This Cookies and Privacy Policy (Cookies and Privacy Policy), together with our website terms of use (Terms of Use Policy) and any other documents referred to in it, set out the basis on which any personal data Roxbury Asset Management Ltd (Roxbury Asset Management Ltd, us, we or our) collects from you, or that you provide to us, will be processed by us. Roxbury Asset Management Ltd is committed to ensuring that your privacy is protected, so please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR), the data controller is Roxbury Asset Management Ltd of 2 Savile Row, London, W1S 3PA.

1.  What type of information do we collect from you?

1.1 We may collect and process the following information from you:

1.1.1  information that you provide by filling in forms on our website (our Website);

1.1.2 if you contact us, we may keep a record of that correspondence; and

1.1.3 details of your visits to our Website and the resources that you access.

2. How do we use your personal data?

2.1 We use information held about you in the following ways:

2.1.1 to carry out our obligations arising from any contracts entered into between you and us;

2.1.2 to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;

2.1.3 to ensure that content from our Website is presented in the most effective manner for you and for your computer or mobile device; and

2.1.4 to notify you about changes to our service.

2.2 We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these.

2.3 If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data.

3. Disclosure of Information

3.1 We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the United Kingdom Companies Act 2006.

3.2 We may disclose your personal information to:

3.2.1 our affiliates or professional advisers;

3.2.2 persons or organisations who work on our behalf to provide a product or a service to you;

3.2.3 companies which perform marketing services on our behalf or with whom we have joint marketing agreements;

3.2.4 other companies who we believe may have products and services of interest to you.

3.3 We may also disclose your personal information to third parties if:

3.3.1 we sell or buy any business assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

3.3.2 Roxbury Asset Management Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

3.3.3 we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of Roxbury Asset Management Ltd, our customers or others, including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. Roxbury Asset Management Ltd’s Data Protection No is ZA101328 or you can contact the ICO on

4. How we store and protect your data

4.1 The data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of contracts, the processing of details or the provision of support services. By submitting your personal data you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Cookies and Privacy Policy.

4.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

4.3 We take all reasonable care to ensure the security of the website and of your personal information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will not share your information other than as provided for in this Cookies and Privacy Policy or as required by law, court order or other government or law enforcement authorities.

5. IP addresses and cookies

5.1 We may collect information about your computer or mobile device, including where available your IP address, operating system and browser type, for system administration purposes.

5.2 Cookies contain information that is transferred to your computer’s hard drive. Cookies allow a web application to tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

5.3 This statistical data does not identify an individual. We only use this information:

5.3.1 to gather information on IP addresses and pages visited;

5.3.2 to analyse trends;

5.3.3 to administer the website;

5.3.4 to track users’ movements on the website; and

5.3.5 for purposes of statistical analysis.

5.4 You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Website. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you log on to our Website.

6. Links to other websites

6.1 This Cookies and Privacy Policy extends only to our Website and does not cover your use of, provision of data to and collection of data on any other website.

6.2 Our Website may from time to time contain links to and from other websites. If you follow a link to any of these websites please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You should always check these policies before you submit any personal data to these websites.

7. Your rights in respect of your information

The GDPR gives you a number of rights in respect of your data, including:

7.1 Right to access

7.1.1 You have the right to access the information we hold about you. If you would like a copy of this information please contact us. We may request proof of your identity before sharing such information.

7.2 Right to rectify your personal data

7.2.1 If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information.

7.3 Right to be forgotten

7.3.1 You may ask us to delete information we hold about you in certain circumstances. It may not be possible for us to delete all of the information we hold about you where we have an ongoing relationship, however please contact us and we will do our best to assist with your request.

7.4 Other rights

7.4.1 In addition to the above, you may also ask us to stop or restrict processing of the information we have about you. You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any other information on these features of your rights, please contact us.

8.  Changes to this privacy policy

8.1 Our Cookies and Privacy Policy may be reviewed and enhanced from time to time as a result of improvements we make to our services, changes in the law or developments in technology. It may be necessary to contact you and obtain your consent regarding any significant changes to our Privacy Policy.

9. Contact

9.1 Questions, comments, requests to exercise any of your rights or to make a complaint, please contact us at Roxbury Asset Management Ltd, 2 Savile Row, London, W1S 3PA or by emailing us your request to

9.2 If we are unable to resolve your complaint you may contact the information Commissioner’s Office at the Exchange Tower, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: +44 1625 545 700.