Question 1

1.  Who we are

Accepted Answer

This Privacy Policy explains how Sazy Capital Holdings Ltd ("we", "us" or "our") collects, uses and protects your personal data when you visit our website at www.sazycapital.com (the "Website").We are a UK investment holding and family office company, registered in England and Wales (Company No. 13478460). Our registered office is at Synergy House, 4th Floor, 114–118 Southampton Row, London WC1B 5AA.We are the data controller in respect of personal data collected via this Website. We are registered with the Information Commissioner's Office (ICO), registration number ZB527646.If you have any questions about this Policy or how we handle your personal data, please contact us at: dataprotection@sazycapital.com.

Question 2

2.  What this Policy covers

Accepted Answer

This Policy covers personal data collected through the Website, including via our contact form, cookies and analytics tools, and links to social media platforms. It does not cover personal data collected in connection with our investment activities or business relationships, which are governed by separate notices provided to the individuals concerned.

Question 3

3.  What personal data we collect

Accepted Answer

3.1  Contact formWhen you use our contact form, we collect your name, email address and the content of your message. This data is submitted to our team by email and is also stored in our website CRM (provided by Wix). Access to the CRM is restricted to authorised Sazy Capital personnel and contracted service providers who are bound by appropriate data processing obligations.3.2  Cookies and analyticsWhen you visit the Website, we automatically collect certain technical information through cookies and similar technologies. We use both Wix's native analytics and Google Analytics (GA4) for this purpose. Please see Section 10 below for full details of the cookies we use and how to manage your preferences.3.3  Social mediaOur Website includes a link to our LinkedIn profile. Clicking through to LinkedIn is governed by LinkedIn's own privacy policy. We do not embed any social media tracking pixels or sharing buttons, and we do not receive personal data from social media platforms by virtue of linking to them.3.4  Third-party tools and tag managementThe Website uses Google Tag Manager to manage third-party tags and scripts. The complete list of cookies and tools in use is available via our cookie preference centre (see Section 10). The Website is built and hosted on the Wix platform.

Question 4

4.  Lawful basis for processing

Accepted Answer

We rely on the following lawful bases under applicable data protection law:●        Legitimate interests — for website analytics and performance monitoring, and for responding to contact form enquiries, where our interests are not overridden by your rights.●        Consent — for non-essential cookies, where you have actively consented via our cookie preference centre.●        Legal obligation — where we are required to process data by applicable law.

Question 5

5.  How we use your personal data

Accepted Answer

We use the personal data we collect to:●        respond to your enquiry or message;●        monitor and improve the performance and usability of the Website;●        comply with our legal obligations; and●        manage our legitimate business interests as an investment holding company.We do not use your personal data for automated decision-making or profiling. We do not sell your personal data to third parties.

Question 6

6.  Who we share your personal data with

Accepted Answer

We do not share your personal data with third parties except as follows:●        Wix — our website platform and CRM provider, acting as a data processor under Wix's data processing terms;●        Google — for Google Analytics (GA4) and Google Tag Manager, operating under Google's privacy commitments and standard contractual clauses;●        Hawthorn Advisors — our web development agency, contracted as a data processor with access limited to what is necessary for website management;●        professional advisers (such as lawyers and accountants) where necessary; and●        regulators, law enforcement or other authorities, where required by law.

Question 7

7.  International transfers

Accepted Answer

Some of our service providers process personal data outside the UK. The following transfers occur as part of how the Website operates:●        Wix hosts the Website across servers in North America and Europe. Where data is processed in the United States, Wix relies on standard contractual clauses as the applicable transfer mechanism.●        Google (Analytics and Tag Manager) may transfer data to the United States. Google participates in the UK-US data bridge and uses standard contractual clauses.In addition, in the ordinary course of our business activities, we may occasionally need to share personal data with parties located in countries outside the UK that do not benefit from an adequacy decision. Where this occurs, we will ensure that appropriate safeguards are in place before any transfer takes place — for example, by entering into the UK International Data Transfer Agreement (IDTA) or another approved transfer mechanism — so that your personal data remains protected to the standard required by applicable law.

Question 8

8.  How long we keep your data

Accepted Answer

Your personal data will be retained for as long as it is necessary to carry out the purposes set out in this Privacy Policy (unless longer retention is required by law). We will not retain personal data beyond this period, and retention is subject to periodic review. We may keep anonymised data, which can no longer be attributed to you, without time limits to the extent that we have a legitimate and lawful interest in doing so.

Question 9

9.  Your rights

Accepted Answer

Subject to certain conditions, data protection law provides you with rights in relation to your personal data, including the right to access, rectify, withdraw consent, erase, restrict, port and object to the processing of your personal information. You also have the right to lodge a complaint with the relevant supervisory authority if you believe your personal data is not being processed in accordance with applicable law. Further detail on each right is set out below. ●        Right to access. You have the right to obtain a copy of the personal data we hold about you.●        Right to rectification. You may request that we correct any inaccurate or incomplete personal data we hold about you. We will update our records accordingly and, where appropriate, notify any third parties to whom such data has been transmitted.●        Right to erasure. You may request that we erase your personal data. We will comply unless there is a lawful reason not to do so.●        Right to restriction. You may request that we restrict the processing of your personal data in certain circumstances — for example, while we verify the accuracy of data you have disputed.●        Right to data portability. You may request a copy of the personal data you have provided to us in a structured, commonly used and machine-readable format, and ask us to transmit it to another data controller of your choice.●        Right to object. You may object to the processing of your personal data where we rely on legitimate interests as our lawful basis. We will stop processing unless we have compelling legitimate grounds that override your interests.●        Right to withdraw consent. Where we rely on your consent to process personal data, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal.●        Right to lodge a complaint. We encourage you to contact us in the first instance if you have any questions or concerns about how we process your personal data. However, you also have the right to lodge a complaint directly with the Information Commissioner's Office (ICO) at www.ico.org.uk or by calling 0303 123 1113.

Question 10

10.  Cookies

Accepted Answer

Some of the cookies we set when you visit the Website are essential to its working functionality. Without these, certain features would not operate correctly.We also use performance cookies to provide a better user experience and to understand how content on the Website is used and how it can be improved.We use Usercentrics as our cookie consent platform, which automatically disables all non-essential cookies until you actively consent. If you do not want to receive non-essential cookies, or wish to change your preferences at any time, you can manage your settings any time by clicking on the fingerprint icon on the bottom left of the website. By clicking through, you can adjust your consent and view the full list of cookies in use on the Website.Please note that disabling certain cookies may affect the functionality of the Website.

Question 11

11.  Security

Accepted Answer

We use appropriate technical and organisational measures to protect the personal data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data. In particular, we:●        hold personal data in secure facilities and, where information is held electronically, on secure servers;●        use encrypted transmission links wherever possible;●        use safeguards such as authentication systems and access control mechanisms to prevent unauthorised access to systems and data;●        regularly review our information collection, storage and processing practices, including physical security measures; and●        restrict access to personal data to those employees, contractors and agents who need it in order to process it on our behalf, and who are subject to strict confidentiality obligations.

Question 12

12.  Third-party links

Accepted Answer

The Website contains a link to our LinkedIn profile. This Policy does not apply to LinkedIn or any other third-party platform. We encourage you to read the privacy policies of any third-party sites you visit.

Question 13

13.  Changes to this Policy

Accepted Answer

We may update this Policy from time to time to reflect changes in our practices or applicable law. The updated version will be posted on this page with a revised "Last updated" date. We encourage you to check this page periodically.

Question 14

14.  Contact us

Accepted Answer

If you have any questions, concerns or requests regarding this Policy or how we handle your personal data, please contact us: Sazy Capital Holdings LtdSynergy House, 4th Floor114–118 Southampton RowLondon WC1B 5AA Email: dataprotection@sazycapital.com If you are not satisfied with our response, you have the right to complain to the Information Commissioner's Office at www.ico.org.uk.