Privacy Policy
Effective date: 1 September 2026
This privacy policy explains how the counting room, trading and actively maintained under the developer name SadaCapital for the benefit of SADA CAPITAL INVESTMENTS LTD, collects, uses, shares and protects personal information. The registered company behind the work is SADA CAPITAL INVESTMENTS LTD, with a registered address at 17 Woodland Road, Seaforth, LIVERPOOL - L21 1DY, United Kingdom (GB). Throughout this document the terms the Company, we, us and our refer to SADA CAPITAL INVESTMENTS LTD. We are committed to protecting the personal information entrusted to us and to handling it fairly, transparently and lawfully under the data protection law of the United Kingdom, including the UK General Data Protection Regulation and the Data Protection Act 2018.
SADA CAPITAL INVESTMENTS LTD acts as a private investment holdings and portfolio administration house. Keeping the books of our clients properly means treating the information behind those books with the same care we apply to a signed ledger entry. This policy records in plain language what personal information we hold, why we hold it, how long we keep it and what rights you have over it. We do not sell your personal data. We do not use your personal data to build advertising profiles about you. We collect only the information that the services we run genuinely require, and we keep the collection as narrow as the task allows.
The developer name SadaCapital identifies the team that designs and operates the counting room services described on this website. Whether you encounter us as SadaCapital or as SADA CAPITAL INVESTMENTS LTD, the same company, the same address and the same data protection commitments apply to everything set out below.
The data controller for personal information collected through this website and through our services is SADA CAPITAL INVESTMENTS LTD. The company is registered and operates from the following address:
SADA CAPITAL INVESTMENTS LTD
17 Woodland Road
Seaforth, LIVERPOOL - L21 1DY
United Kingdom (GB)
You can reach the data protection contact at the reply address below. All privacy requests, questions and complaints should be sent to this address so they reach the correct desk:
Email: reply@sadacapital.lat
Phone: +17167703280
This policy applies to personal information we process in connection with the website at the domain used by this service, our contact channels, our portfolio administration and reporting services, and any correspondence you have with our counting room. It explains how we handle information when you browse this site, when you complete the contact form, when you write to us by email, when you telephone the room, and when you enter into or consider a mandate with SADA CAPITAL INVESTMENTS LTD for portfolio administration, investment research, investor reporting, capital structuring, risk monitoring or custody coordination.
This policy does not cover the practices of independent custodians, banks, regulators, brokers or any other organisation you deal with separately, even where we coordinate with them on your behalf. Each of those parties has its own privacy obligations, and we encourage you to review their notices as well.
We collect personal information in three broad ways: information you give to us directly, information collected automatically as you use this website, and information we receive from third parties who act as trusted sources for the services you have asked us to provide. Not every category applies to every visitor. A person who simply reads this policy provides far less information than a client whose portfolio we administer, and we treat the two very differently.
In every case we apply the principle of data minimisation: we ask for what we need, we hold what we must, and we do not gather personal information for its own sake. Below we describe each source of information in its own section so you can see clearly where the data comes from.
When you use this website you may choose to give us information directly. The main example is the contact form, where you can provide your name, your email address, a subject line and a message describing your portfolio, your holdings or your question. We use the name and email you provide solely so we can reply to you and so the internal desk knows who the inquiry belongs to.
If you telephone the room, write to the reply address or correspond with us about entering into a mandate, you may provide further information, including information about your holdings, your investment objectives, your risk appetite, your identity documents where law requires them, and details needed to operate custody and reporting on your behalf. We treat all of this as confidential, store it only within the scope of the service and mark it clearly so only the officers who need it can see it.
Like most websites, our site records routine technical information when a browser visits. This can include the internet protocol address of the device, the type of browser used, the operating system, the referring page and the pages visited on this site. We collect this information in a form that lets us understand how the site is performing and where visitors concentrate their attention.
We do not combine this technical information with personal identifiers to track an individual across the internet, and we do not attempt to build a profile of any single visitor from their browsing alone. Where you later identify yourself by completing the contact form we may associate your session with your identity only as far as needed to understand which parts of the site helped you most.
For clients under an active mandate we receive information from independent third parties who hold records about your investments. This includes custodians who send statements and confirmations, depositaries who hold your securities, regulators where required by law, and professional advisers you have authorised to act for you, such as lawyers or accountants.
We also receive information from publicly available sources that we consult during investment research, including issuer filings, company registers and official records. We combine third party information with the records we already hold only to render the service you have agreed to, and we keep the sources noted so the provenance of every figure can be traced later in the same way we would trace a disputed ledger entry.
We use personal information for the following purposes, and for no others without telling you first. We respond to your inquiries and correspondence. We prepare, agree and carry out mandates for portfolio administration, investment research, investor reporting, capital structuring, risk monitoring and custody coordination. We verify your identity where the law or a trusted third party requires us to do so.
We reconcile your holdings against custody statements and, where applicable, compute valuations and prepare the reports described elsewhere on this site. We keep accounting and audit records that the law requires us to retain. We operate, secure and improve this website and our internal systems. We detect and prevent fraud, money laundering and other unlawful activity that affects you, us or our other clients, and we comply with court orders and legal obligations.
We never use personal information for direct marketing without a clear and separate consent, and we do not sell personal information to any third party under any circumstances.
Under the UK General Data Protection Regulation every instance of processing must rest on at least one lawful basis. We rely on several. The first is consent, where you freely agree to a particular use and may withdraw that agreement at any time by writing to the reply address. The second is the performance of a contract, where processing is necessary to carry out a mandate you have entered into with SADA CAPITAL INVESTMENTS LTD.
The third is compliance with a legal obligation, where the law requires us to hold or report certain records, for example for tax, audit or anti money laundering purposes. The fourth is a legitimate interest, where processing is necessary for our own proper administration, security and service quality, provided it does not override your rights and freedoms. Where we rely on legitimate interest we record the assessment so the choice can be reviewed.
We process information only for purposes that are lawful, specific and clearly described. These include carrying out your requests and answering your questions, maintaining accurate records of each mandate, operating the five step reporting tide described on our website that runs from collect through verify and value to report and finally file.
Beyond the direct service we process information to keep our systems and records secure, to establish, exercise or defend legal claims, to meet requirements placed on us by regulators and to provide continuity and support when you contact the room. We keep a written record of the purposes we rely on for each type of information so the file remains audit ready at all times.
SADA CAPITAL INVESTMENTS LTD keeps your personal information within the room wherever that is lawful and practical. We share information with third parties only in clearly defined circumstances. We share with independent custodians and depositaries the instructions needed to hold, settle and value your positions. We share with regulators, tax authorities and the police or courts where the law compels us to do so.
We share with professional advisers, including auditors and lawyers, where necessary to advise us or to establish or defend our legal position. We share with the processors who operate our infrastructure, described in the next section, strictly under contracts that bind them to protect the data. We do not share your information with advertisers, brokers or any party whose interest is to sell you products, and we do not share with any third party for its own direct marketing.
To operate the website and the counting room we use a small number of service providers who process personal information under our instruction. These include providers of web hosting and content delivery, providers of secure email and communication, providers of document storage and backup, and software providers whose tools we use to keep records, reconcile positions and prepare reports.
Every provider we engage signs a contract that binds it to process data only on our documented instructions, to keep the data confidential, to apply security measures comparable to our own and to help us respond to data subjects within the legal time limits. We review our processors on a rolling basis and we do not add a processor where the provider cannot demonstrate the safeguards we require.
Because some of our processors and custodians operate internationally, personal information may be transferred to, stored at and processed in a country other than the United Kingdom. Where we transfer personal information outside the United Kingdom we make sure the transfer is protected by an appropriate safeguard recognised under UK data protection law.
This may mean transferring to a country that the United Kingdom has decided provides an adequate level of protection, or relying on standard contractual clauses that have been issued or approved for use under UK law, together with any supplementary measures the transfer requires. We keep a map of where the data flows so that every transfer can be justified on request.
We keep personal information only for as long as we need it for the purpose it was collected and for any longer period the law requires. Contact inquiries are retained for twelve months so we can answer follow up questions and, where a mandate follows, so the history reads continuously into the client record.
Records connected to an active mandate, including position files, valuations, confirmed statements and reports, are kept for the life of the mandate and then for a retention period that reflects our legal duties, audit needs and the holding periods that apply to the type of instrument in question. After the retention period ends the information is securely deleted or anonymised so it can no longer identify an individual.
We apply security measures appropriate to the sensitivity of the information we hold. Access to client records is limited to the named officers who need it for the service, and every access is logged against the officer who performed it. Systems that store personal information are encrypted at rest and in transit, and access to the counting room tools is protected by strong authentication.
We keep our backup strategy so that records can be recovered after any incident, we test our access controls on a routine cycle, and we review who may reach which file whenever an officer changes role or leaves the room. No method of storage is ever completely secure, but we treat the protection of the ledger as the highest operational priority and we respond promptly to any suspected weakness.
This website uses cookies and similar local technologies for a narrow set of purposes related to making the site work correctly. We use strictly necessary cookies so the site displays correctly and remembers your choices during a single visit. We do not use advertising or profiling cookies on this site.
Where we wish to use analytics that set additional cookies we first obtain your consent through the banner shown on the site, and you may withdraw that consent at any time by clearing your browser cookies. Our detailed cookie notice lists the names and purposes of each cookie we set, and you can control or refuse cookies through the settings of your own browser.
Under UK data protection law you hold a set of rights over the personal information we process about you. You may ask for a copy of the information we hold, correct anything that is inaccurate or incomplete, and ask us to delete information where the law permits. You may ask us to restrict processing, object to processing carried out on the basis of a legitimate interest, and ask that your information be transferred to you or to another controller in a portable format.
These rights are not absolute; in some cases the law lets us keep information where we have a clear legal obligation or a legitimate ground that outweighs your request, and we will always explain our decision if that occurs. You can exercise any right by writing to the contact desk at the reply address given in this policy. We respond to every request within one month and we will not penalise you for making one.
The services of SADA CAPITAL INVESTMENTS LTD are directed at adults who own or control portfolios and at professional advisers. This website is not aimed at children and we do not knowingly collect personal information from anyone under the age of sixteen.
If you believe we have collected personal information about a child by accident, please contact us immediately at the reply address and we will delete the information promptly. The counting room has no reason to hold the personal data of children and we treat any such record as an error to be corrected without delay.
This website may contain links to sites operated by third parties, including custodians, regulators, banks and industry information sources. When you leave this site and follow such a link, the privacy practices of the destination site govern the information it collects from you.
We do not control those third party sites and this policy does not apply once you leave our domain. We encourage you to read the privacy policy of every site you visit so you understand how your information is handled outside the counting room.
We may update this privacy policy from time to time to reflect changes in our services, in the way we operate, or in the law itself. When we make a material change we update the effective date shown at the top of this page and we post the revised policy in this same place so it is easy to find.
Where a change materially affects how we use information we already hold about you, we will tell you directly where we have a reliable way to reach you and, where the law requires, we will ask for your consent to the new use before it begins. Continued use of the site after the new effective date indicates that you accept the revised policy.
If you have a question, a request or a complaint about this privacy policy or about how SADA CAPITAL INVESTMENTS LTD handles your personal information, please contact the desk first. We will investigate every matter seriously and respond within one month.
SADA CAPITAL INVESTMENTS LTD
17 Woodland Road, Seaforth, LIVERPOOL - L21 1DY, United Kingdom (GB)
Email: reply@sadacapital.lat
Phone: +17167703280
If you remain unsatisfied after we respond, you have the right to raise a concern with the Information Commissioner of the relevant jurisdiction in the United Kingdom, which is the supervisory authority responsible for data protection there. You may make a complaint to the authority at any time, although we would value the chance to resolve your concern directly with you first.