File 07Confidentiality

Document handling and confidentiality.

The firm receives sensitive operational documentation as part of every portfolio review. The terms below describe how that documentation is held, retained, and disclosed.

Item 01

Document handling

Submitted documentation is held in a private, access-controlled environment. Access is limited to firm personnel and retained counsel directly involved in portfolio review. Documents are not shared with third parties without written authorization.

Item 02

Retention

Documents from declined portfolios are destroyed within thirty days of decline, unless the seller requests return. Documents from acquired portfolios are retained as required for collection and audit.

Item 03

Personal data

Where submitted documentation contains personal data subject to GDPR, UK GDPR, or equivalent, the firm processes it solely for portfolio evaluation and, post-acquisition, collection. Sellers may request a Data Processing Addendum.

Item 04

Confidentiality of the engagement

The existence of a submission, the terms of any offer, and the identity of the seller are confidential and not disclosed except as required by law.