proportionate contractual, organisational and technical safeguards.
6. Retention
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including legal, regulatory, accounting, reporting and dispute-resolution requirements. Financial-services and anti-money-laundering records may need to be retained for a minimum period after a relationship ends, commonly at least five years where the applicable rules require it.
7. Security and communications
We use proportionate administrative and technical measures designed to protect personal information. No internet transmission is completely secure. Email should not be used to send passwords, full payment-card details or other highly sensitive credentials. Telephone or electronic communications may be monitored or recorded where lawful and appropriately notified for compliance, security, quality assurance or record-keeping purposes.
8. Your rights
Subject to applicable law, you may have rights to request access to personal data, correction, deletion, restriction, portability, objection to certain processing and withdrawal of consent where processing is based on consent. Some rights are subject to exemptions, particularly where we must retain records to comply with legal or regulatory obligations.
You also have the right to complain to the UK Information Commissioner’s Office (ICO) if you believe your personal information has been handled unlawfully.
9. Marketing
We do not sell personal data. Where we send direct marketing, we do so in accordance with applicable data-protection and electronic-marketing rules and provide an appropriate way to opt out.
10. Cookies and similar technologies
Our default static deployment uses only strictly necessary browser storage for basic site functionality, such as remembering that you acknowledged the cookie notice. Please see our Cookie Policy. If analytics, embedded media or advertising technologies are added, this policy and the consent mechanism must be updated before those services are enabled.
11. Contact us
Privacy enquiries may be sent to admin@culrossglobal.shop, by telephone on +44 20 7409 1352, or by post to Culross Global Management Limited, 8–10 Hill Street, London, England, W1J 5NG.
12. Changes to this policy
We may update this policy to reflect legal, regulatory, operational or technology changes. The current version will be published on this page with its effective date.