Privacy Policy

1. Introduction

Origen Capital Partners Limited (Company No. 07500184, registered in England & Wales) and Origen Capital LLP (OC No. OC399068, registered in England & Wales), together referred to as "Origen Capital", "we", "us", or "our", are committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, store, and disclose your personal data when you visit our website at origencap.com (the "Website"), communicate with us, or engage our services. It applies to all individuals whose personal data we process, including prospective investors, business contacts, website visitors, and service providers.

We process personal data in accordance with the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018, and, where applicable, the EU General Data Protection Regulation (Regulation (EU) 2016/679) ("EU GDPR").

2. Data Controller

For the purposes of applicable data protection legislation, the data controller is:

If you have any questions about this Privacy Policy or our data practices, please contact us using the details above.

3. Information We Collect

We may collect and process the following categories of personal data:

3.1 Information You Provide Directly

• Identity data: first name, last name, title, and professional role.
• Contact data: email address, telephone number, postal address, and business address.
• Enquiry data: the content of messages submitted through our contact form or via email correspondence.
• Professional data: employer name, job title, investment experience, and accreditation status where relevant to our services.
• Financial data: information provided in connection with investment advisory or structuring services, including net worth declarations and source of funds documentation.

3.2 Information Collected Automatically

• Technical data: IP address, browser type and version, operating system, device type, and screen resolution.
• Usage data: pages visited, time spent on pages, navigation paths, referral source, and exit pages.
• Cookie data: information collected through cookies and similar tracking technologies (see Section 8 below).

3.3 Information from Third Parties

We may receive personal data from business partners, professional advisors, publicly available sources, and regulatory databases in connection with our due diligence and anti-money laundering obligations.

4. How We Use Your Information

We process your personal data for the following purposes and on the following legal bases:

5. Data Sharing and Disclosure

We may share your personal data with the following categories of recipients:

• Group entities: between Origen Capital Partners Limited and Origen Capital LLP for internal administrative purposes.
• Professional advisors: lawyers, accountants, auditors, and consultants engaged in connection with our services.
• Regulatory authorities: the Financial Conduct Authority (FCA), HM Revenue & Customs (HMRC), and other regulatory bodies where required by law.
• Service providers: IT hosting, website analytics, email services, and cloud storage providers who process data on our behalf under appropriate contractual safeguards.
• Business counterparties: co-investors, fund administrators, and transaction counterparties where necessary for the performance of our services, and only with your prior knowledge.

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

6. International Transfers

Given the international nature of our operations across the GCC, UK, EU, CIS, and LATAM regions, your personal data may be transferred to and processed in countries outside the United Kingdom and the European Economic Area. Where such transfers occur, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office or the European Commission.
• Transfers to countries with an adequacy decision from the UK Secretary of State or the European Commission.
• Binding corporate rules or other approved transfer mechanisms.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. Specific retention periods include:

• Enquiry data: retained for up to 24 months from the date of last contact, unless a business relationship is established.
• Client and investor data: retained for a minimum of 6 years following the end of the business relationship, in accordance with FCA and anti-money laundering requirements.
• Website analytics data: retained for up to 26 months.

8. Cookies

Our Website uses cookies and similar technologies to enhance your browsing experience and to analyse website traffic. The types of cookies we use include:

• Strictly necessary cookies: required for the operation of the Website and cannot be disabled.
• Analytics cookies: help us understand how visitors interact with the Website by collecting and reporting information anonymously.
• Functional cookies: enable enhanced functionality and personalisation.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website.

9. Your Rights

Under applicable data protection legislation, you have the following rights in relation to your personal data:

• Right of access: to obtain confirmation of whether we process your personal data and to request a copy of that data.
• Right to rectification: to request correction of inaccurate or incomplete personal data.
• Right to erasure: to request deletion of your personal data in certain circumstances.
• Right to restriction: to request that we restrict the processing of your personal data in certain circumstances.
• Right to data portability: to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object: to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent: where processing is based on your consent, you may withdraw that consent at any time.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one month, or inform you if an extension is required.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit, access controls, regular security assessments, and staff training on data protection obligations.

11. Complaints

If you are not satisfied with our response to a data protection concern, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. Any material changes will be posted on this page with an updated "Last updated" date. We encourage you to review this policy periodically.