Privacy policy #3


Exton Advisors respects your privacy and is committed to protecting
your personal data. This privacy notice will tell you how we look after
your personal data when you visit our website (regardless of where you
visit it from) and give you information about your privacy rights and
how the law protects you.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Exton
Advisors Ltd collects and processes your personal data through your use
of this website, including any data you may provide through this website
when you sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any
other privacy notice or fair processing notice we may provide on
specific occasions when we are collecting or processing personal data
about you so that you are fully aware of how and why we are using your
data. This privacy notice supplements the other notices and is not
intended to override them.


Exton Advisors Limited is the controller and responsible for this website.

We have appointed a data privacy manager who is responsible for
overseeing questions in relation to this privacy notice. If you have any
questions about this privacy notice, including any requests to exercise
your legal rights, please contact the data privacy manager using the
details set out below.

Full name of legal entity: Exton Advisors Limited

Name and title of data privacy manager: John Astill, Director

Email address:

Postal address: 5 Wigmore Street, London, W1U 1PB

You have the right to make a complaint at any time to the InformationCommissioner’s Office (ICO), the UK supervisory authority for data
protection issues ( We would, however, appreciate the
chance to deal with your concerns before you approach the ICO so please
contact us in the first instance.

Third-party links

This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may
allow third parties to collect or share data about you. We do not
control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read
the privacy notice of every website you visit. 

The data we collect about you

Personal data, or personal information, means any information about
an individual from which that person can be identified. It does not
include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name and title.
  • Contact Data includes postal address (this may be your home address if you have provided this to us), email address and telephone numbers.
  • Publicly Available Data including information collected from publicly available resources, data bases and credit agencies
  • Legal Data including information about relevant and
    significant litigation or other legal proceedings against you or a
    third party related to you and our interaction with you
  • Technical Data includes internet protocol (IP)
    address, your login data, browser type and version, time zone setting
    and location, browser plug-in types and versions, operating system and
    platform and other technology on the devices you use to access this
  • Profile Data includes your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We may also collect and use Aggregated Data such as statistical or
demographic data for various purposes. Aggregated Data may be derived
from your personal data but is not considered personal data in law as
this data does not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage of
users accessing a specific website feature. However, if we combine or
connect Aggregated Data with your personal data so that it can directly
or indirectly identify you, we treat the combined data as personal data
which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about
you (this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about your health and genetic and
biometric data). Nor do we collect any information about criminal
convictions and offences.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data
by filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:

  • appoint us to advise upon or seek funding for a litigation case;
  • appoint us to arrange, place and administer insurance policies;
  • are a party to a litigation case we are engaged upon;
  • subscribe to our publications;
  • request marketing to be sent to you;
  • attend a seminar or other event;
  • enter a survey;
  • offer to provide or provide services to us; or
  • apply for a job with us.

Automated technologies or interactions. As you
interact with our website, we may automatically collect Technical Data
about your equipment, browsing actions and patterns. We collect this
personal data by using cookies and other similar technologies. Please
see the Cookie Policy on our website for further details.

Publicly available sources. We may receive personal
data about you from various publicly available sources, such as Identity
and Contact Data from third party websites.

How we use your personal data

We will only use your personal data when the law allows us to. Most
commonly, we will use your personal data in the following circumstances:

  • Fulfilling contracts: where we need to perform the contract we are about to or have entered into with you
  • Legitimate interests: where it is necessary for our
    legitimate interests (or those of a third party) and your interests and
    fundamental rights do not override those interests.
  • Legal duty: where we need to comply with a legal or regulatory obligation.

We have set out below more detail about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing
your personal data other than in relation to sending third party direct
marketing communications to you via email. You have the right to
withdraw consent to marketing at any time by contacting us at

 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the
ways we plan to use your personal data, and which of the legal bases we
rely on to do so. We have also identified what our legitimate interests
are where appropriate.

Note that we may process your personal data for more than one lawful
ground depending on the specific purpose for which we are using your
data. Please contact us at
if you need details about the specific legal ground we are relying on
to process your personal data where more than one ground has been set
out in the table below.

Purpose / Activity Lawful basis Legitimate interests
·       To provide services to you such as securing litigation funding or an insurance contract
·       To manage investments

·       To assess, monitor and manage the funding of litigation cases

·       To assist with managing investor relations

·       To provide services requested by you or your organisation

·       To identify persons authorised to instruct/appoint Exton and sign any relevant documentation

·       Fulfilling contracts
·       Legitimate interests

·       Legal duty

·       Fulfilling our legal obligations
·       Complying with rules and guidance from regulators
Customer Service
·       To analyse and improve our services and communications
·       Keeping you up to date on the latest news, events and other information we feel would be of interest to you

·       Customer surveys and marketing campaigns or other promotional activities or events

·       Collecting information about your preferences to create a
user profile to personalise our communication and interaction with you

·       Consent
·       Fulfilling contracts

·       Legitimate interests

·       Legal duty

·       Keeping our
records up to date, working out which of our products and services may
be of interest to you and telling you about them
·       Developing and improving out products and services

·       Developing future business initiatives

·       Seeking consent when we need it

Business management
·       To manage
and administer your or your organisations business relationship with
Exton, including processing payments and insurance premiums, accounting,
auditing, billing and collection and support services
·       Legitimate interest
·       Legal duty

·       Fulfilling contracts

·       Complying with rules and guidance from regulators
·       Fulfilling our legal obligations
Managing risk
·       To comply
with screening or identity obligations; these may include automated
checks of personal data or other information about your identity against
applicable sanction lists
·       To protect the security of and managing access to our
premises, IT and communication systems, online platforms, websites and
other systems, preventing and detecting security threats, fraud or other
criminal or malicious activities

·       To comply with our legal and regulatory obligations and
requests, in the UK and elsewhere in the world, including reporting to
and/or being audited by national and international regulatory bodies

·       To comply with court orders and exercises and/or defend our legal rights

·       Fulfilling contracts
·       Legitimate interests

·       Legal duty

·       Meeting our regulatory and legal obligations
·       Complying with rules and guidance from regulators

·       Fulfilling our legal obligations


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data
to form a view on what we think what may be of interest to you. This is
how we decide which content may be relevant for you (we call this

You will receive marketing communications from us if you have
requested information from us or if you otherwise provided us with your
details and, in each case, you have not opted out of receiving that

For market research purposes, we may also contact you to ask for your feedback.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at

Where you opt out of receiving these marketing messages, this will
not apply to personal data provided to us for a different purpose.


You can set your browser to refuse all or some browser cookies, or to
alert you when websites set or access cookies. If you disable or refuse
cookies, please note that some parts of this website may become
inaccessible or not function properly. For more information about the
cookies we use, please see the Cookie Policy on our website.

Change of purpose

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 you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us at

If we need to use your personal data for an unrelated purpose, we
will notify you and we will explain the legal basis which allows us to
do so.

Please note that we may process your personal data without your
knowledge or consent, in compliance with the above rules, where this is
required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out
below for the purposes set out in the table in paragraph 4 above:

  • third parties involved in the provisions of services to clients
    including insurance companies, litigation finance companies and other
    potential litigation funders, solicitors, barristers and other
    professional advisers;
  • our professional advisers, auditors and insurers;
  • third party service providers to whom we outsource services, for
    example archival, auditing, reference checking, professional advisory
    (including legal, accounting, financial and business consulting), IT
    support, technology, website, research, banking, payment, data
    processing, insurance, marketing and security services;
  • third parties with whom we have co-promotional arrangements (such as jointly sponsored events);
  • regulatory authorities, courts, tribunals, government agencies and other law enforcement agencies.

We will not disclose your personal data to another party unless we
are under a legal, regulatory or professional obligation to do so, we
have obtained your consent, or we need to do so in order to provide you
with the services you have engaged us for. This includes the processing
of any payment or where we use third party service providers to provide
services that involve data processing. Some of these entities may be
located outside the European Economic Area.

If you have any questions in relation to the transfer of your personal information please contact us at

International transfers

Whenever we transfer your personal data out of the EEA, we ensure a
similar degree of protection is afforded to it by ensuring at least one
of the following safeguards is implemented:

  • We will transfer your personal data to countries that have been
    deemed to provide an adequate level of protection for personal data by
    the European Commission. For further details, see the section on the
    European Commission website ( titled ‘Adequacy of the
    protection of personal data in non-EU countries’.
  • We may use specific contracts approved by the European Commission
    which give personal data the same protection it has in Europe. For
    further details, see the section on the European Commission website
    ( titled ‘Model contracts for the transfer of personal
    data to third countries’.
  • Where we use providers based in the US, we may transfer data to them
    if they are part of the Privacy Shield which requires them to provide
    similar protection to personal data shared between the Europe and the
    US. For further details, see the section on the European Commission
    website ( titled ‘EU-US Privacy Shield’.

Please contact us at if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access to
your personal data to those employees, agents, contractors and other
third parties who have a business need to know. They will only process
your personal data on our instructions and they are subject to a duty of

We have put in place procedures to deal with any suspected personal
data breach and will notify you and any applicable regulator of a breach
where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we
consider the amount, nature, and sensitivity of the personal data, the
potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the
applicable legal requirements.

Please contact us at for details of retention periods for different aspects of your personal data.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In some circumstances we may anonymise your personal data (so that it
can no longer be associated with you) for research or statistical
purposes in which case we may use this information indefinitely without
further notice to you.

Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • To request access to your personal data.
  • To request correction of your personal data.
  • To request erasure of your personal data.
  • To object to processing of your personal data.
  • To request restriction of processing your personal data.
  • To request transfer of your personal data.
  • To withdraw consent.

Please see the Legal Rights section below to find out more about these rights.

If you wish to exercise any of the rights set out above, please contact [John Astill] at

You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a reasonable
fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these

We may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal data
(or to exercise any of your other rights). This is a security measure
to ensure that personal data is not disclosed to any person who has no
right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month.
Occasionally, it may take us longer than a month, if your request is
particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.

Your Legal Rights

You have the right to:

  • Request access to your personal data (commonly known as a “data
    subject access request”). This enables you to receive a copy of the
    personal data we hold about you and to check that we are lawfully
    processing it.
  • Request correction of the personal data that we hold about you. This
    enables you to have any incomplete or inaccurate data we hold about you
    corrected, though we may need to verify the accuracy of the new data
    you provide to us.
  • Request erasure of your personal data. This enables you to ask us to
    delete or remove personal data where there is no good reason for us
    continuing to process it. You also have the right to ask us to delete or
    remove your personal data where you have successfully exercised your
    right to object to processing (see below), where we may have processed
    your information unlawfully or where we are required to erase your
    personal data to comply with local law. Note, however, that we may not
    always be able to comply with your request of erasure for specific legal
    reasons which will be notified to you, if applicable, at the time of
    your request.
  • Object to processing of your personal data where we are relying on a
    legitimate interest (or those of a third party) and there is something
    about your particular situation which makes you want to object to
    processing on this ground as you feel it impacts on your fundamental
    rights and freedoms. You also have the right to object where we are
    processing your personal data for direct marketing purposes. In some
    cases, we may demonstrate that we have compelling legitimate grounds to
    process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This
    enables you to ask us to suspend the processing of your personal data in
    the following scenarios: (a) if you want us to establish the data’s
    accuracy; (b) where our use of the data is unlawful but you do not want
    us to erase it; (c) where you need us to hold the data even if we no
    longer require it as you need it to establish, exercise or defend legal
    claims; or (d) you have objected to our use of your data but we need to
    verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third
    party. We will provide to you, or a third party you have chosen, your
    personal data in a structured, commonly used, machine-readable format.
    Note that this right only applies to automated information which you
    initially provided consent for us to use or where we used the
    information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to
    process your personal data. However, this will not affect the lawfulness
    of any processing carried out before you withdraw your consent. If you
    withdraw your consent, we may not be able to provide certain products or
    services to you. We will advise you if this is the case at the time you
    withdraw your consent.