Privacy Policy
This Privacy Policy explains how Sugatu Capital (“Sugatu”, “we”, “us”, “our”) collects, uses, and protects your personal data. We are committed to safeguarding your privacy and handling your personal information in accordance with the UK General Data Protection Regulation 2018 (“UK GDPR”), the Data Protection Act 2018 (“DPA”), and all other applicable laws and regulations.
Who We Are
Sugatu Capital is a trading name of AmberHill LLP (FRN: 1034752).
AmberHill LLP is an appointed representative of Thornbridge Investment Management LLP (FRN: 713859), which is authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom.
For the purposes of data protection legislation, Thornbridge Investment Management LLP is the data controller of your personal information.
What Information We Collect
We may collect and process the following categories of personal data:
  • Full name, address, phone number, and email address
  • Date of birth, gender, nationality
  • Identification details (e.g. passport, driver’s licence)
  • Proof of address (e.g. utility bill, bank statement)
  • National insurance or tax identification number
  • Employment and professional details
  • Financial details, including information about your income, assets, liabilities, and source of funds/wealth
  • Trading experience and transaction history
  • Information on your relationship with banks and other financial institutions
  • Records of communications with us (email, telephone, in-person, or otherwise)
  • Information collected from use of our website (including cookies and IP addresses)
We may also collect information from third parties, such as identity verification services, regulators, service providers, or marketing agencies, where permitted by law.
How We Use Your Information
We process your personal data to:
  • Provide you with our investment services and comply with regulatory obligations
  • Carry out customer due diligence, credit and identity checks (as required under anti-money laundering regulations)
  • Maintain records of our business relationship and communications
  • Improve the usability and functionality of our website
  • Provide you with updates, marketing, and information on our products and services (where you have given consent or where we have a legitimate interest)
  • Comply with legal and regulatory requirements
We will not sell, rent, or lend your personal information to third parties. We only share personal data in accordance with this Privacy Policy and applicable laws.
Cookies
Our website uses cookies to improve user experience and analyse site usage. Cookies are small files stored on your device that help us recognise your browser and track website interactions.
  • We use both session and persistent cookies.
  • Third-party cookies may also be used, including Google Analytics.
  • You can block or delete cookies through your browser settings, but this may affect the usability of our website.
For more detail, please see our Cookies Policy (below).
Data Security
We take appropriate technical and organisational measures to protect your personal information against unauthorised access, misuse, alteration, or loss. This includes:
  • Password-protected systems
  • Restricted access to personal data
  • Encryption of data in transit
  • Secure storage for both digital and paper-based records
  • Regular staff training on data protection
Data Retention
We retain your personal data for as long as necessary to meet our legal, regulatory, and business obligations. Typically, this is up to seven years after the end of our relationship, in line with anti-money laundering and regulatory record-keeping requirements.
Transfers Outside the UK / EEA
We may transfer your personal data to service providers or group companies outside the UK/EEA. Where this occurs, we ensure that equivalent safeguards are in place, consistent with UK GDPR.
Your Rights
Under data protection laws, you have the following rights:
  • The right to be informed about how we use your data
  • The right to access the personal data we hold about you
  • The right to have inaccurate data corrected
  • The right to have your personal data erased (“right to be forgotten”)
  • The right to restrict processing of your data
  • The right to object to processing (including marketing)
  • The right to data portability
  • The right to withdraw your consent (where applicable)
To exercise any of these rights, please contact us at info@thornbridge.com.
Complaints
If you are concerned about our handling of your personal data, please contact us first and we will address your concerns promptly.
If you remain unsatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO): https://ico.org.uk
Cookies Policy (Summary)
We use cookies for the following purposes:
  • To recognise your device and browser when visiting our website
  • To track usage patterns and analyse traffic
  • To personalise website content and improve functionality
You can manage cookie preferences through your browser. Blocking cookies may affect website functionality.
For more details on managing cookies:
  • Google Chrome
  • Safari
Sugatu Capital is a trading name of AmberHill LLP (FRN: 1034752). AmberHill LLP is an appointed representative of Thornbridge Investment Management LLP (FRN: 713859) which is authorised and regulated by the Financial Conduct Authority ("FCA") in the United Kingdom