Last updated: 09/02/2026‍

1. Introduction

This privacy policy explains how Sibylla Genesis LLP (“we”, “us”, “our”) collects, uses, stores, and protects personal data, and how individuals can exercise their rights under the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

We are committed to safeguarding the privacy of our website visitors, investors, prospective investors, business contacts, and other individuals whose personal data we process.

2. Who we are

Sibylla Genesis LLP

Registered address: Lake House, Market Hill, Royston, SG8 9JN, United Kingdom
‍Correspondence address: 52 Jermyn Street, London, SW1Y6LX, United Kingdom
Company number: OC457518

For the purposes of data protection law, Sibylla Genesis LLP is the data controller of personal data processed in connection with our business and our website.

3. Personal data we collect

We may collect and process the following categories of personal data:

a) Information you provide to us

  • Name
  • Job title and employer
  • Email address and telephone number
  • Postal address
  • Information provided via contact forms, email correspondence, or meetings
  • Investor or prospective investor information, including suitability and professional status information
  • Any other information you voluntarily provide to us

b) Information collected automatically

When you visit our website, we may automatically collect:

  • IP address
  • Browser type and version
  • Operating system
  • Pages visited and time spent on the site
  • Referring website

This information is typically collected using cookies and similar technologies. See section 11 for further details.

c) Information from third parties

We may receive personal data from:

  • Professional advisers, introducers, or placement agents
  • Fund administrators, custodians, and other service providers
  • Publicly available sources
  • Regulatory or supervisory authorities

4. How we use your personal data

We use personal data for the following purposes:

  • To operate, maintain, and improve our website
  • To respond to enquiries and communicate with you
  • To manage relationships with investors, prospective investors, and business contacts
  • To carry out investor onboarding, due diligence, and ongoing monitoring
  • To comply with legal, regulatory, and compliance obligations, including anti-money laundering and counter-terrorist financing requirements
  • To manage our business operations, including record keeping and internal reporting
  • To protect our rights, property, and legitimate business interests

5. Legal bases for processing

Under UK GDPR, we rely on one or more of the following legal bases to process personal data:

  • Consent – where you have given clear consent for us to process your personal data for a specific purpose
  • Contract – where processing is necessary for the performance of a contract or to take steps at your request prior to entering into a contract
  • Legal obligation – where processing is necessary to comply with applicable laws or regulations
  • Legitimate interests – where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms

6. Data sharing and disclosures

We may share personal data with trusted third parties where necessary, including:

  • Fund administrators and custodians
  • Legal, tax, audit, and compliance advisers
  • IT, hosting, and software service providers
  • Professional advisers, introducers, or placement agents
  • Regulatory, supervisory, or law enforcement authorities where required by law

All third parties are required to process personal data securely and in accordance with applicable data protection laws.

7. International transfers

Personal data may be transferred to, and processed in, countries outside the UK where we or our service providers operate.

Where such transfers occur, we ensure appropriate safeguards are in place, such as:

  • UK adequacy regulations
  • International Data Transfer Agreements (IDTAs)
  • Standard contractual clauses and appropriate risk assessments

8. Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements.

Retention periods are determined based on:

  • The nature of the data
  • Legal and regulatory obligations
  • Business and operational requirements

When personal data is no longer required, it is securely deleted or anonymised.

9. Your rights

Under UK GDPR, you have the right to:

  • Request access to your personal data
  • Request correction of inaccurate or incomplete data
  • Request erasure of your personal data, in certain circumstances
  • Request restriction of processing
  • Object to processing based on legitimate interests
  • Request data portability
  • Withdraw consent at any time, where processing is based on consent

To exercise any of these rights, please contact us using the details in section 13.

10. Security of personal data

We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure.

These measures include access controls, secure IT systems, and internal data protection policies.

11. Cookies and website analytics

Our website may use cookies and similar technologies to improve functionality and analyse usage.

Cookies may include:

  • Strictly necessary cookies
  • Analytics or performance cookies

Where required, we will obtain your consent before placing non-essential cookies on your device. Further details are provided in our cookie policy.

12. Third-party websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites, and we encourage you to review their privacy policies separately.

13. Contact details

If you have any questions about this privacy policy or how we handle personal data, please contact:

Email: info@sibyllagroup.com
Registered address: Lake House, Market Hill, Royston, SG8 9JN, United Kingdom
Correspondence address: 52 Jermyn Street, London, SW1Y 6LX, United Kingdom

14. Complaints

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):

Information Commissioner’s Office
Website: https://www.ico.org.uk

15. Changes to this policy

We may update this privacy policy from time to time to reflect changes in legal requirements or our business practices. Any updates will be posted on this page with an updated “Last updated” date.