Privacy Notice

Last update: September 18, 2025

Rosebud Capital Investment Ltd (“Rosebud,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information of individuals (“you,” “your,” or “user”) who interact with us. This Privacy Policy (“Policy”) applies to information we collect on our website (rosebudcapital.co.uk), our digital platforms, and other channels owned or controlled by Rosebud (collectively, the “Website”).This Policy describes the categories of personal information we obtain, the ways in which we use such information, the legal bases on which we rely, the circumstances under which we may share it, and the rights available to you under applicable law.

Information We Collect

Rosebud may collect personal information in the following categories:
• Contact information – name, postal address, email address, and telephone number.
• Account and login information – usernames, passwords, and settings to access Rosebud platforms.
• Financial and trading activity data – information relating to trading activity, allocation frameworks, or performance data shared voluntarily through our educational tools.
• Professional information – CVs, employment history, partnership applications, or other professional interactions.
• Demographic and preference information – data you provide through forms, surveys, or communications.
• Technical and device data – IP address, device identifiers, browser type, operating system, location data, and browsing behaviour.
• Usage and interaction data – number and frequency of visits, content viewed, referral sites, links clicked, email open rates.
• Recruitment and employment data – if you apply for a role, we may collect details about your education, work eligibility, and references.
• Other information – any data you voluntarily provide when engaging with us.
We may also obtain data from third-party sources such as analytics providers, trading platforms, business partners, and public records, and combine it with the information we collect directly.

How We Use Personal Information

We may process personal information for the following purposes:
• To provide educational resources, tools, and services.
• To deliver and improve our systems, platforms, and internal processes.
• To communicate with you regarding updates, opportunities, and services.
• To personalise your Website experience.
• To monitor performance within our community and refine our frameworks.
• To conduct analytics, research, and anonymised reporting.
• To maintain Website integrity, prevent misuse, and detect fraud.
• To comply with UK legal and regulatory obligations.To manage recruitment, applications, and partnerships.

Cookies, Tracking, and Analytics

We use cookies, tracking pixels, and analytics tools to collect technical and usage data. This helps us:
1. Recognise your device and remember preferences.
2. Analyse traffic and user interaction with our Website.
3. Improve usability and optimise communications.
4. Measure Website performance and develop new features.
We use both first-party and third-party cookies. Third-party providers include (but are not limited to): Google Analytics, Klaviyo, ManyChat, FX Blue, MyFXBook, Telegram, and Vantage.

Cookie Banner (GDPR + PECR Compliance)
On your first visit to our Website, you will be presented with a cookie consent banner. This allows you to accept or reject non-essential cookies in accordance with the UK GDPR and the Privacy and Electronic Communications Regulations (PECR). You can update your preferences at any time.
If you disable cookies, some Website features may not function properly.

Lawful Basis for Processing

Under the UK GDPR, our lawful bases for processing include:
• Contract – to deliver services or resources you request.
• Legitimate interests – to operate, evaluate, and improve our business while balancing your rights.
• Legal obligations – to comply with applicable laws and regulations.
• Consent – for direct marketing or non-essential cookies, where required.

International Data Transfers

Some of our partners and service providers (e.g., Google, Klaviyo, Telegram, Vantage) are based outside the UK/EEA. Where personal data is transferred internationally, we ensure appropriate safeguards are in place, including adequacy decisions or the UK International Data Transfer Agreement (IDTA) / Standard Contractual Clauses (SCCs), as applicable.

Automated Decision-Making and Profiling

We may use performance monitoring and analytics tools to assess trading behaviour and engagement within our community. These processes are used for research, education, and system development only. We do not rely on automated decision-making that produces legal or similarly significant effects on individuals.

Sharing of Information

We do not sell personal data. We may disclose it in the following circumstances:
• To affiliates, service providers, and partners who support our operations (including Vantage, Klaviyo, FX Blue, MyFXBook, ManyChat, Google, and Telegram).
• To regulators, courts, or authorities when legally required.
• To protect the rights, safety, or integrity of Rosebud, our users, or others.
• In connection with corporate transactions (e.g., merger, acquisition, restructuring).
• With your explicit consent.
Third parties are contractually required to process data in compliance with applicable law.

Data Retention

We retain personal information only for as long as necessary to fulfil the purposes outlined in this Policy, or as required by law. When no longer needed, information will be securely deleted or anonymised.

Security

We maintain appropriate administrative, technical, and physical safeguards to protect personal data against unauthorised access, disclosure, alteration, or destruction.

Children’s Data

Our services are not directed to, and are not intended for, individuals under the age of 18. We do not knowingly collect personal information from children.

Your Rights Under UK GDPR

You have the right to:
• Access – request a copy of your personal data.
• Rectify – correct inaccurate or incomplete data.
• Erase – request deletion of your data, subject to legal exemptions.
• Restrict – limit the processing of your data in certain circumstances.
• Portability – request your data in a structured, machine-readable format.
• Object – object to processing based on legitimate interests or direct marketing.
• Withdraw consent – where processing relies on consent.
To exercise these rights, please contact us at contact@rosebudcapital.co.uk. We may need to verify your identity before fulfilling your request.

Complaints

We encourage you to contact us first so we can address your concerns but if you are dissatisfied with how your data has been handled, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):
www.ico.org.uk

Third-Party Links and Services

Our Website may include links to third-party websites, apps, or plug-ins. These are operated independently and governed by their own privacy policies. Rosebud is not responsible for the content or practices of third-party providers.

Updates to This Policy

We may update this Policy from time to time to reflect changes in practices, law, or technology. Updates will be posted here with a revised effective date.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact:
Rosebud Capital Investment Ltd
Email: contact@rosebudcapital.co.uk
London, United Kingdom
© 2025 Rosebud Capital Investment Ltd. All Rights Reserved.