Privacy Policy

Last Updated: 1 November 2024 | Effective Date: 1 November 2024

Your privacy is fundamental to our business. This policy explains how Little Brick Capital collects, uses, and protects your personal information in accordance with UK GDPR and data protection laws.

1. Introduction

Little Brick Capital Limited ("we", "us", "our") is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

We are registered as a data controller with the Information Commissioner's Office (ICO) and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Data Controller: Little Brick Capital Limited
Contact: info@littlebrickcapital.co.uk
Registered Office Address: 207 Regent Street, London, United Kingdom, W1B 3HH
Company Number: 16582288

2. Information We Collect

2.1 Information You Provide

  • Identity Data: Name, title, date of birth, nationality
  • Contact Data: Email address, telephone numbers, postal address
  • Financial Data: Bank account details, investment amounts, transaction history
  • Tax Data: Tax identification numbers, residency status
  • Verification Data: Passport/ID copies, proof of address, source of funds documentation
  • Investment Data: Investment preferences, risk tolerance, portfolio holdings
  • Communication Data: Correspondence and feedback you provide

2.2 Information We Collect Automatically

  • Technical Data: IP address, browser type, device information, operating system
  • Usage Data: Pages visited, time spent, click patterns, navigation paths
  • Cookie Data: As detailed in our Cookie Policy
  • Location Data: Geographic location based on IP address

2.3 Information from Third Parties

  • • Identity verification services for KYC/AML compliance
  • • Credit reference agencies
  • • Fraud prevention agencies
  • • Public sources (Companies House, electoral register)
  • • Professional advisors acting on your behalf

3. Legal Basis for Processing

We process your personal data under the following legal bases:

Contract Performance

Processing necessary to fulfil our investment services agreement with you

Legal Obligations

Compliance with anti-money laundering, tax reporting, and regulatory requirements

Legitimate Interests

Business operations, fraud prevention, network security, and service improvements

Consent

Marketing communications and optional services (you may withdraw consent at any time)

4. How We Use Your Information

4.1 Service Provision

  • • Managing your investment account and portfolio
  • • Processing investment transactions
  • • Sourcing and acquiring LEGO sets on your behalf
  • • Providing portfolio valuations and performance reports
  • • Managing storage and insurance of your assets
  • • Facilitating asset liquidation when requested

4.2 Compliance and Legal

  • • Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
  • • Tax reporting to HMRC and other authorities
  • • Regulatory reporting and compliance
  • • Fraud prevention and detection
  • • Legal proceedings and dispute resolution

4.3 Communications

  • • Service updates and important notices
  • • Investment opportunities (with consent)
  • • Market insights and research
  • • Customer service and support

5. Data Sharing and Disclosure

We may share your personal data with:

5.1 Service Providers

  • • Storage and logistics partners for asset management
  • • Insurance providers for asset coverage
  • • Banking and payment processors
  • • IT and cloud service providers
  • • Professional advisors (lawyers, accountants, auditors)

5.2 Legal and Regulatory

  • • HMRC for tax reporting
  • • Financial Conduct Authority (if applicable)
  • • Law enforcement agencies
  • • Courts and tribunals
  • • Regulatory bodies and ombudsmen

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections.

Important: We never sell, rent, or trade your personal data to third parties for marketing purposes.

6. International Data Transfers

Your data may be transferred outside the UK/EEA for processing or storage. When we do so, we ensure:

  • • The country has an adequacy decision from the UK government
  • • Appropriate safeguards are in place (Standard Contractual Clauses)
  • • The transfer is necessary for contract performance
  • • You have explicitly consented to the transfer

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data:

  • • Encryption of data in transit and at rest
  • • Secure servers with firewall protection
  • • Access controls and authentication requirements
  • • Regular security assessments and penetration testing
  • • Staff training on data protection
  • • Incident response procedures
  • • Business continuity and disaster recovery plans

8. Data Retention

We retain your personal data for as long as necessary to:

  • • Provide our services to you
  • • Comply with legal and regulatory requirements
  • • Resolve disputes and enforce agreements

Retention Periods

  • Client account data: 6 years after account closure
  • Transaction records: 6 years from transaction date
  • AML/KYC documents: 5 years after relationship ends
  • Marketing preferences: Until consent withdrawn
  • Website analytics: 26 months

9. Your Rights

Under UK GDPR, you have the following rights:

Right of Access

Request copies of your personal data

Right to Rectification

Correct inaccurate or incomplete data

Right to Erasure

Request deletion of your data ("right to be forgotten")

Right to Restrict

Limit how we use your data

Right to Portability

Receive your data in a portable format

Right to Object

Object to processing for direct marketing

To exercise any of these rights, contact us at: info@littlebrickcapital.co.uk

You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk

10. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from children. If you are under 18, please do not provide any personal information to us.

11. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of any material changes by:

  • • Posting the new policy on our website
  • • Sending you an email notification
  • • Updating the "Last Updated" date

Your continued use of our services after changes constitutes acceptance of the updated policy.

12. Contact Information

For questions about this privacy policy or to exercise your data rights, contact our Data Protection Officer:

Data Protection Officer

Little Brick Capital Limited

Email: info@littlebrickcapital.co.uk

Registered Office Address: 207 Regent Street, London, United Kingdom, W1B 3HH

Company Number: 16582288

Response Time: We aim to respond to all data protection inquiries within 30 days.