Artystone

Artystone LLP is an alternative investment adviser that targets mispriced opportunities across corporate capital structures using proprietary fundamental and legal analysis.

investors@artystone.com

GENERAL PRIVACY NOTICE FEBRUARY 2026

Purpose of this privacy statement

This privacy notice explains how Artystone LLP collects and processes your personal data. We are committed to protecting your personal data and this privacy statement will explain how it is looked after and what rights you have.

If you have any questions about this privacy notice or how your personal data is dealt with, including any requests to exercise your legal rights, please contact us using the details below.

Whose personal data do we process

Artystone LLP may collect and process the personal data of various categories of people who interact with it, mostly clients or prospective clients. This privacy statement applies to all personal data we obtain and process, whichever category you might fall into. What data we use and how it is used will depend on the particular circumstances, as explained within this notice.

What sort of personal data do we process and how is it collected?

The types of personal data that we will collect and use will depend on various circumstances, for example, your relationship with Artystone LLP, why you are interacting with us and the type of services or products provided to you. The data may include, for example:

identity information, such as your name, the company you work for, your job title and department
contact details, such as your email address and phone number(s)
communication preferences
information which you provide in subscription documents and other forms
identity documents and other personal information used to carry out anti-money laundering (AML) checks, or to apply for travel documents on your behalf
audio recordings of telephone calls, video calls and meetings, together with any transcripts, summaries or notes derived from them, where you interact with us by phone, video conference or in person
any other personal data we may obtain through you interacting with us

We obtain data from you directly as you interact with us, though sometimes information is received from third parties with whom we have a contractual relationship.

For what purpose do we collect your personal data?

We will only use your personal data for the purposes for which it has been provided. Generally, we will process your personal data in order to provide you with those services and other offerings you want to receive from us and to fulfil any contractual obligations. We will only use your personal data for the purposes for which it has been provided to it. If we are going to process your personal data in addition to the original reasons it was collected, you will be informed of this prior to processing.

We may record, transcribe or take notes from telephone calls, video conferences and meetings in which you participate. We do this for purposes including investment research and analysis; maintaining accurate records of discussions with counterparties, advisers, experts and service providers; evidencing instructions, transactions and agreements; staff training and quality control; internal compliance and audit; and to comply with applicable regulatory obligations, including under FCA rules where relevant. Where a call or meeting is recorded, the recording and any derived materials are treated as confidential and held on our secure systems.

What lawful bases do we rely on to process your personal data?

We will only use your personal data in compliance with this privacy notice and the applicable laws and regulations. We rely on the following lawful bases under Article 6(1) UK GDPR:

Legitimate interests (Article 6(1)(f)) — for the day-to-day operation of our business, including investment research and analysis, recording and note-taking from calls and meetings, communications with counterparties and service providers, marketing to professional contacts, and the management of our relationships with clients, prospective clients and counterparties. We have assessed that our legitimate interests are not overridden by your interests, rights or freedoms.
Performance of a contract (Article 6(1)(b)) — where processing is necessary to perform a contract with you or to take steps at your request prior to entering into a contract.
Legal obligation (Article 6(1)(c)) — where processing is necessary to comply with applicable legal and regulatory obligations, including AML and KYC requirements, FCA rules, tax reporting, and responses to lawful requests from authorities.
Consent (Article 6(1)(a)) — in limited circumstances where we ask for your specific consent. You may withdraw consent at any time.

Who do we share your personal data with?

We do not share or disclose your personal information without your consent, other than for the purposes specified in this notice or where there is an applicable legal requirement. We may share your personal data with other organisations from time to time, as required by our contract with you. For example:

Your service providers or potential service providers who process data for you, including those providing IT and system administration services and hosting.
Other organisations such as auditors and compliance consultants
to competent authorities (including tax authorities), courts and bodies as required by law or requested or to affiliates for internal investigations and reporting

How do we look after your data?

We have put in place appropriate security measures to help prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. In addition, we limit access to your personal data to those agents, contractors and other third parties who have a business need to know. They will only process your personal data on instruction and subject to a duty of confidentiality. 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 legally required to do so.

How long will we use your personal data for?

We will only keep your personal data for as long as necessary to fulfil the purposes for which it is collected it or to enable us to comply with our legal obligations or enforce our legal rights. At the end of the retention period, we will either delete your data completely, or anonymise it so that, for example, it can be aggregated with other data so that it can be used, without identifying you.

What are your legal rights?

You have the following rights relating to the personal data we hold about you:

The right of access to your personal data (Article 15)
The right of rectification, where personal data is incorrect or incomplete (Article 16)
The right of erasure, the ‘right to be forgotten’ (Article 17)
The right to restrict processing (Article 18)
The right to data portability (Article 20)
The right to withdraw consent at any time, where processing is based on consent (Article 7(3))
The right to object to processing, including for direct marketing purposes (Article 21)

Please note that there may be circumstances where we cannot delete information that we hold about you because of our legal obligations.

Accessing your data

Should you wish to access your data, 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 circumstances.

We may need to request specific information from you to help 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 the response.

Changes to this privacy statement or to your data

This privacy statement may change from time to time.

Contact or Complaints

Stefano Malfitano
Email: smalfitano@artystone.com
Tel: +44 20 7925 7785

You are entitled to complain at any time to the Information Commissioner’s Office (ICO) at www.ico.org.uk.