Privacy Policy

1. Who We Are

Ascendancy Advisors Limited is a company registered in England and Wales under company number 15179861, with its registered office at Suite RA01, 195 – 197 Wood Street, London E17 3NU, United Kingdom.

For personal information collected through the public Website, enquiries, subscriptions, the Client Portal and AAL's own business administration, AAL is the data controller. This means that we determine why and how that information is processed.

For some client mandates, the parties' respective data-protection roles may be addressed separately in an engagement letter or other written agreement. Where AAL processes personal information solely on a client's documented instructions, the client's privacy notice may also apply.

2. Scope of This Policy

This Privacy Policy applies when you:

• visit the public pages of theaalgroup.com;
• use Ask AAL or another public Website function;
• contact AAL or submit a mandate enquiry;
• request access to, register for or use the private Client Portal;
• subscribe to, download or enquire about AAL publications;
• act for, work with or are connected to a prospective or existing client, supplier, professional adviser or counterparty; or
• are an individual whose personal information is lawfully reviewed in connection with a client mandate, counterparty assessment, compliance review or commercial-intelligence assignment.

This policy does not make confidential mandate information public and does not alter any separate confidentiality, non-disclosure or engagement obligations agreed in writing.

3. Personal Information We Collect

The information we collect depends on how you interact with AAL and may include:

• Contact and professional information: name, business email address, telephone number, organisation, role, jurisdiction and professional profile;
• Enquiry and mandate information: the content of enquiries, transaction background, requested services, correspondence, documents and attachments supplied to us;
• Client Portal information: access-request details, account identifiers, authentication and session information, portal activity, service requests and communications;
• Subscription and publication information: subscription status, publication preferences and records of material requested or downloaded;
• Commercial and administrative information: engagement records, billing and payment status, invoices, contractual records and supplier information;
• Identity, corporate and due-diligence information: identity and verification documents, directorships, beneficial ownership, corporate affiliations, sanctions or watchlist results, litigation or insolvency information, adverse-media references and other transaction-relevant records where necessary for a mandate;
• Technical and usage information: IP address, browser and device type, operating system, referral source, pages visited, access times, security events and similar technical logs; and
• Communications: emails, meeting notes, call records and other business correspondence.

Please do not send personal information that is unnecessary for the purpose of your enquiry or mandate. In particular, do not send passport copies, bank details, medical information or other sensitive material through a general enquiry unless AAL has specifically requested it through an appropriate channel.

4. Information Obtained From Other Sources

AAL may receive personal information from clients, prospective clients, authorised representatives, intermediaries, professional advisers, counterparties and service providers. For mandate-specific work, we may also obtain information from lawful public or commercially available sources, including:

• company, beneficial-ownership, insolvency and court registers;
• regulatory, sanctions, enforcement and public-authority records;
• corporate websites, professional profiles and published reports;
• reputable news, media and commercial databases; and
• documents or explanations supplied by the parties to a transaction.

Where information is obtained indirectly, AAL uses it only where there is a lawful basis and where the processing is necessary and proportionate to the relevant purpose.

5. Special Category and Criminal-Offence Information

AAL does not intentionally collect special category personal information through ordinary public Website use. However, mandate materials or lawful research may occasionally contain sensitive information or information relating to alleged or established criminal conduct.

We process such information only where it is necessary for a defined purpose, an applicable condition under data-protection law is satisfied, and appropriate safeguards are in place. Depending on the circumstances, this may include processing necessary for legal claims, preventing or detecting unlawful acts, protecting against dishonesty, preventing fraud, or meeting applicable regulatory requirements.

AAL does not maintain a general register of criminal convictions and does not carry out consumer credit reporting or employment background screening through this Website.

6. How and Why We Use Personal Information

We may use personal information to:

• respond to enquiries and assess whether a proposed mandate is suitable for AAL;
• take steps requested before entering into a contract or engagement;
• provide agreed advisory, due-diligence, reporting, publication or portal services;
• verify identity, authority, ownership, conflicts and transaction context;
• conduct counterparty, sanctions, fraud-risk and commercial-intelligence reviews within the agreed scope of a mandate;
• manage client, supplier and professional relationships;
• administer subscriptions, access requests, invoices and payments;
• operate, secure, troubleshoot and improve the Website and Client Portal;
• maintain business, compliance, accounting and audit records;
• establish, exercise or defend legal rights and resolve disputes;
• comply with applicable legal, regulatory, court or law-enforcement requirements; and
• send publications or business communications that you have requested or that we are otherwise permitted to send.

7. Lawful Bases

AAL relies on one or more of the following lawful bases, depending on the circumstances:

• Contract and pre-contractual steps: where processing is necessary to respond to your request, assess a prospective engagement, administer a subscription or portal account, or perform an agreement with you;
• Legal obligation: where processing is necessary to comply with applicable company, accounting, tax, court, regulatory or other legal requirements;
• Legitimate interests: where necessary to operate and protect AAL's business, assess prospective mandates and counterparties, prevent fraud and misuse, maintain security, manage professional relationships, conduct proportionate transaction-related research, improve services, or establish and defend legal rights, provided those interests are not overridden by your rights and interests;
• Consent: where you have actively consented, including for non-essential analytics technologies or particular communications where consent is required. You may withdraw consent at any time, without affecting earlier lawful processing; and
• Legal claims or other specific statutory conditions: where additional protection applies to special category or criminal-offence information.

Where AAL relies on legitimate interests, we consider the necessity of the processing, its expected benefit and its potential effect on the individuals concerned.

8. If You Do Not Provide Information

You are not generally required to provide personal information merely to browse the public Website. However, if information is needed to answer an enquiry, verify authority, conduct onboarding, provide portal access, perform an engagement or meet a legal requirement, AAL may be unable to proceed without it.

9. Cookies, Analytics and Similar Technologies

The Website uses essential technologies required for security, functionality and session handling. AAL also uses Google Tag Manager and Google Analytics 4 on public Website pages to understand Website use and performance.

Non-essential analytics technologies are disabled unless and until the visitor provides the required consent. Advertising storage, advertising personalisation and advertising-user-data signals are denied by default, and AAL does not currently use behavioural advertising or remarketing technologies.

Further details, including how to manage preferences, are set out in our Cookie Policy.

10. Publications and Communications

Subscriptions to the Weekly Digest or China Commercial Intelligence Brief may be administered through Substack or another publication platform identified at the point of subscription. That provider may process subscriber information under its own privacy terms as an independent controller or service provider, depending on the activity.

You may unsubscribe from publication emails using the unsubscribe mechanism provided in the relevant communication. Operational messages concerning an active engagement, payment, security or portal account are not marketing communications and may still be sent where necessary.

11. When We Share Personal Information

AAL does not sell personal information. We may disclose personal information only where necessary and proportionate, including to:

• website hosting, secure database, portal, authentication, IT-support and cybersecurity providers;
• analytics and tag-management providers, where the required consent has been obtained;
• email, document-delivery, publication and communications providers;
• payment providers where a client chooses to use an identified payment link or payment service;
• professional advisers, accountants, auditors, insurers and legal representatives subject to appropriate duties of confidentiality;
• the client commissioning a mandate and persons authorised within the agreed scope of the work;
• registries, verification providers or other sources used to confirm submitted information;
• courts, regulators, tax authorities, law-enforcement bodies or other public authorities where disclosure is required or lawfully justified; and
• a prospective purchaser or successor in connection with a genuine corporate restructuring, merger or sale, subject to appropriate confidentiality and data-protection controls.

Service providers are permitted to use personal information only for the contracted purpose and must protect it in accordance with applicable law and their contractual obligations.

12. International Transfers

AAL operates across borders and may use service providers or work with authorised parties located outside the United Kingdom. This may result in personal information being accessed from or transferred to another country.

Where UK data-protection law treats a transfer as restricted, AAL will use an available lawful transfer mechanism, which may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another legally recognised safeguard. We also consider the nature of the information, the purpose of the transfer and the safeguards available in the destination country.

13. Retention

AAL keeps personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, evidential, security and dispute-resolution requirements. Unless a different period is required by law, contract or the circumstances of a mandate, our normal retention periods are:

• General enquiries that do not proceed: up to 24 months after the last meaningful contact;
• Unsuccessful, withdrawn or incomplete portal-access requests: up to 12 months after the request is closed;
• Active portal accounts: for the life of the account and normally up to 24 months after closure, except where linked records must be retained longer;
• Client, mandate, contractual, compliance, invoice and transaction records: normally seven years after the engagement or business relationship ends;
• Subscription and publication records: while the subscription or relationship remains active and normally up to 24 months afterwards;
• Website, access and security logs: normally up to 12 months, unless required longer to investigate an incident or protect legal rights; and
• Cookie and analytics information: according to the periods described in the Cookie Policy and the relevant platform configuration.

Information may be deleted earlier where it is no longer needed, or retained longer where reasonably necessary for litigation, an investigation, a legal hold or another documented lawful reason. AAL may retain anonymised information that no longer identifies an individual.

14. Security and Confidentiality

AAL uses proportionate administrative, technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. Measures may include restricted access, authentication controls, encryption in transit where supported, secure hosting, access logging, backups and confidentiality obligations.

No internet transmission or information system is completely risk-free. You should use the secure channel identified by AAL for sensitive mandate material rather than sending it through a general Website form or ordinary email without prior arrangement.

15. Automated Decision-Making

AAL does not use personal information collected through the Website or Client Portal to make solely automated decisions that produce legal or similarly significant effects. Research tools and screening systems may assist AAL's work, but material mandate conclusions are subject to human review.

16. Your Data-Protection Rights

Subject to applicable law and the circumstances of the processing, you may have the right to:

• request access to your personal information;
• request correction of inaccurate or incomplete information;
• request erasure of information where there is no lawful reason to retain it;
• request restriction of processing in certain circumstances;
• object to processing based on legitimate interests or to direct marketing;
• receive certain information in a portable format where the right applies;
• withdraw consent where processing is based on consent; and
• complain to the Information Commissioner's Office.

These rights are not absolute. AAL may need to retain or withhold information where permitted by law, including to protect another person's rights, preserve legal privilege, prevent or detect unlawful conduct, or establish and defend legal claims.

To exercise a right, contact us using the details below. We may request reasonable information to verify your identity and authority. We normally respond within one month, although the law allows additional time for complex or numerous requests. We do not ordinarily charge a fee.

17. Third-Party Websites and Services

The Website contains links to external platforms and may display third-party content, including Clutch, Substack, LinkedIn, Facebook, X, Google services and payment providers. AAL does not control the privacy practices of an external service once you leave the Website or interact directly with that service. You should review the relevant provider's privacy information before supplying personal information.

18. Children

The Website and AAL's commercial services are directed to business and professional users and are not intended for children. We do not knowingly use the Website to solicit personal information from anyone under 18.

19. Changes to This Privacy Policy

AAL may update this Privacy Policy to reflect changes in law, technology, Website functionality, service providers or business operations. The revised policy will be posted on this page with an updated date. Material changes may also be communicated through an appropriate channel where required.

20. Contact and Complaints

Questions, requests or complaints concerning this Privacy Policy or AAL's handling of personal information should be sent to:

Ascendancy Advisors Limited
Suite RA01, 195 – 197 Wood Street
London E17 3NU, United Kingdom
Company number: 15179861
Email: info [at] theaalgroup [dot] com

You also have the right to complain to the UK Information Commissioner's Office. Further information is available at ico.org.uk/make-a-complaint. We would appreciate the opportunity to address your concern first, but you are not required to contact AAL before approaching the regulator.