PRIVACY POLICY

This privacy policy sets out how New North Litigation Capital Investment Advisers Limited (New North, we, us or our) uses and protects your personal data.

1. Purpose of this privacy policy

This privacy policy gives you information about how New North collects and uses your personal data through your use of this website and when you engage with us to use the services that New North provides.

This website is not intended for children, and we do not knowingly collect data relating to children.

New North is the controller and responsible for your personal data.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes name, title, job title, and employer details.
• Contact Data includes address, email address and telephone numbers.
• Know Your Client/KYC Data includes documents to allow us to carry out checks in compliance with anti-money laundering laws, such as your passport and driver’s licence. We may also carry out these checks on the relevant party to any litigation whose claim we are considering funding.
• Technical Data includes internet protocol (IP) address.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Personal data relating to litigation/claims

When providing our services, we may be provided with and process personal data relating to individual claimants or defendants, witnesses, and other individuals who are involved in a claim that is being considered for funding or that has received funding (“Claim File Data”). We process this personal data to assist us in determining the merits of a claim. 

Claim File Data may include special categories of personal data about individuals (this includes details about an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, genetic and biometric data, and details of criminal offences).

We anticipate that Claim File Data will usually be subject to legal professional privilege, which will mean such data will not be subject to all of the rights given to data subjects as set out in section 9 of this policy. We will confirm this to the relevant data subject on a case-by-case basis.   

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  
• apply for our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. As outlined above, we may receive Claim File Data and various personal data from entities (such as law firms) seeking to use our services. In addition, we may collect personal data from credit reference and fraud prevention agencies, websites, Companies House, the Electoral Register, financial institutions, advisors and consultants, sanctions lists, and due diligence providers, among others. 

If you provide information to us about any person other than yourself or your employees, you must ensure that you have the authority (including a lawful ground) under the applicable data protection laws to share any personal data with us for the purpose of the services we are providing.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure client experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Legal basis
Establishing a client relationship	(a) Performance of a contract with you
Conducting checks to identify you and verify the identities of those seeking our funding (including law firms/claimants),  to help prevent and detect fraud, crime, and money laundering	(a) For our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us
Claim File Data: Assessing the merits of a claim,	Claim File Data will only be used in relation to assessing the merits of a claim. Subject to the rights of data subjects set out below (to the extent they apply), the legal basis we will rely upon to use Claim File Data will be: (a) Use of the personal information is necessary for our legitimate interests of providing litigation funding. (b) In the case of special category data, such use is necessary for the establishment, exercise or defence of a legal claim.
To manage our relationship with you which will include: (a) Dealing with your requests, complaints and queries (b) Communication with you and sending you updates (c) Notifying you about changes to our privacy policy	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To send you relevant marketing communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business)

Direct marketing

When you contact us via our website, your personal data is collected..

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see Cookie Policy.

5. Disclosures of personal data

We may share your personal data where necessary with the parties set out below:

• With our affiliates for the purposes of providing you with our services.
• Third party professionals such as expert witnesses, corporate finance advisers, tax advisors, solicitors or barristers, , where we are instructing them, in particular where they have been instructed to assist with due diligence in relation to our services.
• Credit reference agencies and fraud prevention agencies.
• Any prospective buyer or seller (and their representatives) in the event that we sell or buy any business or assets.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within our group for the purpose of providing the services. This will involve transferring your data outside the UK to our affiliate in Jersey.

From time to time, we may need to transfer personal data to other countries (which may include countries outside the UK or the European Economic Area (EEA)). This can include countries where we do business, which are linked to your engagement with us or where our third parties conduct activities. These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements.

When we, or our permitted third parties, transfer your personal data outside the UK or the EEA, we will take reasonable steps in accordance with the applicable data protection requirements to ensure the protection and security of your personal data to the standard required in the UK:

• use of approved contractual clauses; and
• ensuring that we only transfer your personal data to persons or entities that are appropriately authorised and/or accredited to process personal data in compliance with applicable data protection requirements.

By submitting your personal data to us in accordance with this Policy you consent to these transfers for the purposes specified in this Policy.

7. Data security

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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for 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, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

9. Your legal rights

If you are an individual (a data subject), this section sets out your legal rights in respect of any of your personal data that we are holding and/or processing. If you wish to exercise any of your legal rights you should put your request in writing to us (using our contact details below) giving us enough information to identify you and respond to your request. You have the right (in certain circumstances):

• to request access to information about personal data that we may hold and/or process about you, including: whether or not we are holding and/or processing your personal data; the extent of the personal data we are holding; and the purposes and extent of the processing;
• to have any inaccurate information we hold about you be rectified and/or updated. If any of the personal data that you have provided changes, or if you become aware of any inaccuracies in such personal data, please let us know in writing giving us enough information deal with the change or correction;
• in certain circumstances to request that we delete all personal data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the personal data for legal compliance purposes. If this is the case, we will let you know;
• in certain circumstances to request that we restrict the processing of your personal data, for example where the personal data is inaccurate or where you have objected to the processing (see below);
• to request a copy of the personal data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you we will let you know;
• in certain circumstances to object to the processing of your personal data. If so, we shall stop processing your personal data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing then we will let you know;
• in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you we will let you know; and
• to object to direct marketing.

If you wish to exercise any of the rights set out above or have any other queries or concerns, please don’t hesitate to contact us at info@newnorthlc.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: info@newnorthlc.com
• Postal address: Ty Capital 104d St. John Street, Clerkenwell, London, United Kingdom, EC1M 4EH.

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 4^th August 2025.

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, for example a new address or email address.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.