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This Policy sets out the obligations of Arlington Capital Ltd, a company registered in England and Wales under number 9578016, whose registered office is at 33 St James's Street, London SW1A 1HD (“the Company”) regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).

In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);

When the data subject withdraws their consent;

When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;

When the personal data is processed unlawfully (i.e. in breach of the GDPR);

When the personal data has to be erased to comply with a legal obligation; or

Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by the Company for communication purposes during the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.

For further information on other aspects of data protection and compliance with the GDPR, please contact the Company’s Data Protection Officer Rosalind Hillyard at


Data Retention

As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.

Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.

When establishing and/or reviewing retention periods, the following shall be taken into account:

The objectives and requirements of the Company;

The type of personal data in question;

The purpose(s) for which the data in question is collected, held, and processed;

The Company’s legal basis for collecting, holding, and processing that data;

The category or categories of data subject to whom the data relates;

If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).



Data Ref.

Type of Data

Purpose of Data

Review Period

Retention Period or Criteria



Contact Details

To enter into Company Database


6 years



Investment history and preferences

To ensure relevance of communication 


6 years



Timeline of contact

To ensure relevance of communication


6 years


If you require further information please contact the Company’s Data Protection Officer at

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