Privacy policy

Last updated: 31 August 2026

This policy explains how Sceptre Investment Management Ltd collects, uses, shares and protects personal data, and the rights you have in relation to it.

1Who we are

Sceptre Investment Management Ltd (“Sceptre”, “we”, “us”) is a company registered in England and Wales (company number 12607022) with its registered office at The Clink, Odiham, RG29 1LU.

We are the controller of the personal data described in this policy. We are registered with the Information Commissioner’s Office under registration number C2043821.

Sceptre is an appointed representative of Eschler Asset Management LLP, which is authorised and regulated by the Financial Conduct Authority (FRN 510079). Eschler acts as our principal firm and is responsible for our regulated activities.

2Who this policy covers

This policy applies to personal data about:

• visitors to our website;
• prospective and current investors, and the individuals connected with them, such as directors, beneficial owners, authorised signatories and advisers;
• business contacts, including representatives of counterparties, service providers and other professional firms; and
• job applicants.

Our services are intended only for professional clients and eligible counterparties. We do not knowingly collect personal data from children.

3Personal data we collect

Depending on our relationship with you, we may collect:

• Identity and contact details: name, title, job title, employer, postal address, email address and telephone number.
• Due diligence information: date of birth, nationality, copies of identity documents, proof of address, tax residence and tax identification numbers, source of funds and source of wealth, and the results of sanctions, politically exposed person and adverse media screening.
• Investment and financial information: investor classification, bank account details for subscriptions and redemptions, holdings, transaction history and correspondence.
• Communications: records of emails, telephone calls and meetings, which we may be required to keep under regulatory rules.
• Website data: IP address, browser and device information, and pages visited, collected through cookies and similar technologies.
• Recruitment information: CVs, qualifications, employment history and references.

We collect this data directly from you, from the organisation you represent, from fund administrators and other service providers, and from public sources and screening databases used for regulatory checks.

4How we use it and our legal basis

We only use personal data where UK data protection law allows us to. The main purposes and the legal basis we rely on are:

Where we rely on legitimate interests, we have considered whether those interests are outweighed by your rights and you can object at any time (see section 10). You can unsubscribe from any information we send you by replying to the message or contacting us.

Some due diligence checks may reveal information about criminal convictions or offences. We process this only where necessary to meet our legal obligations to prevent financial crime, as permitted by the Data Protection Act 2018.

We do not make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.

5Investors in funds we manage

If you invest in a fund for which we act as manager or adviser, the fund itself (acting through its board) is usually a separate controller of your personal data, and the fund’s administrator processes it on the fund’s behalf. The fund’s offering documents contain its own privacy notice, which explains how the fund uses your data, including under the Cayman Islands Data Protection Act where the fund is established there. This policy covers the personal data that Sceptre itself receives and uses.

6Who we share it with

We do not sell personal data. We share it only where necessary, with:

• Eschler Asset Management LLP, as our principal firm, for regulatory oversight and compliance monitoring;
• funds we manage or advise, their boards and their administrators, custodians, depositaries and auditors;
• our professional advisers, including lawyers, accountants and auditors;
• service providers who support our business, such as IT, email, document storage, website hosting and identity verification providers, who act on our instructions under written contracts;
• regulators, tax authorities and law enforcement bodies, including the Financial Conduct Authority, HM Revenue & Customs and the Cayman Islands Monetary Authority, where we are required or permitted to do so; and
• a buyer or successor if all or part of our business is sold or reorganised, subject to appropriate confidentiality protections.

7International transfers

Some of the organisations we share data with, including fund service providers and technology providers, are located outside the United Kingdom, for example in the Cayman Islands, the European Economic Area and the United States. Where we transfer personal data outside the UK, we make sure it is protected by an adequacy decision under UK law, the UK International Data Transfer Agreement or Addendum, or another safeguard permitted by UK data protection law. You can ask us for details of the safeguards that apply.

8How long we keep it

We keep personal data only for as long as we need it for the purposes described above, including to meet legal, regulatory, tax and accounting requirements. In particular:

• anti-money laundering records are kept for at least five years after the end of the business relationship, as required by the Money Laundering Regulations 2017;
• records required under FCA rules are generally kept for at least five years, and longer where the FCA or our principal firm requires;
• website analytics data is kept for no longer than 26 months; and
• unsuccessful job applications are deleted within 12 months unless you agree to us keeping them longer.

When data is no longer needed, we delete or anonymise it securely.

9Security

We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access, including access controls, encryption, multi-factor authentication and confidentiality obligations on our staff and service providers. If a personal data breach occurs that is likely to put you at risk, we will notify you and the Information Commissioner’s Office where the law requires it.

10Your rights

Under UK data protection law you have the right to:

• request a copy of the personal data we hold about you;
• ask us to correct inaccurate or incomplete data;
• ask us to delete your data, where we no longer have a lawful reason to keep it;
• ask us to restrict how we use your data;
• object to our use of your data where we rely on legitimate interests, and to direct marketing at any time;
• receive your data in a portable format, where the processing is based on consent or contract and carried out by automated means; and
• withdraw your consent at any time, where we rely on consent.

Some rights are limited where we must keep data to meet a legal obligation, such as anti-money laundering record-keeping. To exercise any right, contact us using the details below. We will respond within one month and will not usually charge a fee.

If you are unhappy with how we have handled your data, please contact us first so we can try to resolve it. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

11Cookies

Our website uses cookies that are strictly necessary for it to work, for example to remember your cookie choices and keep the site secure. With your consent, we also use analytics cookies to understand how visitors use the site so that we can improve it. We do not use advertising cookies.

You can accept or reject non-essential cookies using the banner shown when you first visit, and change your choice at any time through the cookie settings link in the footer or your browser settings. Rejecting analytics cookies does not affect your ability to use the site.

12Changes to this policy

We may update this policy from time to time. The latest version will always be available on this page, with the date it was last updated shown at the top. Where changes are significant, we will take reasonable steps to let affected individuals know.

13Contact us

For any questions about this policy or how we handle personal data, please contact: