The terms set out in this Data Protection Statement apply to any information you give Codex Capital Partners Limited and/or any member of the Codex Group of companies from time to time. It will also apply to any information you have already provided.

We may revise or supplement our Data Protection Statement from time to time for any of the following reasons:

  • to provide for the introduction of new or improved systems, methods of operation, services or facilities;
  • to reflect an actual or expected change in market conditions or general market practice;
  • to comply with or anticipate any changes in any legal or regulatory requirement;
  • to ensure that our business is run prudently;
  • to make our Data Protection Statement clearer or more favourable to you; or
  • to rectify any mistake that might be discovered from time to time.

You must not send us personal information about someone else without first getting his or her consent for it to be used and disclosed in the ways set out in our Data Protection Statement. This is because we will assume he or she has consented, although we may still ask for confirmation from them. Where you do give us information about someone else, or someone else discloses a connection with you, that information may be taken into account with your other personal information.

We treat your privacy very seriously and we understand that you will wish to know how we will use the information we collect from or about you. We use your personal information in accordance with our Data Protection Statement and will fully comply with all applicable UK data protection legislation (including the General Data Protection Regulation 2018). It is important that you take all necessary and appropriate steps to protect your data yourself (for example, by ensuring that all passwords and access codes are kept secure).

Codex Group consists of Codex Capital Partners Limited and Codex Capital Partners (UK) Limited and any direct or indirect subsidiaries of those two companies.

Information which we may collect about you

We may collect and process the following information about you:

  • Information you provide (either directly or through an agent such as a solicitor, independent financial advisor or introducer) by completing an application for our products and services, whether in writing, on our website, over the telephone or by some other means. This information may include your name, address, contact details, date of birth, bank details, details about your employment and financial information.
  • Records of any correspondence from you or anyone acting on your behalf.
  • Details of transactions you carry out with us.

Purpose of collecting the information

We may process, transfer and disclose your information for the purposes of:

  • providing you with services, monitoring your investments and complying with your instructions;
  • verifying your identity;
  • detecting and preventing fraud;
  • complying with laws and regulations (including the rules of any regulatory authority) and public duties;
  • in the interests of security and crime prevention;
  • analysis in order to assess and improve our business or the business of Code Group and the services Codex Group offers;
  • where you have a contract with you to do so or you have provided explicit consent, we may contact you time to time for regarding product and services available marketing purposes.

We will act proportionately and responsibly when we process, transfer or disclose your information and we will act strictly in accordance with the General Data Protection Regulation Act 2018. We will not process any of the above information.

We may at any time search your record with a fraud prevention agency. If at any time you give us or procure the giving of false or inaccurate information and we suspect fraud we will record this. The fraud prevention agency will use information recorded for statistical analysis about fraud and will also share it with other organisations who will use it to prevent fraud and to help make decisions on motor, household, credit, life and other insurance proposals and claims by you, members of your household or any other businesses associated with you.

We may from time to time contact you about products and services available from Codex Group which we believe may be of interest to you. We may do this by post or by phone unless you have told us in writing not to; and by e-mail, text or other electronic means if you have provided us with explicit consent that we can. You can tell us in writing at any time if you change your mind and wish to withdraw consent.

Disclosure of your information

Your personal information may be passed to and used by companies within Codex Group and our agents and sub-contractors who administer or process the information on our behalf Most of our sub-contractors and administrators are based in the UK or EEA, however, one in particular is based in Gibraltar. Please contact Kate Osborne at Codex Capital Partners Limited, 39-41 Charing Cross Road, London, WC2H 0AR for an up-to-date list of the current members of Codex Group and detail of any agent or sub-contractors we use from time to time.

We may also disclose your personal information to third parties in the following circumstances:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer.
  • If Codex Capital Partners Limited or Codex Capital Partners (UK) Limited or substantially all of one or both of their assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of the Codex Group, our customers, or others.

International transfer

We may on occasion transfer your personal information outside the European Economic Area (EEA) to countries which may not offer the same level of data protection as the United Kingdom.

In particular, your information may be sent to Gibraltar, which is where one of our company administrators is based, and the USA and any other jurisdiction in which our IT providers, an agent or a sub-contractor carries on business. If this happens, we will ensure that anyone to whom we pass your information agrees to treat your information with the same level of protection as if we were dealing with it.

Access to your information and correction

Subject to some exceptions, you have a right to access personal data that is held about you. To obtain a copy of the personal information we hold, you should write to Kate Osborne at Codex Capital Partners Limited, 39-41 Charing Cross Road, London, WC2H 0AR or email We will respond to you within one month of receipt of the request. We will provide a copy of the information held free of charge however we may charge a reasonable fee to comply with requests for further copies of the same information. You may also request from us details of the fraud prevention agencies with which we may have carried out searches. If there are any inaccuracies in the information we hold about you, please notify us of this in order that we may correct the information we hold about you.

How to contact us

If you have any comments or questions about our Data Protection Statement please contact Kate Osborne, our Data Protection Officer at 39-41 Charing Cross Road, London, WC2H 0AR or email

Conditions of access to the Codex Capital Group Website (the “Terms”)

By accessing any page on this website, you agree to be bound by the following Terms:

Risk Warning

The value of investments and the income from them may fall as well as rise and is not guaranteed.  Consequently, you may not receive back the amount originally invested.  Past performance is not necessarily a guide to future returns.  The value of any securities denominated in a foreign currency will be influenced by the rate of exchange used to convert them back into your base currency.

No Offer

The information contained in the Website is not intended to constitute any offer to sell or the invitation or solicitation of an offer to buy any product or service or security by any company described or referred to in the Website or by any subsidiary, holding company, affiliate or associated company of such company (all such companies hereafter collectively referred to as “Codex Capital” and individually as “members” of the Codex Capital Group) and must not be relied upon in connection with any investment decision. You should rely solely on your own investigation regarding any investment decision and should seek competent professional advice.

Use of the Website

As a condition to your use of the Website, you will not, directly or indirectly: (a) use the Website to infringe upon the intellectual property rights of others; (b) use the Website or make any attempt to penetrate, modify or manipulate the Website to invade the privacy of any other user thereof; (c) attempt to modify, erase or damage any information contained on the Website or any device connected thereto; (d) reverse engineer any portion of the Website; (e) restrict or inhibit others from using the Website; (f) engage in conduct or distribute material that is harmful, obscene, otherwise illegal or objectionable, or gives rise to civil or criminal liability; (g) spoof or otherwise impersonate any individual or entity; or (h) violate or attempt to violate the security or integrity of the Website. Codex Capital reserves the right to investigate and to involve and cooperate with law enforcement authorities, and to pursue a lawsuit or criminal prosecution, for any alleged or actual harmful or illegal activities involving the Website.

Codex Capital reserves the right, at any time, to modify or discontinue, temporarily or permanently, the Website, with or without notice and to modify these Terms at any time. You should visit the Website periodically to review the current Terms.

The Website is not intended for use by minors.

Accuracy and Content of Information

Whilst every reasonable precaution has been taken to ensure the accuracy, security and confidentiality of information available on this website, no representation or warranty (including liability towards third parties), expressed or implied, is made as to its accuracy, reliability or completeness, and no liability is accepted for any errors or omissions.

Expressions and opinions on this website represent the views of Codex Capital which may be subject to change without notice.  These views are provided for information purposes only and should not be construed as constituting investment, legal, tax or other advice nor be relied upon in making an investment or other decision.  You should obtain relevant and specific professional advice before making any investment decision.

Access Subject to Local Restrictions

The Website and all information and functionality contained within it are not directed at or intended for use by any person resident or located in any jurisdiction where (a) the distribution of such information or functionality is contrary to the laws of such jurisdiction or (b) such distribution is prohibited without obtaining the necessary licenses or authorisations by the relevant member of the Codex Capital group and such licenses or authorisations have not been obtained.

No Warranty

All content on the Website is provided “as is”, with no guarantees of completeness, accuracy or timeliness, and without representations, warranties or other contractual terms of any kind, express or implied. Codex Capital further assumes no responsibility for, and makes no warranties that, functions contained on the website will be accurate, current, uninterrupted, omission free or error-free, that defects will be corrected, or that the website or the services that make it available will be free of viruses or other harmful components.

Copyright and Trademarks

Copyright trademarks, database rights, patents and all similar rights on this website are owned by Codex Capital or related parties.  You may download or print a hard copy of individual pages and/or selections of the website, provided that you do not remove copyright or other proprietary notices.  Any downloading or other copying from the website will not transfer title to any software to you.  You may not reproduce (in whole or part), transmit (by electronic means or otherwise), modify, link or use for any public or commercial purposes the website without the prior permission of Codex Capital.  Nothing on this website shall be construed as granting any license or right to use any image, trademark, service mark or logo.  You shall indemnify us from and against all actions, claims, proceedings, costs and damages (including any damages or compensation paid by us on the advice of our legal advisors to compromise or settle any claims and all legal costs or expenses arising from any breach by you of these copyright and trademarks.

External websites

The Website may contain links to third party websites. Codex Capital takes no responsibility for the content of off-site pages or any other websites linked or linking to the website.


Codex Capital will not use confidential information for any purpose other than that for which it was given.  Nor will Codex Capital reveal that information to other organisations except in the proper performance of its duties or where required to do so under compulsion of law or where requested by a regulatory agency.

We treat your privacy very seriously and we understand that you will wish to know how we will use the information we collect from or about you. We will act proportionately and responsibly when we process, transfer or disclose your information and will act strictly in accordance with our Data Protection Statement and will fully comply with all applicable UK data protection legislation (including the General Data Protection Regulation 2018).

For further information on how we will use and protect your personal data please refer to our Data Protection Statement.


This website uses cookies. Cookies are small files that are stored on the hard drive of your computer which help us to improve our site and to deliver a better and more personalised service.

Many websites use cookies and you can find more information about them (including how to disable them if you wish) at:, a website run by an industry body. Please note that if you disable cookies, you may be unable to access parts of our website.

For more information on how we use cookies please see our Cookies Policy.


You agree to indemnify and hold Codex Capital harmless from any claim, demand, cause of action, debt, loss or liability, including properly incurred legal fees, to the extent that such action is based upon, arises out of, or relates to your breach of these Terms or your use of the Website.  This indemnity shall survive any termination of these Terms.

Severability Clause

To the extent that any provision of these Terms is found by any competent court or authority to be invalid, unlawful or unenforceable in any jurisdiction, that provision shall be deemed not to be part of this disclaimer but such finding shall not affect the validity, lawfulness or enforceability of the remainder of these Terms in that jurisdiction, nor shall it affect the validity, lawfulness or enforceability of these Terms in any other jurisdiction.

Governing Law

These Terms are governed and shall be construed in accordance with the laws of England.  You agree that any disputes arising out of the Terms or otherwise between us shall be subject to the exclusive jurisdiction of the English courts.

We use cookies on our website so that we can ensure it’s working the way it should and make improvements.
A cookie is a small file of letters and numbers that is sent and stored on your computer and/or mobile device which provides us with information in relation to your website usage, and allows us to recognise that you have used our website before.

Cookies are safe and secure and are commonly used by websites.

A cookie typically contains:

  • the name of the server the cookie was sent from;
  • the lifetime of the cookie; and
  • a unique identifier (usually a number).

How cookies work

When you visit the Codex website, our website server sends a cookie to your device and uses this number to recognise you when you return to the site or browse from page to page. This cookie is then stored on your computer or mobile device.

All websites can send a cookie to your browser if your browser settings allow it. Many websites do this to track online flow.

Types of cookies

Cookies may be categorised on the basis of their life span:

  1. Session or temporary cookies: these cookies expire when you close your browser or when the session times out.
  2. Persistent or permanent cookies: these are usually stored on your hard disk and survive across multiple sessions but have a longer expiration date.

Please find below a table detailing the types of cookies used on our website:

Cookie NameSet byData StoredPurposeMore info
PHPSESSIDWordPressA random unique number or string of letters and numbers.As you browse around the pages on this site, the session cookie tells the website that you are the same person requesting the webpages, and not a new visitor to each page. This cookie does not identify you personally and is not linked to any other information we store about
tk_tcWordPressAnonymousThis cookie collects metrics about the users use of the website related to the features so that can improve their
_gaGoogle AnalyticsAnonymousUsed to distinguish
_gidGoogle AnalyticsAnonymousUsed to distinguish
_gatGoogle AnalyticsAnonymousUsed to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named
AMP_TOKENGoogle AnalyticsAnonymousContains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID
__utmaGoogle AnalyticsAnonymousUsed to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google
__utmtGoogle AnalyticsAnonymousUsed to throttle request
__utmbGoogle AnalyticsAnonymousUsed to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google
__utmcGoogle AnalyticsAnonymousNot used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operates in conjunction with the __utmb cookie to determine whether the user was in a new session/
__utmzGoogle AnalyticsAnonymousStores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google
__utmvGoogle AnalyticsAnonymousUsed to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google
CONSENTGoogleAnonymousCookie set by Google to off-loaded static content (JavaScript code, images and CSS) to a different domain name in an effort to reduce bandwidth usage and increase network performance for the end

Controlling or deleting cookies

You can easily control and disable cookies through your browser settings. Learn how to remove cookies set on your device. Removal of cookies may impact the experience whilst using the website through repeated requirements for entry of confirmation.