Privacy Policy
We ask that all users of our website ("you" and its derivatives) read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
This website privacy policy is divided into the following sections:
- Who we are
- Our website
- Our collection of your Personal Data
- Our use of your Personal Data and legal basis for processing
- Who we share your Personal Data with
- Transfer of your Personal Data out of the United Kingdom or EEA
- How long we keep your Personal Data
- Cookies and similar technologies
- Your rights
- Keeping your Personal Data secure
- How to complain
- Changes to this website privacy policy
- How to contact us
Who we are
This website is operated by Drakewood Capital Management Limited (hereinafter “DCM”, “we”, “us”, “our”). We are a commodity investment specialist with a complementary mix of commodity hedge funds and fabrication businesses.
We collect, use and are responsible for certain personal information about you (referred to as “Personal Data” within this privacy policy). We process your Personal Data in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation 2016/679 (“GDPR”), the GDPR as it forms part of the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018 (“UK GDPR”), the Data Protection Act 2018 (“Data Protection Laws”), and other applicable data protection laws in the territories in which we operate. We are responsible as ‘controller’ of that Personal Data for the purposes of those Data Protection Laws.
Our website
This privacy policy relates to your use of our website, www.drakewood.co.uk only.
Throughout our website, we may link to other websites owned and operated by certain trusted third parties. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.
Our collection of your Personal Data
We collect Personal Data about you when you access our website, register with us, contact us, or send us feedback.
We collect this Personal Data from you either directly, such as when you register with us or contact us, or indirectly, such as your browsing activity while on our website (see “Cookies” below).
The Personal Data we collect about you depends on the particular activities carried out through our website. Such information is:
- your name, date of birth, address and contact details (“Contact Data”);
- bank account and payment details (“Financial Data”);
- details of any feedback you give us by phone, email, post or via social media (“Feedback Data”);
- information about the services we provide to you (“Services Data”);
- your account details, such as username, login details (“Account Data”); and
- online identifiers (such as your IP address), device information and information about your visit to our website (including URLs, page interaction information and methods used to leave our website) (“Device and Usage Data”)
Our use of your Personal Data and legal basis for processing
When we use your Personal Data, we are required to have a legal basis under Data Protection Laws for doing so. We process your Personal Data for the following purposes and in reliance on the following legal bases:
| Personal Data | Purpose of processing | Legal basis for processing |
|---|
| Contact Data | Create and manage your account with us | Legitimate interests in establishing and operating your account. |
| Verify your identity | Legitimate interests in ensuring enquiries are genuine. |
| Provide services to you | Compliance with legal obligations before entering a contract. |
| Notify you of service changes | Legitimate interests in running and administering our business. |
| Keep you informed | Legitimate interests in keeping you updated. |
| Financial Data | Provide services to you | Legitimate interests Being our legitimate interest in running and administering our business. |
Contract To provide services to you in accordance with our contract with you. |
| Feedback Data | Improve our services | Legitimate interests Being our legitimate interest in improving the services we provide to you and others. |
| Services Data | Provide services to you | Legitimate interests Being our legitimate interest in running and administering our business. |
Contract To provide services to you in accordance with our contract with you. |
| Account Data | Create and manage your account with us | Legitimate interests Being our legitimate interest in communicating with you and developing the relationship between us in the context of establishing and operating your account. |
| Provide services to you | Legitimate interests Being our legitimate interest in running and administering our business. |
Contract To provide services to you in accordance with our contract with you. |
| Device and Usage Data | Customise our website and its content to your particular preferences | Consent We will only collect your personal data if you have given clear consent. |
Legitimate interests Being our legitimate interest in ensuring our website presents information to you in a user- friendly way. |
| Improve our website | Consent We will only collect your personal data if you have given clear consent. |
Legitimate interests Being our legitimate interest in ensuring our website functions efficiently and to improve your experience on our website. |
This website is not intended for use by children and we do not knowingly collect or use Personal Data relating to children.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. In such circumstances, we are entitled to suspend or terminate our contract with you.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will obtain your consent where required.
We do not carry out automated decision-making or profiling in relation to your Personal Data.
Who we share your Personal Data with
With regards to the Personal Data we process in connection with using the website, we will only disclose any Personal Data you submit to us if this is required for the purposes of service administration, to enable us to maintain and operate the website, as well as to collect traffic data.
Otherwise, and in connection with our provision of the services, we may share your Personal Data with the following categories of recipients as necessary for the purposes set out in this website privacy policy:
- representatives, agents, custodians, administrators, intermediaries and/or other third-party product providers appointed by a Fund or other client (such as accountants, professional advisors, custody service providers and product providers);
- third party agents and contractors for the purposes of them providing services to us, Funds and other clients (for example, our accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies and debt collectors);
- any depository, clearing or settlement system, counterparties, dealers and others where disclosure of your personal data is reasonably intended for the purpose of effecting, managing or reporting transactions;
- where you are a joint account or portfolio holder (or otherwise one of multiple persons holding an account or portfolio), we may disclose your personal data to the other joint account or portfolio holder or other person;
- any regulatory, supervisory or governmental authorities to the extent we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud;
- other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity; and
- any successor in interest, in the event of a liquidation or administration of DCM.
Transfer of your Personal Data out of the United Kingdom or EEA
We may transfer your Personal Data to countries which are located outside the United Kingdom or the European Economic Area (“EEA”). Where we do so, we will ensure that such transfer is performed in accordance with Data Protection Laws.
Such countries may not have the same or equivalent Data Protection Laws to those in the United Kingdom and the EEA. Where the Information Commissioner's Office and/or the European Commission (as applicable) have not given a formal decision whether these countries provide an adequate level of data protection similar to those which apply in the United Kingdom and/or the EEA (as applicable), any transfer of your Personal Data will be subject to appropriate safeguards. This may include entering into standard data protection clauses approved by the Information Commissioner's Office and/or the European Commission (as applicable). Data Protection Laws are designed to help safeguard your privacy rights and provide you with remedies in the unlikely event of the misuse, loss or other damage of or to your Personal Data.
How long we keep your Personal Data
We will only keep your Personal Data for as long as required for the purposes for which it was collected, or as required to comply with or enforce our legal rights under Data Protection Laws.
Cookies and similar technologies
DCM sets and accesses cookies and similar technologies (referred to here as cookies) on your device to obtain information about how you access and use our website. This helps us to provide you with a good experience and allows us to improve the website. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website during your browsing session or on each subsequent visit, or to another website that recognises that cookie. The cookies we set do lots of different jobs, like help us to improve the website and deliver a better and more personalised service, remember your preferences and generally improve the user experience. Personal Data may be processed when cookies are deployed. This data can include information such as IP addresses, browser type, operating system, and browsing behaviour.
The Personal Data collected via cookies may be used to track your activity on our website, target content and advertisements to you based on your online activity and personalise your experience. For instance, tracking cookies help us understand which pages you visit and how much time you spend on them, allowing us to tailor content and suggestions to your interests. Targeting cookies enable us to serve ads that are more relevant to you, and personalisation cookies remember your preferences to provide a seamless browsing experience. Moreover, security and performance cookies are used to ensure the security and integrity of our website and monitor and improve website performance.
We rely on legitimate interests for placing strictly necessary cookies when you visit our website (such as security cookies) and seek your consent for placing optional cookies when you visit our website (such as tracking, targeting and personalisation cookies).
Please refer to our Cookie Policy for more information about our use of cookies, when we will request your consent before placing them and how to disable them.
For further information on cookies generally, including how to manage cookies on popular browsers, visit www.aboutcookies.org or www.allaboutcookies.org.
Your rights
Under Data Protection Laws, you have a number of important rights, which you may exercise free of charge. In summary, those include rights to:
- access to your Personal Data and to certain other supplementary information that this privacy policy is already designed to address;
- require us to correct any mistakes in your Personal Data which we hold;
- require the erasure of Personal Data concerning you in certain situations;
- receive the Personal Data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that Personal Data to a third party in certain situations;
- object at any time to processing of Personal Data concerning you for direct marketing;
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
- object in certain other situations to our continued processing of your Personal Data;
- otherwise restrict our processing of your Personal Data in certain circumstances; and
- withdraw your consent at any time (to the extent we are processing your Personal Data based on your consent).
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on an individual’s rights under the UK GDPR at https://ico.org.uk/for-the-public/.
If you would like to exercise any of those rights, please email or write to us, using the contact details set out below under “How to contact us”, providing us with:
- enough information to identify you (e.g., account number, username, registration details);
- proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- details regarding the Personal Data to which your request relates.
Keeping your Personal Data secure
We have appropriate security measures in place to prevent Personal Data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your Personal Data to those who have a genuine business need to know it. Those processing your Personal Data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you raise about our use of your Personal Data and ask that you contact us to resolve any concerns in the first instance.
Data Protection Laws also give you right to lodge a complaint with a supervisory authority, in particular, in the European Union (or European Economic Area), the local data protection authority in the country where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the United Kingdom is the Information Commissioner's Office who may be contacted at:
Water Lane,
Wycliffe House Wilmslow,
Cheshire SK9 5AF,
e-mail: [email protected] ,
website: https://ico.org.uk/concerns/ ,
helpline 0303 123 1113 .
Changes to this website privacy policy
This website privacy policy was last updated on 2 April 2025.
We may change this website privacy policy from time to time. Any changes we may make to this website privacy policy will be posted on this page. You should review this page regularly to ensure you understand how we collect, use and process your Personal Data. Any changes we may make to this website privacy policy will be effective from the date on which those changes have been posted on this page.
How to contact us
Please contact us if you have any questions about this privacy notice or the Personal Data that we hold about you.
If you wish to contact us, please send an email to [email protected] or write to
Drakewood Capital Management Limited at
16 Great Queen St,
London WC2B 5AH,
United Kingdom.
