Topor & Co. Limited
Data Protection and Privacy Policy
In this Policy, “TCL”, “we”, “us” and “our”, refer to Topor & Co. Limited, a company established in the United Kingdom with its registered office at Fora Borough Yards, 13 Dirty Lane, London, SE1 9PA. TCL’s company registration number is 07151311.
TCL is committed to safeguarding information provided to us by any third parties (“you”) (including its clients and all visitors to the website www.topor.co.uk (the “Website”)) from which any individual can be identified, such as names, contact details and ID data (“Personal Information”). To the extent that any Personal Information is collected, it will be held in confidence in accordance with the Data Protection Legislation (as defined below).
Please read the following Privacy Policy for an explanation of how we use and protect your information.
We will only use Personal Information which is provided to us, or otherwise obtained by us, as set out in this Policy. We will ensure that your Personal Information is handled in accordance with the “Data Protection Legislation” (meaning any law applicable from time to time relating to the processing of Personal Information and/or privacy as the same may be re-enacted, applied, amended, superseded, repealed or consolidated, including without limitation the UK General Data Protection Regulation (‘UK GDPR’) and the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003, in each case including any legally binding regulations, directions and orders issued from time to time under or in connection with any such law).
By visiting and/or contacting us through the Website (or otherwise engaging with us, such as for investor relations purposes), you acknowledge that we may collect, use and transfer your Personal Information as set out in this Policy. TCL reserves the right to change this Policy from time to time and you should therefore check this page frequently to ensure that you are happy with any changes.
For the purposes of the Data Protection Legislation, TCL is deemed to be the “data controller” in respect of any Personal Information that you provide to us or we otherwise obtain about you. TCL is registered with the Information Commissioner’s Office (‘ICO’) as a data controller.
Last updated: March 2026
1. PERSONAL INFORMATION THAT WE COLLECT FROM YOU
When you engage with us (e.g. sending us emails, contacting us via telephone or visiting or making an enquiry through the Website), you may provide Personal Information about yourself including your name and contact details (e.g. your address, email address and telephone number) and your job title and CV where you apply for a role with us. If you consider investing with us, you may also provide us with your financial information and various other necessary Personal Information (e.g. your social security or tax payer identification number, investment history and bank details). Where you make use of our Website we may also collect information about your use of the Website (e.g. your IP address and choice of web browser). Some of this Personal Information is collected and processed so we can perform a contract with you, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (namely to carry out and improve our business, analyse the use of our Website and services and support our staff and clients).
In order to comply with our legal obligations, we may record calls made on certain employees' landline and mobile telephone lines. Where this is in effect, we will make this clear by a spoken notice at the point of connection of the call.
Where you apply for a job with us, we may collect from you and third parties (where relevant) additional Personal Information such as your CV and any references. Unless you agree that we can keep such information on file for future opportunities or we need to retain such information for compliance with our legal obligations, in the event that you are unsuccessful, we will only retain this Personal Information for as long as is reasonably necessary to process your application.
Where you provide Personal Information on behalf of another individual, you are responsible for notifying that individual that you have provided their Personal Information to us and directing them to this Policy as to how we will process their Personal Information.
2. PERSONAL INFORMATION THAT WE RECEIVE FROM OTHER SOURCES
We may receive information from third parties who collect Personal Information from you and pass it on to us. For example: (i) where we are conducting due diligence on prospective investee companies or deciding whether to invest in third parties we may also receive Personal Information concerning key personnel; (ii) our staff may also give us emergency contact information as part of our emergency scenario planning and may give us details of their dependents and of other people in relation to their employee benefits arrangements; (iii) where another individual makes an investment on your behalf, they may provide us with certain Personal Information to effect the transfer of the investment to you, such as your name and contact details; (iv) your employer may provide your Personal Information to us in connection with a service they provide to us or in connection with services that we provide to our clients; and (v) we may receive information from past employers and others concerning your employment history where you apply for a job with us. Where this is the case the third party is responsible for informing you that they have shared your Personal Information with us, directing you to this Policy as to how we will process your Personal Information and obtaining any relevant consents from you to ensure you are happy with the ways in which your Personal Information will be used, but once we are holding it, we will only handle it in accordance with this Policy.
3. SENSITIVE PERSONAL INFORMATION
Under the UK GDPR, certain categories of Personal Information are treated as “special category data” and attract heightened protection. These categories are: (i) racial or ethnic origin; (ii) political opinions; (iii) religious or philosophical beliefs; (iv) trade union membership; (v) genetic data; (vi) biometric data (where used for identification); (vii) health data; (viii) data concerning a person’s sex life or sexual orientation; and (ix) data relating to criminal convictions and offences.
You may provide us with such information from time to time in connection with your application to invest with us, our provision of investment services to you, where you apply for a job with us or otherwise. In such cases, the provision of this information is entirely voluntary and subject to your express consent, however, we may be unable to carry out some activities necessary to process your application, instructions or other requests without the provision of such information. Where necessary, we may also process such information in the establishment, exercise or defence of legal claims.
Where we do receive such information, we will only keep it for as long as strictly necessary in order to comply with our obligations under the law.
4. WHAT WE DO WITH YOUR PERSONAL INFORMATION
We will only use your Personal Information in order to (a) manage and administer your investment or proposed investment and any related accounts on an ongoing basis, in accordance with the contract between you and us (lawful basis: performance of a contract); (b) provide investor relations and support to you in respect of these services (lawful basis: performance of a contract / legitimate interests); (c) improve our Website and services (lawful basis: legitimate interests); (d) comply with our own legal and regulatory obligations, including in relation to financial promotion, applicable anti-money laundering and counter terrorist financial legislation, the Common Reporting Standard and FATCA (lawful basis: legal obligation); (e) for our internal business processes, including providing support to our staff and our assessments of prospective investee companies (lawful basis: legitimate interests); and (f) where relevant, process your application for employment (lawful basis: performance of a contract / legal obligation).
Where you have explicitly consented at the time we collected your Personal Information or where we otherwise have a right to do so, we may also use your Personal Information to let you know about any of our services that may be of interest to you and/or inform you about important changes or developments to our services by email.
Where you or your employer (or any other entity you work for) provides services to us, you and/or they may provide us with some of your Personal Information in connection with the provision of the services, such as your name, business contact details and other ID information. We will only process such Personal Information in connection with the provision of the services and in accordance with this Policy.
5. HOW WE SHARE YOUR PERSONAL INFORMATION
Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your Personal Information with certain third parties, such as account custodians, service providers, regulatory bodies, auditors, technology providers and any duly authorised agents or related, associated or affiliated companies of the foregoing for the same purposes.
By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. We ask all third parties to treat your Personal Information securely and in accordance with this Policy and will take reasonable steps to enforce this. We will never sell your data.
In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose it in order to comply with any legal obligation (such as anti-money laundering or anti-terrorist financing obligations), carry out an internal investigation, enforce our Terms and Conditions or any other agreement, or protect the rights, property, or safety of TCL, our group companies and our clients, directors, employees or other personnel.
In particular, in order to comply with the Common Reporting Standard and FATCA, Personal Information may be shared with the tax authority of the jurisdiction in which the relevant account is domiciled, which in turn may exchange information with foreign tax authorities (including the U.S. Internal Revenue Service).
In exceptional circumstances, if we are sold or merged with another company we may disclose your information to a potential buyer so that they can continue to provide the services you have requested.
6. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
Where we transfer your Personal Information outside the United Kingdom, we will ensure that appropriate safeguards are in place as required by the UK GDPR. Such safeguards may include: (a) transferring to a country that the UK Government has determined provides an adequate level of data protection; (b) using UK-approved Standard Contractual Clauses; or (c) relying on another lawful transfer mechanism. If you would like further information about the safeguards we have in place for international transfers, please contact us at info@topor.co.uk.
7. OUR SECURITY MEASURES AND DATA RETENTION
We will only keep your Personal Information for as long as we reasonably require for business or other purposes and, in any event, only for as long as the Data Protection Legislation allows. In practice, we apply the following indicative retention periods: (a) client records and investment-related documentation are retained for a minimum of five years following the end of the client relationship, in line with FCA requirements; (b) AML/KYC records are retained for five years from the end of the business relationship or a one-off transaction; (c) employee records are retained for six years after employment ends; and (d) job applicant records (where unsuccessful) are retained for up to six months unless you consent to longer retention.
Unfortunately, the transmission of information via the internet is not completely secure and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the Website; any transmission is therefore at your own risk.
Some of our premises use CCTV for the purpose of crime prevention, however, this is under the control of a third party and therefore you should consult any notices they display and their privacy statements for more information.
8. COOKIES AND WEBSITE TRACKING
Our Website uses cookies and similar tracking technologies. Cookies are small text files placed on your device when you visit our Website. We use the following types of cookies:
• Strictly necessary cookies: required for the Website to function and cannot be switched off.
• Analytics cookies: help us understand how visitors interact with the Website (e.g. via tools such as Google Analytics). These are only set with your consent.
Where cookies are not strictly necessary, they will only be placed on your device with your prior consent. You can manage or withdraw your cookie preferences at any time through your browser settings.
9. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
Under the UK GDPR, you have the following rights in relation to your Personal Information:
• The right to be informed about how your Personal Information is used (as set out in this Policy).
• The right of access — to request a copy of the Personal Information we hold about you.
• The right to rectification — to ask us to correct inaccurate or incomplete data.
• The right to erasure (‘right to be forgotten’) — to ask us to delete your data where there is no longer a lawful ground to hold it.
• The right to restrict processing — to ask us to limit how we use your data in certain circumstances.
• The right to data portability — to receive your data in a structured, machine-readable format and transfer it to another controller.
• The right to object — to object to processing based on legitimate interests or for direct marketing purposes.
• The right to withdraw consent — where we process your Personal Information on the basis of consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• The right not to be subject to automated decision-making, including profiling, that produces a legal or similarly significant effect (note: TCL does not carry out such automated decision-making).
To exercise any of these rights, please contact us at info@topor.co.uk. We will respond within one month of receiving your request (or inform you if a further extension is needed).
10. COMPLAINTS
Should you have any queries or complaints in relation to how we use your Personal Information, please contact us at info@topor.co.uk. You also have the right at any time to lodge a complaint directly with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection, without first contacting us. The ICO’s website is www.ico.org.uk.
9. CHANGES TO THIS PRIVACY POLICY
TCL may amend this Policy from time to time. We will notify you of any material changes by posting an updated version on the Website and, where appropriate, by email. Any changes to this Policy will be posted on the Website.
10. OUR CONTACT INFORMATION
If you have any questions (including relating to transfers of your Personal Information outside the United Kingdom), please feel free to contact us by email at: info@topor.co.uk.
11. SUBJECT ACCESS REQUEST
A Subject Access Request (SAR) form is available at this link: Subject Access Request form.