Privacy Policy

1. Who we are (data controller)

Bespokeist Management LLC (“Bespokeist”, “we”, “us”) is located in Delaware, USA. Our group also includes Bespokeist Partners Ltd, a company incorporated in England and Wales. Bespokeist Partners Ltd is the data controller responsible for your personal data for the purposes of the UK GDPR.

We are registered with the UK Information Commissioner's Office (ICO) under registration number ZC200036.

2. Scope of this policy

This policy applies to personal data we collect through this website, namely: (a) information you voluntarily submit through our website form; and (b) information collected automatically through cookies and similar technologies.

3. The personal data we collect

3.1 Information you provide to us

If you choose to submit information through a form on our website, we collect the following personal data:

• Your name;
• Your email address;
• Your telephone number;
• Your company name; and
• Any additional information requested.

Providing this information is voluntary. You do not have to submit it in order to browse the website, but if you do not provide it we may be unable to respond to or contact you.

3.2 Information collected automatically (cookies)

When you visit our website, we and our analytics providers may place cookies and similar technologies on your device. These are described in Section 8 below.

4. How and why we use your personal data, and our lawful basis

Under the UK GDPR we must have a lawful basis to process your personal data. We rely on the following:

4.1 Information you submit through the website form

• Purpose: to respond to your enquiry and to contact you about our services using the details you have provided.
• Lawful basis: your consent (UK GDPR Article 6(1)(a)), which you give by submitting the form. You may withdraw your consent at any time (see Sections 7 and 9). Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

4.2 Analytics cookies

• Purpose: to understand how visitors use our website so we can measure and improve its performance.
• Lawful basis: your consent, obtained through our cookie banner. Setting non-essential cookies also requires consent under PECR (see Section 8).

5. Marketing and how we may contact you

Where you have submitted your details and consented, we may contact you by email or telephone in connection with our services. You can ask us to stop contacting you, or to delete your details, at any time by emailing privacy@bespokeist.vc. You have an absolute right to object to your personal data being used for direct marketing.

6. Where your data is stored and how long we keep it

The personal data you submit through the website form is stored in our secure business database, which is held separately from the website itself. The website does not retain a copy of your submitted personal data.

We keep this information for as long as necessary for the purposes described above, and until you ask us to delete it. When you ask us to remove your information (see Section 7), we will erase all of the personal data you submitted, unless we are required by law to retain certain information.

7. Deleting your information

You may ask us to remove all of the information you have submitted at any time by sending an email to privacy@bespokeist.vc. On receiving a valid request, we will delete your personal data from our database and confirm once this has been done, ordinarily within one calendar month.

8. Cookies and similar technologies

Our website uses the following categories of cookies:

• Strictly necessary cookies: these are essential for the website to function correctly. They do not require your consent, but we tell you about them here.
• Analytics cookies: these help us understand how visitors interact with the website. They are non-essential and are only placed on your device with your prior consent.

When you first visit the website you will be presented with a cookie banner allowing you to accept or reject non-essential (analytics) cookies. You can change or withdraw your cookie preferences at any time through the cookie settings on our website. Under PECR, we must obtain your consent before setting non-essential cookies, and consent must be freely given, specific, informed and indicated by a clear affirmative action.

Note: from 5 February 2026, the Data (Use and Access) Act 2025 amended PECR, including introducing limited new exemptions from the consent requirement for certain low-risk cookies and increasing potential penalties. Our cookie practices are kept under review in line with the latest ICO guidance.

9. Your rights under UK GDPR

Under the UK GDPR you have the following rights in relation to your personal data:

• The right to be informed about how we use your personal data (this policy).
• The right of access to the personal data we hold about you.
• The right to rectification of inaccurate or incomplete personal data.
• The right to erasure (“the right to be forgotten”).
• The right to restrict processing in certain circumstances.
• The right to data portability where processing is based on consent and carried out by automated means.
• The right to object to processing, including an absolute right to object to direct marketing.
• Rights in relation to automated decision-making and profiling. We do not carry out automated decision-making that produces legal or similarly significant effects.
• The right to withdraw consent at any time where we rely on consent.

To exercise any of these rights, please email privacy@bespokeist.vc. We will respond within one calendar month. There is normally no charge for exercising your rights.

10. International transfers

Because Bespokeist Management LLC is located in the USA, your personal data will be transferred to, stored in, or accessed from the United States. Where we transfer personal data outside the UK, we will ensure an appropriate safeguard is in place as required by the UK GDPR — for example, an International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or reliance on UK ‘adequacy’ (data bridge) arrangements where available.

11. Data security

We take appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, misuse or alteration, and we hold your submitted data in a secure database separate from the website.

12. Sharing your personal data

We do not sell, loan or rent your personal data. We may share it within our corporate group and with service providers who process data on our behalf under appropriate contractual protections, or where required by law.

13. Changes to this policy

We may update this policy from time to time. The current version and its “last updated” date will always be available on our website.

14. How to contact us and how to complain

For any privacy question, or to exercise your rights, contact us at privacy@bespokeist.vc.

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk. We would, however, appreciate the chance to address your concerns first.