1 Introduction

ASK Private Client recognises that investors value their privacy. This notice explains how ASK Private Client and, where relevant, ShareIn collect, use, share and protect personal data, the lawful bases they rely on, and the rights available to you.

This privacy notice was last updated on 11 August 2026.

2 Who we are and our respective data-protection roles

This privacy notice applies to A.S.K. PARTNERS FS LIMITED (company number 16692091), trading as ASK Private Client, with registered office at 35 Harley Street, London W1G 9QU. ASK Private Client is registered with the Information Commissioner’s Office (“ICO”) under registration number ZB982728.

Share In Limited (company number SC408803), trading as ShareIn, provides the Portal infrastructure, client-money, ISA manager and regulatory-principal services. ShareIn is authorised and regulated by the Financial Conduct Authority and is registered with the ICO under registration number ZA029742. ShareIn acts as a processor where it handles personal data solely on ASK Private Client’s instructions. It acts as a separate controller where it determines the purposes and means of processing required for its own regulatory, client-money, fraud-prevention, complaints and legal obligations.

ASK Private Client and ShareIn may act as joint controllers for specified onboarding, investor-classification, appropriateness, know-your-customer (“KYC”) and anti-money-laundering (“AML”) processing where they jointly determine the purposes and means. Their joint-controller arrangements allocate operational responsibilities, but you may exercise your rights against either controller. ASK Private Client is the primary contact for privacy enquiries relating to the Portal and will coordinate with ShareIn where appropriate.

Payment and investment transactions through the Portal are administered using ShareIn’s systems and relevant banking or payment providers. Appropriate technical and organisational security measures are used, including encryption in transit where applicable. No method of transmission or storage is completely secure.

3 Why we may collect data about you

There are many reasons why we may collect and process your personal information and data, including:

  • to provide and manage products and services you have requested
  • to verify your identity, ensure you meet eligibility requirements, protect against fraud and manage risk
  • to comply with legal or regulatory requirements
  • to tell you about ASK Private Client, platform developments, related services and investment opportunities where electronic-marketing law permits this and, for an investment opportunity, only where the financial promotion may lawfully be communicated to you;
  • to re-organise or make changes to our business.

4 Legal reasons for collecting and using your data

When we collect your personal data, we will do so in line with the following legal reasons.

  1. Performance of a contract and steps before entering a contract. We process information needed to register you, administer your Account, assess applications, facilitate investments and payments, provide requested support and perform our agreements with you. Core Account administration is not based on consent.
  2. Legal obligations. We process information where necessary to comply with financial-services and financial-promotion requirements, including KYC, AML, sanctions, investor categorisation, preliminary suitability, risk-warning, cooling-off, record-keeping, tax, complaints and other legal or regulatory obligations.
  3. Legal compliance. If the law or any regulator in any competent jurisdiction requires us to, we may need to collect, process or share your data.
  4. Legitimate interests. We may process information where necessary for legitimate interests such as operating and securing the Portal, preventing fraud, administering and evidencing financial-promotion controls, maintaining marketing-suppression records, improving services, managing risk, establishing or defending legal claims and managing our business. We use this basis only after considering whether those interests are overridden by your rights and interests.
  5. Consent. We rely on consent where it is the appropriate basis, including for optional marketing or non-essential cookies where required. You may withdraw consent at any time without affecting processing carried out before withdrawal.

We do not routinely solicit health or detailed vulnerability information. Where limited information volunteered for support or accessibility reveals health or other special-category data, or where we process criminal-offence information for financial-crime purposes, we identify both an Article 6 lawful basis and the additional condition required by the UK GDPR and Data Protection Act 2018. Depending on the circumstances, the additional condition may include explicit consent, vital interests, the establishment or defence of legal claims, or a substantial-public-interest condition supported by law. Where required, we maintain an appropriate policy document. We do not rely on legitimate interests alone as the special-category or criminal-offence condition.

Some information is required by law, regulation or contract. If you do not provide it, we may be unable to open or maintain an Account, assess eligibility, accept an investment application or make a payment. We will indicate where information is mandatory.

Please remember that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you.

5 How we collect and use your data

We may obtain information in several ways which may include:

  1. Information which you give to us, including when you contact us or register your interest in ASK Private Client;
  2. Information that we receive from third parties including other companies in the ASK Partners group and other companies who provide services to you or us (including via fraud prevention agencies or government agencies);
  3. Information that we learn about you through our relationship with you;
  4. Information that we gather from the technology which you use to access our services (for example an IP address or telephone number);
  5. Information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.

We collect and process personal information and data about you at the start of, and for the duration of, your relationship with us – in each case where we have a reason for doing so and only where that reason is permitted under data protection law. The section below sets out how we collect and use your data in specific circumstances.

The categories we may process include identification and contact details; account and authentication data; client classification, investor categorisation, financial circumstances, knowledge and experience; jurisdiction and regulatory-journey information; transaction and payment data; KYC, AML, sanctions, fraud and criminal-offence information; communications and complaints; technical, device and cookie data; marketing preferences and suppression records; and limited support or accessibility information that you choose to provide. We do not ordinarily require detailed medical information or information about members of your household.

If information is obtained from someone other than you, sources may include ShareIn, ASK group companies, banks and payment providers, identity and fraud-prevention agencies, credit-reference agencies, public registers, sanctions and politically exposed person databases, professional advisers, counterparties and publicly available sources.

It’s important that you keep your personal information with us up to date, so please let us know if anything changes.

When you contact us

When you contact us (including by phone, email, through social media or through a website contact form) in relation to ASK Private Client, we may process your personal information (including your name, address, contact details, the name of the organisation you work for and other personal information you’ve given us) in order to respond to your query and provide the customer services you have asked us to (if any; for example providing assistance with the ASK Private Client platform).

We process contact and enquiry information to take steps at your request, perform our contract, provide customer support and pursue our legitimate interests in responding to and recording enquiries. If you do not provide information reasonably required to deal with an enquiry, we may not be able to respond fully.

When you register your interest in ASK Private Client, we will use your personal information to complete your registration and evaluate whether you qualify to invest based on applicable regulation.

The details we (or our relevant service providers) collect from you may include your name, address, date of birth, email address, phone number, nationality, investor categorisation, information about your financial circumstances, anti-crime and fraud information (to verify that you are neither suspected nor a victim of fraud or other offences and that your details do not appear on politically exposed persons and sanctions lists), education (including experience of and understanding of investing), visual images (such as copies of passports or drivers licence to verify identity) and payment or bank account details.

We do not routinely ask investors to provide medical information or detailed information about vulnerability. You may choose to tell us about an accessibility need, communication preference or personal circumstance where this would help ASK Private Client or ShareIn provide the service or communicate appropriately. Where possible, we record only the support or adjustment required rather than the underlying condition or other sensitive details. We process any special-category personal data only where an Article 6 lawful basis and an additional condition under data-protection law apply.

When you register or invest, personal data may be shared with ShareIn, relevant ASK group companies, Subparco Lenders or investment issuers, banks and payment providers, identity-verification, fraud-prevention, credit-reference and professional-service providers, and regulators or authorities, where necessary for the purposes and lawful bases described in this notice.

Marketing communications

We may use your contact details and marketing preferences to tell you about ASK Private Client, platform developments and related services. We will send electronic marketing only where you have given valid consent or where the “soft opt-in” under the Privacy and Electronic Communications Regulations applies. Where the soft opt-in is used, we obtained your details during a sale or negotiations for a sale, market only our similar products or services, and offered a clear opportunity to opt out when collecting your details and in every message.

Some communications about investment opportunities are financial promotions relating to non-mass market investments (“NMMIs”). Consent to receive marketing does not mean that you are eligible to receive every financial promotion. Before sending or making an NMMI financial promotion available, ASK Private Client and ShareIn may use your client classification, investor category, financial circumstances, investment knowledge and experience, objectives, previous assessments, jurisdiction and regulatory-journey information to determine whether the communication may lawfully be made to you. Depending on the circumstances, required steps may include investor categorisation, a preliminary assessment of suitability, a personalised risk warning, a cooling-off period and provision of prescribed risk information.

If you have opted in to marketing but are not eligible to receive a particular investment promotion, we may send general corporate or service information but will not send or make that promotion available to you. We may suppress or restrict investment marketing where a classification or assessment has expired, is incomplete, cannot be verified or indicates that the promotion should not be communicated. You may opt out at any time using the unsubscribe link, changing your Portal preferences or contacting us. Opting out does not affect essential Account or regulatory communications or existing Investments. We may retain the minimum information needed on a suppression list and regulatory records that law requires us to keep.

To make our website better and more secure

We will use your personal information for the purposes of administering our website and making it more secure, including troubleshooting, data analysis, testing, research, statistical and survey purposes. We process your data for this reason because we have a legitimate interest to provide you with the best experience we can, and to ensure that our website is kept secure.

You can manage non-essential cookies at any time by accessing the page www.askprivateclient.co.uk/cookies. Browser “do not track” signals are not a substitute for the choices presented by the Portal unless the Portal expressly states otherwise.

Technical information and analytics

When you visit our website, we will automatically collect the following information:

  • technical information, including the IP address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

We may also collect information on your location on our websites, such as your location data when accessing the website in line with the location settings on your phone or internet browser. This can be disabled or amended via the relevant iOS/Android device setting or in your internet browser settings.

We may work with various third parties, including advertising networks, analytics providers, hosting providers and search information providers from whom we may also receive general aggregated anonymous information about you.

6 How we use your information

We will only use or disclose your personal data for the purposes it was collected for and as disclosed in this notice.

7 Sharing your information

We may share personal data within the ASK Partners group, including ASK Partners Limited and its subsidiaries, where necessary for the purposes described in this notice. If a recipient is outside the UK, the transfer protections described in section 9 apply.

Recipients may act as processors, separate controllers or joint controllers depending on the activity. Processors may use personal data only under documented instructions and appropriate contractual safeguards. Separate and joint controllers are responsible for their own compliance and may provide additional privacy information where required.

In addition to the above, some of the organisations we may share your information with include:

  • Anyone who is named and authorised on your ASK Private Client account
  • Our affiliates and partners, including our white-label partners, to the extent necessary to enable us to deliver our services to you.
  • Banks and payment providers, to fund Accounts, safeguard client money and process investment-related payments and withdrawals.
  • Identity-verification, fraud-prevention, AML, sanctions-screening and credit-reference providers, both during onboarding and periodically while you have an Account, to verify identity, assess eligibility and risk, prevent and detect crime and comply with legal and regulatory obligations. These providers may keep their own records and may act as separate controllers.

We may also share your information for the following reasons.

If our business is sold

We will transfer your personal information to a third party as follows:

  • if we sell or buy any business or assets, we will provide your personal information to the seller or buyer (but only to the extent we need to, and always in accordance with data protection legislation); and
  • if ASK Private Client, or the majority of its assets, is acquired by somebody else, in which case the personal information held by ASK Private Client will be transferred to the buyer.

We process your personal information in this way because we have a legitimate interest to ensure our business can be continued by the buyer.

Where we have a legal or regulatory obligation

In some circumstances we may need to share your personal information:

  • if we are under a duty to disclose or share it to comply with a legal obligation (for example, to investigate something like theft or fraud); or
  • to protect the rights, property or safety of our website. This includes (but is not limited to) exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

In difficult circumstances

Occasionally ASK Private Client investors will share information which indicates that they, or a member of their household, are in imminent danger or at serious risk, and in line with guidance from the Information Commissioner, in such circumstances we may refer the situation to relevant authorities or sources of assistance. In such cases we will consider first and foremost the interests of the person at risk.

For statistical and research purposes

We may share some broader statistics and customer profiling information with third parties, but the information or data will be anonymised, so you will not be identifiable from it.

8 Cookies

How do we use cookies?

Our services use cookies to distinguish you from other users of our services. This helps us to provide you with a good user experience when you browse our website and keeps your visit secure from cross-site forgery. It also allows us to improve our services, comply with our legal obligations, pursue our legitimate interests and do helpful things.

What options do I have?

Some necessary cookies can't be turned off - stuff breaks without them or sometimes we have a legal obligation or legitimate interest in using them. You have the choice to accept or reject cookies in two additional categories - "Analytics and Performance" and "Marketing and Communications". This option appears when you first visit our website, and at any time when you use the "Change cookie settings" link in the website footer.

  • ASP.Net_SessionId: Enhances user experience by remembering session history.
  • ASPXAUTH: Records users authentication session
  • _culture: Assists recognising user’s nationality and language preferences, login, token, username recognition and encoding.
  • RequestVerificationToken: Part of a mechanism to protect against cross site scripting attacks
  • ARRAffinity: Enhances user browsing experience – part of load balancing setup
  • cookie-policy: Tracks presentation of the cookie information advice

The cookie names provided in this list are not exhaustive and can vary as we and our vendors update our systems, or where session identifiers are included in the cookie name.

Cookie preferences

You can manage cookie preferences at any time using the “cookies” link in the website footer. Necessary cookies cannot be disabled through that tool; optional Analytics and Performance and Marketing and Communications cookies are used only in accordance with your recorded choice.

Necessary: These cookies are essential for the proper functioning of our website. They are necessary for maintaining the website's performance and fulfilling regulatory requirements, such as remembering your progress through a form (e.g., when completing an investment application) and allowing access to secure areas of the website. These cookies always need to be on and can't be switched off.

Analytics and Performance: We use Azure Application Insights to help us continuously improve performance and usability. We also use Google Analytics to measure how you use the website so we can improve it based on user needs. Google Analytics sets cookies that store anonymised information about:

  • how you got to the site
  • the pages you visit on www.askprivateclient.co.uk and how long you spend on each page
  • what you click on while you're visiting the site

Marketing and communications: subject to your consent where required, these cookies and similar technologies may be set by us or advertising partners to measure engagement, personalise content and assess campaign effectiveness. You can withdraw consent at any time.

9 Where is my data processed

Portal data is hosted using service providers with data centres in the United Kingdom and European Economic Area, including Ireland, and may be accessed by authorised personnel and providers in other locations as necessary to provide and support the services.

The data and information that we collect and process may be transferred to, processed in and stored at, a destination outside of the UK.

Where personal data is transferred outside the United Kingdom, the relevant controller uses a lawful transfer mechanism. This may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU standard contractual clauses or another mechanism permitted by UK data-protection law. We also assess the transfer and apply supplementary measures where required. Contact us for information about the safeguard used for a particular transfer. All information that you provide us with is stored on our secure servers, or those of our third parties’ data storage providers.

10 Security

We will take all steps reasonably necessary to ensure that your information and/or data is treated securely and in accordance with this privacy notice.

We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Internet transmission cannot be guaranteed to be completely secure. Nothing in this notice limits any responsibility or right that cannot lawfully be excluded.

11 How long do we retain your data for?

We retain personal data only for as long as reasonably necessary for the purposes described in this notice and to meet legal, regulatory, tax, accounting, complaints and claims requirements. Different categories have different periods. Account, transaction, investor-categorisation, financial-promotion, preliminary-suitability and other regulatory records will generally be retained for the period required by applicable financial-services, financial-promotion and AML rules after the relationship or communication ends; some records may be kept longer where needed for litigation, regulatory enquiries or fraud prevention. Support and accessibility information is reviewed periodically and deleted or updated when no longer required. Detailed medical documents will not ordinarily be retained where recording the requested adjustment is sufficient.

When setting a period, we consider the nature, volume and sensitivity of the data, the risk of harm, the purpose, applicable limitation periods and legal or regulatory requirements. At the end of the period, we securely delete or anonymise the data unless continued retention is required or permitted by law. You may request further information about the period applying to a category of your data.

12 What are my rights under data protection laws?

You may exercise applicable data-protection rights by contacting ASK Private Client using the details in section 14. We may ask for information needed to verify identity. Requests are normally free of charge and answered within the period required by law, although rights may be limited or subject to exemptions in some circumstances.

12.1 Right to object

The right to object to us handling your personal information where we are handling your personal information based on our legitimate interests. If you ask us to stop handling your personal information in this way, we will stop unless we can show you that we have compelling grounds as to why we should continue to use your personal information. Please note that if you ask us to stop handling your data in the ways set out in this privacy policy it may impact our ability to deliver, and your ability to receive, any services we provide. You can also ask us to stop handling your personal information for marketing purposes at any time.

12.2 Right of access

The right to access your personal information which we are handling, and you are entitled to receive confirmation and details about whether your personal information is being processed by us.

12.3 Right to rectification

The right to require us to rectify any inaccurate personal information we hold about you. You also have the right to ask us to complete personal information which you think is incomplete.

12.4 Right to restriction

The right to restrict our processing of your personal information in certain circumstances.

12.5 Right to data portability

This right only applies to your personal information we are handling because you consented to us using it or because there is a contract in place between us.In this case, you have the right to receive your personal information in a structured, standard machine-readable format, and the right to ask us to send your personal information to another organisation or to give it to you.

12.6 Right to erasure

The right to require us to erase your personal information in certain circumstances.

12.7 Right to withdraw consent and object to marketing

Where processing is based on consent, you may withdraw consent at any time without affecting earlier processing. You have an absolute right to object to direct marketing. If you have a privacy concern, please contact ASK Private Client first so that we can try to resolve it. You also have the right to complain to the ICO at www.ico.org.uk or by telephone on 0303 123 1113.

12.8 Automated decision-making and profiling

We may use automated rules and profiling to support identity, sanctions, fraud, jurisdiction, financial-promotion eligibility, investor-categorisation, preliminary-suitability and appropriateness checks. We may use these rules to prevent a promotion from being sent or displayed where the relevant criteria have not been met. Unless we tell you otherwise at the relevant time, we do not make a decision based solely on automated processing that produces legal or similarly significant effects. If we do, we will explain the logic and likely consequences and provide the safeguards required by law, which may include human intervention and allowing you to express your view and challenge the decision. We do not use health, disability or other special-category information to infer that you are high-net-worth, sophisticated or professional, or to expand the NMMI promotions you are eligible to receive. Limited support information may be used to adjust how or when a permitted communication is delivered.

13 What about websites we link to?

The website may include links to third-party websites, advertisers, affiliates, plug-ins and applications. If you click on a link to any of these websites or enable those connections, you will leave our websites and this may allow third parties to collect or share data about you. We have no control over these third-party websites and are not responsible or liable for (i) their privacy statements, notices or policies or (ii) any contents or materials on third-party websites. We encourage you to check the privacy notice of every third-party website before you submit any personal data to these websites.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

14 Updates, additional notices and contact

Changes to our privacy notice

We keep this notice under review and will publish updated versions on the ASK Private Client website. Where a change materially affects how we use personal data, we will take reasonable steps to bring it to your attention and obtain consent if consent is required. Continued use of the Portal does not waive your data-protection rights.

Additional notices or policies

It is important that you read this notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This notice supplements any other privacy notices or policies and is not intended to override them.

UK Information Commissioner

We would always rather you speak to us first if you have any questions about our handling of your personal data, so we can resolve any problems as quickly as possible. However, if you are not happy with the way we have handled your data, or would like more information about your rights, you can contact the Information Commissioner’s Office, the UK’s independent authority on data privacy at www.ico.org.uk.

Contact us

ASK Private Client will usually be the controller for Portal relationship data and is the primary contact for privacy questions and rights requests. Contact us through the Portal, by post at 35 Harley Street, London W1G 9QU, or at the monitored privacy email address published on the Portal. Where your request concerns processing for which ShareIn is controller or joint controller, we will coordinate with ShareIn or direct you to the appropriate ShareIn contact.