Privacy Policy

Last updated: June 2026

UKAP Holdings Limited

Company number: 07505002

First Floor, 85 Great Portland Street, London, England, W1W 7LT

ICO Registration: ZA333868

1. Who We Are

UKAP Holdings Limited ("UKAP", "we", "us" or "our") is the data controller responsible for your personal data when you use the UKAP Shareholder Portal. Our Data Protection contact is Malcolm Simmonds, who can be reached at admin@ukapgroup.co.uk.

2. Data We Collect

We collect the following categories of personal data:

  • Identity data: full name and shareholder reference.
  • Contact data: email address and postal address.
  • Holding data: number of shares, certificates and transaction history.
  • Technical data: IP address, browser type, sign-in timestamps and audit logs.

3. How We Process Your Data

We process your data to verify your identity, provide access to the shareholder portal, send statutory communications, maintain accurate shareholder records and comply with our legal obligations under the Companies Act 2006.

4. Data Sharing

We do not sell your data. We share it only with our regulated professional advisors, our authentication and hosting providers acting under contract on our behalf, and where required by law or a competent regulator.

5. Data Storage

Data is stored on secure servers within the UK and EEA. Where data is transferred outside the UK or EEA, we rely on adequacy decisions or appropriate safeguards such as the UK International Data Transfer Agreement.

6. Data Retention

We retain shareholder records for as long as you remain a shareholder and for a minimum of seven years after you cease to be one, in line with statutory record-keeping requirements.

7. Your GDPR Rights

You have the right to:

  • Access the personal data we hold about you.
  • Request correction of inaccurate or incomplete data.
  • Request erasure where there is no compelling reason to keep it.
  • Object to or restrict processing in certain circumstances.
  • Request portability of data you have provided to us.
  • Lodge a complaint with the Information Commissioner's Office (ico.org.uk).

8. Cookies

The portal uses strictly necessary cookies to keep you signed in and maintain session security. No advertising or third-party tracking cookies are used.

9. Security

Access is protected by single-use magic-link authentication, encrypted connections (TLS) and audit logging. We review access controls on an ongoing basis.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified to you by email or via a notice in the portal.

11. Contact

For any privacy enquiry, please contact:
Malcolm Simmonds, Data Controller
UKAP Holdings Limited, First Floor, 85 Great Portland Street, London, W1W 7LT
admin@ukapgroup.co.uk