Privacy Policy

Date of Latest Update: 10 April 2026

Primary Capital Partners LLP (“Primary”, “we”, “our”, “us”) respect your privacy and are committed to protecting your personal data – that is any information from which a person can be identified, such as names, contact details and ID information (which we refer to collectively as  “Personal Data” in this Privacy Policy). We want to be transparent with you about how we will use your Personal Data collected by us when you visit our website available at www.primary.pe (the “Site”) and any other Personal Data that you may provide to us or which we acquire through our day-to-day business activities. We also want to tell you about your data protection rights.

With that in mind, this website privacy policy (the “Privacy Policy”) covers the following:

• WE MAY MAKE CHANGES TO THIS PRIVACY POLICY
• WHO WE ARE
• WHAT PERSONAL DATA WE COLLECT
• HOW WE USE YOUR PERSONAL DATA
• WHO WE SHARE YOUR PERSONAL DATA WITH
• HOW WE KEEP YOUR PERSONAL DATA SECURE
• HOW LONG WE STORE YOUR PERSONAL DATA
• YOUR RIGHTS RELATING TO YOUR PERSONAL DATA
• MARKETING
• OUR POLICY ON CHILDREN
• THIRD-PARTY LINKS
• COMPLAINTS
• HOW TO CONTACT US

 

WE MAY MAKE CHANGES TO THIS PRIVACY POLICY.

We may amend this Privacy Policy from time to time without notice. If that happens, the new version of this Privacy Policy will be made available on this page and will apply from such time as it is made available.

 

WHO WE ARE.

This Site is operated and owned by Primary Capital Partners LLP (“Primary”, “we”, “our”, “us”), and we are ordinarily the ‘controller’ of your Personal Data for the purposes of Data Protection Legislation (as defined below).

Where this Privacy Policy relates to the processing of investors’ Personal Data, the general partner entity of the relevant fund (the “General Partner”) also acts as a separate data controller in respect of that Personal Data, alongside Primary. In those sections of this Privacy Policy, references to “Primary”, “we”, “us” and “our” should be read as references to both Primary and the General Partner.

Our registered address is at Augustine House, 6a Austin Friars, London EC2N 2HA, England.

 

WHAT PERSONAL DATA WE COLLECT.

Use of your Personal Data.

This Privacy Policy sets out how we will use your Personal Data collected by us when you visit the Site, and any other Personal Data that you may provide to us or which we acquire through our day-to-day business.

• For investors in Fund V and any future funds, please read this Privacy Policy alongside our data privacy notice for investors as contained in the investor subscription documentation (the “Data Privacy Notice for Investors”).
• For staff, please read this Privacy Policy alongside our Staff Privacy Policy.

This Privacy Policy is designed to provide privacy information to every person whose data we hold, including those with whom we do not have a direct relationship. In the event of any conflict between this Privacy Policy the Staff Privacy Policy, the Staff Privacy Policy shall take precedence.

We will ensure that your Personal Data is handled in accordance with the law. The relevant law here is: (i) the United Kingdom General Data Protection Regulation (the “UK GDPR”); (ii) the Data Protection Act 2018 (the “Data Protection Act 2018”); (iii) the EU General Data Protection Regulation (the “EU GDPR”); (iv) the Privacy and Electronic Communications (EC Directive) Regulations 2003; (v) and all similar or related legislation relating to the processing of Personal Data and/or privacy applicable from time to time or as re-enacted, applied, amended, superseded, repealed or consolidated that is applicable to us (together the “Data Protection Legislation”).

How do we collect Personal Data, and what Personal Data do we collect?

We may collect and receive (and use for the purposes set out in this Privacy Policy) your Personal Data in the following ways: (i) information that you provide to us (for example, when you make use of the Site, log into the investor portal, complete subscription or application forms, respond to online surveys or contact us); (ii) information that we collect automatically (for example, details of your visit to the Site, including your IP address, choices as to cookies and your choice of web browser); (iii) information we generate in the course of our relationship with you (for example, transaction records, account information and correspondence with us); and (iv) information that we receive from third parties or from publicly available sources (for example, public databases and websites such as social media platforms).

We may collect the following Personal Data about you. Please note that some of the Personal Data described below may constitute Sensitive Data, which is subject to additional legal requirements as set out in the “Sensitive Data” section of this Privacy Policy.

1. General Contacts and Site Visitors

   When contacting or corresponding with us via email, via telephone, in writing or otherwise, you may provide Personal Data including your name and contact details. You may also provide us with Personal Data about your preferences for receiving marketing communications and, when you attend one of our events, about your dietary requirements and accessibility requirements. We will process this Personal Data in order to enter into and perform contracts with you, to pursue our legitimate interests (e.g. of operating and improving the websites, developing and improving our business, conducting marketing activities, ensuring the safety and security of our employees and visitors, preventing and investigating unlawful or unauthorised use of Personal Data or the Site, and enforcing our terms of use and other agreements), to comply with our legal and professional obligations (such as the recording of voice and telephone lines where applicable in accordance with MIFID II requirements) and, where required by and in accordance with the Data Protection Legislation, with your consent.

2. Investors

   If you (or an institutional investor or investment vehicle with which you are associated) invest, have invested or consider investing with us, we may also collect and process various Personal Data about you (or, where the investor is a legal entity, about natural persons connected to that entity, such as contact persons, directors, employees, trustees, nominees, agents, representatives and/or beneficial owners). Such Personal Data may include:

   • identity and verification information (such as name, date of birth, passport details, nationality and identity verification documents);
   • financial details (such as bank details, IBAN and BIC codes, source of wealth, source of funds, assets and investment experience);
   • tax-related information (such as tax identifiers, tax status and tax certificates);
   • compliance-related information (such as PEP status, sanctions status and criminal convictions information); and
   • investment activity information (such as subscription, redemption, conversion and transfer information).

   This processing will be justified by the performance of a contract concluded with you, or for the purpose of corresponding with you for business purposes, compliance with legal and regulatory obligations (such as KYC, AML, and tax and accounting reporting obligations) and/or in the furtherance of our legitimate interests in managing and administering your investment and our business.

   Please refer to our Data Privacy Notice for Investors.

3. Staff

   We may collect, store, and use Personal Data of our current and former staff. Please refer to our Staff Privacy Policy for further information available on Primary’s server. If you are a former staff member and do not have easy access to the Staff Privacy Policy, you may request a copy by it by contacting us using the information contained in the “How to Contact Us” section below.

4. Job Applicants

   When individuals apply for roles with us, we acquire Personal Data, including identity and contact information, CVs and covering letters, employment history, educational qualifications, interview notes, references and right to work information. We will process such Personal Data pursuant to our legitimate interests in recruiting and selecting suitable candidates for roles within our business and to comply with our legal and regulatory obligations (including, for example, verifying your right to work in the UK).

5. Third party contacts

   If you provide services to us or have a business dealing with us (or are employed or engaged by an entity which provides services or has a business dealing with us), we may acquire Personal Data including your identity and contact details, employment information and copies of ID documents or similar information. We will process this Personal Data in order to enter into and perform contracts with you and/or to pursue our legitimate interests (e.g. for the purpose of corresponding with you and operating our business). In certain situations, we may be legally required to conduct due diligence or carry out KYC and AML checks.

6. Management teams of target and portfolio companies

   In the course of our investment activities, we may collect Personal Data about individuals at businesses we are considering investing in or have invested in as part of our due diligence and investment process. This may include identity and contact information, professional background and employment history, financial information (including remuneration and shareholdings), and information from public sources such as Companies House and LinkedIn. We will process this Personal Data in order to pursue our legitimate interests (e.g. of growing and operating our business and investments).

7. Information about those related or otherwise connected to our staff

   We sometimes ask members of our staff to provide details of their next of kin and nominated beneficiary information for the purpose of our emergency scenario planning or in case an incident occurs at work. We may also ask for details of their dependents, spouses and/or other people in relation to their employee benefits arrangements, so that we can use this information for the benefit of our staff. We process this Personal Data in accordance with our legitimate interests in maintaining a safe working environment and, where relevant, our contractual obligations to our staff in connection with the administration of their benefits arrangements.

Aggregated Data.

We also generate, use and share “Aggregated Data” such as statistical or demographic data for the purpose of our own marketing, promotional purposes, fund reporting, investor analysis and monitoring of our business performance. In order to monitor and improve the Site, we may also collect and record certain aggregated data about how you use it, including the pages you visit, the URL from which you arrived and the URL to which you navigate when you leave. This aggregated data is used primarily to enhance your experience of the Site. Provided that the Aggregated Data cannot identify you as an individual (and you cannot be re-identified by combining the Aggregated Data with other data), it will not constitute Personal Data for the purposes of applicable Data Protection Legislation.

Sensitive Data.

Certain of the Personal Data we collect may, as set out above, constitute “Sensitive Data” (otherwise known as special category data), such as:

• details about your race or ethnicity, political opinions and activities (for example in respect of your PEP status), or trade union membership; and/or
• information about criminal convictions and offences.

Outside of the contexts set out above in this Privacy Policy, due to its sensitivity, we ask that you do not volunteer Sensitive Data to us unsolicited, for example by including it in emails or in any free-text fields on our Site, unless we have specifically requested it from you.

Where we process Sensitive Data (as described in this Privacy Policy), we are required to identify an additional legal basis under Article 9 of the UK GDPR. Whilst we try to minimise the processing of Sensitive Data as far as possible, depending on the context, we will rely on one or more of the following conditions:

• you have freely given you explicit consent for one or more specified purposes;
• employment, social security and social protection, where processing is necessary to carry out our obligations as an employer, for example in connection with occupational health, employee benefits and equal opportunities monitoring;
• substantial public interest, where processing is necessary for reasons of substantial public interest, including in connection with the prevention and detection of unlawful acts, fraud prevention, suspicion of money laundering or terrorist financing, and compliance with our regulatory obligations; and
• legal claims, where processing is necessary for the establishment, exercise or defence of legal claims.

Where we rely on explicit consent as our Article 9 condition, you have the right to withdraw that consent at any time by contacting us using the details set out in the “Your Rights Relating to Your Personal Data” section set out below.

Data collected via cookies.

Some of our data collection (including collection of usage data) is facilitated by the use of cookies and similar technologies. For more information, please refer to our Cookie Policy.

 

HOW WE USE YOUR PERSONAL DATA.

Purposes.

We will only use your Personal Data for the purposes for which we collected it.

You do not have to provide Personal Data to us. However where we need to process your Personal Data either to comply with law or to perform our obligations to you, and you fail to provide that data when requested, we may not be able to perform our obligations to you (for example, to make the Site and services available to you) but we will notify you if this is the case at the time.

Legal basis.

In respect of each of the purposes for which we use your Personal Data, we ensure there is a ‘legal basis’ for doing so, as required by the relevant Data Protection Legislation. Above, we set out examples of the legal bases we rely on. However, by way of overview, most commonly, we will rely on one of the following legal bases:

• “Performance of a contract”: this is applicable where we need to use your Personal Data to perform our obligations under a contract.
• “Legitimate interest”: this is applicable where we use your Personal Data for our legitimate interests (and your interests and fundamental rights do not override those interests).
• “Compliance with Law”: this is applicable where we need to use your Personal Data to comply with our applicable legal or regulatory obligations (such as KYC, AML and, tax and accounting reporting obligations).
• “Consent”: this is applicable where we have your freely given, specific and informed consent to use your Personal Data for a particular purpose. Where we rely on consent, you have the right to withdraw it at any time by contacting us, as set out in the “Your Rights Relating to Your Personal Data” and “How to Contact Us” sections below.
• Legal bases in respect of Sensitive Data: Where we process Sensitive Data (as described in this Privacy Policy), we are required to identify an additional legal basis under Article 9 of the UK GDPR, as described above.

 

WHO WE SHARE YOUR PERSONAL DATA WITH.

Categories of recipients.

By submitting your Personal Data to us, you acknowledge that certain third parties, such as those set out below, may receive and process your Personal Data:

• Fund associates and subsidiaries, related parties and members of our corporate group
• Our service providers (including our IT, infrastructure and other service providers)
• Our advisers (such as our lawyers, auditors, insurers, tax advisers and other advisers)
• Fund managers, depositories, administrators, custodians and investment advisors
• Public authorities and regulators
• Law enforcement agencies
• Courts or tribunals
• Potential acquirers

We will only share your Personal Data with third parties (such as those included above) in connection with the purposes for which we use your Personal Data as set out in this Privacy Policy.

Where it is necessary for the performance of our obligations to you, or in order to pursue our legitimate interests in operating our business, we may share your Personal Data with third parties who reasonably require it in order to perform a function for you or provide a service to us - such as IT hosting and support, email delivery and database management services.

It may also be necessary to share your Personal Data in order to comply with our legal or regulatory obligations (such as our anti-money laundering and know-your-client obligations), to carry out an internal or independent investigation, to enforce any agreement we have with you or a related party, or to protect the rights, property or safety of Primary, our staff or our investors. This includes exchanging Personal Data with other organisations for the purposes of fraud protection and prevention.

We may further share your Personal Data with auditors, advisers, law enforcement bodies or other entities for the purpose of establishing or defending our legal rights, complying with applicable law, or carrying out an internal or independent investigation.

We may also share your Personal Data in connection with a corporate reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or capital.

International transfers of your Personal Data.

It will sometimes be necessary for us to transfer your Personal Data outside the UK and/or the European Economic Area (“EEA”) to our affiliates, service providers and other third parties, or for your Personal Data to be accessed by staff operating outside the UK/EEA who work for us or for one of our suppliers. We will ensure that any such transfer or access is carried out in accordance with this Privacy Policy and the Data Protection Legislation. Where required by Data Protection Legislation, we will put in place appropriate contractual arrangements with such entities. Please contact us if you would like to know more about these agreements – please contact us using the details set out in the “Your Rights Relating to Your Personal Data” and “How to Contact Us” sections below.

 

HOW WE KEEP YOUR PERSONAL DATA SECURE.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. However, whilst we will take all reasonable steps to protect your Personal Data, we cannot guarantee the security of any Personal Data you disclose online.

We limit access to your Personal Data to those employees and other persons who have a business need for such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breaches or incidents. These include a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. In the event of any such breach, we have systems in place to work with applicable regulators where necessary and/or required. In addition, in certain circumstances (including where we are legally required to do so), we will notify you of breaches affecting your Personal Data.

 

HOW LONG WE STORE YOUR PERSONAL DATA.

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected or received it (including to satisfy any legal, accounting or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes) and, in any event, only for as long as Data Protection Legislation and our own internal rules and policies allow.

To determine the appropriate retention period for your Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, as well as the applicable legal requirements.

 

YOUR RIGHTS RELATING TO YOUR PERSONAL DATA.

You have certain rights in relation to your Personal Data. Under certain circumstances, by law you have the right, subject to certain exemptions, to:

• Request certain information. This enables you to, in certain circumstances, request information about the processing, including the identity of the data controller, the purpose of the processing and any proposed disclosure to another party/transfer of the data abroad.
• Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you, and to check that we are lawfully processing it.
• Request the rectification of your Personal Data. This enables you to have any inaccurate Personal Data we hold about you corrected.
• Request the erasure of your Personal Data. This enables you to ask us to delete or remove your Personal Data (or part thereof).
• Object to our processing of your Personal Data. This enables you to ask us to stop processing your Personal Data.
• Withdraw your consent to our processing of your Personal Data. You may withdraw your consent you may have given to us to hold and use your Personal Data.
• Request the transfer of your Personal Data. This enables you to ask us to provide to you, or a third-party you have chosen, your Personal Data in a structured, machine-readable format.
• Request the restriction of our processing of your Personal Data. This enables you to ask us to restrict the processing of your Personal Data.
• Make a complaint to us in accordance with the “Complaints” section below if you think that we aren’t complying with our obligations regarding your Personal Data.

Please ensure that any Personal Data you provide us with is accurate and complete and you notify us of any changes to your Personal Data as soon as possible so that we can update our records.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (“ICO”) or, if you are an EU data subject, guidance from one of the competent European supervisory authorities.

If you would like to exercise any of those rights, please email, call or write to us at contact@primary.pe or neelm@primary.pe, +44 207 920 4800, or write to the Compliance Officer at the following address: Primary Capital Partners LLP, Augustine House, 6a Austin Friars, London, EC2N 2HA. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded or excessive, we may charge a reasonable fee or refuse to comply.

 

MARKETING

Where you have given us your express consent to do so, or where we otherwise have the right to contact you, we may send you marketing materials, event invitations and industry updates, whether by email or in hard copy.

You may opt out of receiving such communications from us at any time by: (i) contacting us  (please see details under “How to Contact Us” below); (ii) clicking the unsubscribe or opt-out link, to the extent included, at the bottom of any such email we send you; or (iii) where communications are sent by post, sending us a written cancellation request to the address included in those materials.

 

OUR POLICY ON CHILDREN.

Our Site is not intended for children below the age of 16, and we do not knowingly collect data relating to children.

 

THIRD-PARTY LINKS.

Our Site may include links to third-party websites and/or content. Please note that clicking on those links means you will be leaving the Site and accessing another. We do not control these third-party websites and are not responsible for their privacy statements and procedures. When you leave our Site, we encourage you to read the privacy policy of every site you visit.

 

COMPLAINTS

We hope that we can resolve any query or concern you raise about our use of your information. If you have a complaint about how we handle your Personal Data, please contact us in the first instance using the details set out in the How to Contact Us section below.

Where we are acting as a data controller in respect of your Personal Data, we are responsible for handling your complaint. Where we are acting as a data processor on behalf of a data controller, responsibility for handling your complaint rests with that data controller rather than with us. In those circumstances, we will endeavour to pass your complaint on to the relevant data controller so that they are able to deal with it directly, and in any event, we will do so in accordance with our obligations under applicable Data Protection Legislation and any contractual arrangements we have in place with that data controller.

Data Protection Legislation also gives you the right to lodge a complaint with a supervisory authority in the UK or the EU/European Economic Area depending on where you work, normally live or where any alleged infringement of Data Protection Legislation occurred. The supervisory authority in the UK is the ICO who may be contacted at https://ico.org.uk/make-a-complaint/ or by telephone at 0303 123 1113. If you are an EU data subject, you have the right to make a complaint to one of the competent European supervisory authorities.

 

HOW TO CONTACT US

Email, call or write to us at contact@primary.pe or neelm@primary.pe, +44 207 920 4800, or write to the Compliance Officer at the following address: Primary Capital Partners LLP, Augustine House, 6a Austin Friars, London, EC2N 2HA.