Privacy Policy

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.

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.
• Support data: messages and files you choose to send through live chat, together with chat timestamps and related device or connection information.

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.

If you consent to live chat, we process your chat messages to answer enquiries and provide portal support. The lawful basis is your consent to the optional chat service and, where relevant, our legitimate interest in providing effective shareholder support. You can withdraw cookie consent at any time through Cookie settings in the footer.

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.

When you enable live chat, Crisp IM SAS (Crisp) processes chat content and related technical data on our behalf to provide the service. Crisp acts as our service provider and is not permitted to use that information for its own advertising. When you are signed in, your name and email are shared with Crisp so our team knows who they are helping, and your live-chat choice is saved to your account so it applies on every device.

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.

Crisp may process information using infrastructure or service providers outside the UK. Where this involves an international transfer, we rely on appropriate contractual safeguards and applicable UK data-protection transfer mechanisms.

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.

Live-chat records are retained only for as long as needed to handle and document the enquiry, meet legal or regulatory obligations, and resolve disputes, after which they are deleted or anonymised in accordance with our retention arrangements.

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).

The portal uses strictly necessary cookies to keep you signed in and maintain session security. With your consent, it may also use analytics cookies and Crisp live-chat cookies. Crisp does not load unless Marketing consent is granted. See our Cookie Policy for details and use Cookie settings in the footer to change your choice.

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

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.

For any privacy enquiry, please contact:
Malcolm Simmonds, Data Controller
UKAP Holdings Limited, Fifth Floor, 167-169 Great Portland Street, London, W1W 5PF
admin@ukapgroup.co.uk