Privacy Policy

1. Who we are

For the purpose of this Privacy Notice, “you” or “your” means any end user accessing the website, and “we”, “us”, “our” or “EWI Capital” means EWI Capital Limited, company number 06535573 with our registered office address at New Arch House, 57b Catherine Place, London, SW1E 6DY.

2. Processing personal data
   • By using or accessing the website, https://www.ewicapital.com/ (Website), communicating with us and/or in purchasing our products and/or services, you understand and agree that we will collect and process your personal data in accordance with this Privacy Notice. If you do not agree with this Privacy Notice you must not access or use our Website.
   • This Privacy Notice gives you information about how we collect and use your personal data through your use of our Website, including any personal data you may provide when you contact us via email, phone, or when using the ‘contact us’ form on our Website (Contact Us).
   • Please read this Privacy Notice carefully to understand our practices regarding our processing of your personal data, including how we collect, use and protect it.
   • Our Website is not intended for children and we do not knowingly collect data relating to children.
   • EWI Capital is the data controller and is responsible for your personal data as set out in this Privacy Notice.
3. Personal Data we collect
   • Personal data means any information about an individual from which that person can be identified.
   • We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name and last name;
• Contact Data includes email address, where provided, phone number; and
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website, and/or some of our services.
• Usage Data includes information about how you interact with and use Our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our Website to help improve the Website and our service offering.

4. How we collect your information
   • We use different methods to collect data from and about you including through:
     • Your interactions with us. You may give us your personal data by filling in our contact form or by corresponding with us by post, phone, email or otherwise.
     • Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy https://www.ewicapital.com/cookies for further details.
     • Technical Data is collected from your device and interaction with our Website, including information about your browser, device, and how you access our Website. This data may be generated by website functionality and security services used to protect the site and ensure proper operation.

5. How we use your information
   • Legal basis: we are required to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
     • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
     • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
     • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.
   • Purposes for which we will use your personal data: We have set out in the table below, a description of how we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis and retention period
To respond to customer enquiries	(a) Identity (b) Contact	Legitimate interests – to receive and respond to prospective or actual client enquiries (e.g. responding to questions about our services or requesting further information). We will retain this data for 12 months after the enquiry is resolved, unless it leads to a customer relationship.
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Notice. (b) Dealing with your requests, complaints and queries.	(a) Identity (b) Contact	(a) Necessary to comply with a legal obligation. (b) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you. We will retain this data for the term of our contract with you, and for 6 years thereafter.
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical Data	Legitimate interests – to ensure website security, prevent abuse, and maintain proper functioning when contacting us (e.g. detecting spam or malicious submissions using server logs and security cookies). We will retain this data for up to 12–24 months, unless required longer for security investigations.
To use data analytics to improve our Website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.	(a) Technical (b) Usage	Legitimate interests – to understand how users interact with Our Website and improve functionality (e.g. number of visits to the contact page or form submission rates). We will retain this data for up to 24 months, in aggregated or anonymised form where possible.
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you.	(a) Identity (b) Contact (c) Technical (d) Usage (f) Marketing and Communications	legitimate interests – to carry out direct marketing, develop our products/services and grow our business. Consent – having obtained your prior consent to receiving direct marketing communications from any third party We will retain this data for 12-24 months.

• Third–party marketing: We will obtain your express consent before we share your personal data with any third party for their own direct marketing purposes.

6. Opting out of marketing
   • You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at information@ewicapital.com.
7. Cookies

For more information about the cookies we use and how to change your cookie preferences, please see https://www.ewicapital.com/cookies

8. Disclosures of your personal data
   • Your personal data may, for the purposes set out in this Privacy Notice, be disclosed for processing to:
     • third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them;
     • to any third party where such disclosure is required in order to enforce or apply any contracts we have in place, or to protect the rights, property, or safety of EWI Capital, our customers, our employees or contractors, or others but always in accordance with applicable laws; and/or
     • protect the rights, property or safety of EWI Capital, our customers, our employees, our contractors, or others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.
   • We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable law.
9. International transfers
   • Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented by implementing appropriate safeguards. These may include:
     • entering into contractual agreements that impose strict data privacy and security obligations (e.g. the European Commission’s Standard Contractual Clauses or the International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses). You may request a copy of these safeguards by contacting us;
     • applying technical and organisational security measures (such as encryption, access controls, and data minimisation protocols);
     • conducting data transfer risk assessments or legal evaluations, where required under applicable laws; and/or
     • relying on the explicit consent of the individual, where permitted or required under relevant law.

10. Data security
    • We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
    • We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
    • We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
    • We believe that we have appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
11. Data retention
    • We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
    • To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
    • By law we must keep basic information about our customers for six years after they cease being customers for tax and legal/litigation purposes.
    • In some circumstances you can ask us to delete your data: see paragraph ‎12 below for further information.
12. Your legal rights
    • You have a number of rights under data protection laws in relation to your personal data.
    • You have the right to:
      • Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
      • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
      • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
      • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
      • You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting Out of Marketing in paragraph 6 for details of how to object to receiving direct marketing communications).
      • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
      • Withdraw consent at any time where we are relying on consent to process your personal data (see the table above for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
      • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    • If you want us to establish the data’s accuracy;
    • Where our use of the data is unlawful but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
      • If you wish to exercise any of the rights set out above, please contact us via email as per the contact details in paragraph

13. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

14. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

15. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

16. Contact details

If you have any questions about this Privacy Notice or about the use of your personal data or if you want to exercise your privacy rights, please contact us via:

• Email: information@ewicapital.com ; or
• Post: New Arch House, 57b Catherine Place, London, SW1E 6DY.

17. Changes to the privacy notice and duty to inform us of changes
    • We keep our Privacy Notice under regular review. This version was last updated in May 2026.
    • It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
18. Third-party links

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the Privacy Notice of every website you visit.

 

19. Complaints

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can make a complaint by contacting us.