Last Updated: 08/12/2025
Introduction
Welcome to the privacy notice of Xenith Capital ("we", "us", or "our"). We are committed to protecting your personal data and respecting your privacy.
Xenith Capital operates as a Strategy Provider to Pelican Trading (a trading name of London & Eastern LLP). This privacy notice explains how we collect, use, and share your personal data when you visit our website (www.xenithcapital.co.uk) or engage with our automated trading strategies.
Important Note on Regulation: Xenith Capital is not authorised or regulated by the Financial Conduct Authority (FCA). However, we partner with regulated infrastructure providers to deliver our services. This requires specific data sharing arrangements outlined in Section 5 of this notice.
Important Information and Who We Are
Controller Xenith Capital is the controller and responsible for your personal data.
Registered Office: 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF.
Email: info@xenithcapital.co.uk
Third-Party Links This website may include links to third-party websites (such as our broker partners), 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
We may collect, use, store, and transfer different kinds of personal data about you, including:
Identity Data: First name, last name, username, or similar identifiers.
Contact Data: Email address and telephone number.
Investor Profile Data: Information regarding your investor categorisation (e.g., High Net Worth, Restricted Investor, or Sophisticated Investor status) and risk appetite, which we are required to collect for financial promotion compliance.
Technical Data: Internet protocol (IP) address, browser type, and version, time zone setting, and location.
Usage Data: Information about how you use our website and view our strategy factsheets.
Marketing and Communications Data: Your preferences in receiving marketing from us.
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:
Service Delivery: To provide you with access to our strategy factsheets and performance data.
Onboarding & Suitability: To assess your eligibility to view Restricted Mass Market Investments (RMMI) under FCA financial promotion rules.
Introduction: To introduce you to our regulated partners (Pelican/Vantage) for account opening and trade execution.
Marketing: To send you educational content, strategy updates, and newsletters (where you have opted in).
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.
Disclosures of Your Personal Data
To facilitate the execution of our trading strategies, we share your personal data with our regulated infrastructure partners:
A. Regulated Infrastructure Partners
Pelican Trading (London & Eastern LLP): We share your contact and identity data with Pelican Trading (FCA Firm Ref: 534484) to facilitate your introduction to the trading ecosystem and for compliance monitoring.
Note on Brokerage: We do not directly open accounts for you. We introduce you to Vantage Global Limited (Vanuatu), where you will open your own account. However, by connecting to our strategies, you authorise Vantage/Pelican to share your trading performance data and account balance with us for the purposes of calculating performance fees and strategy monitoring.
B. Operational Service Providers
Technology Providers: Third-party platforms we use for business operations, including SendFox (email automation), Lunacal/Calendly (appointment booking), and website hosting services.
Professional Advisers: Lawyers, bankers, auditors, and insurers.
International Transfers
Our execution partner, Vantage Global Limited, is headquartered in Vanuatu.
While we may not directly transfer your initial application data to them (as you sign up directly), our services rely on data flows between the UK (Pelican/Xenith) and Vanuatu (Vantage). By using our services, you acknowledge that:
Your trading account is held in a jurisdiction outside the UK/EEA.
Data regarding your trades and performance will be processed internationally to facilitate the copy-trading and fee-calculation services we provide.
We ensure that any data we receive back from our international partners is treated with the same security standards as UK data.
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. We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.
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.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Withdraw consent at any time.
If you wish to exercise any of the rights set out above, please contact us at info@xenithcapital.co.uk.
Cookies
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 (such as the Investor Categorisation Pop-Up) may become inaccessible or not function properly.
Queries, Requests, or Concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our us on info@xenithcapital.co.uk
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.
