Key Capital Privacy Statement

Privacy Statement

KCII Limited and its subsidiaries (collectively “Key Capital”) are data controllers and the firm and its staff are committed to protecting your rights to privacy and confidentially.  We will ensure that your personal data is processed fairly and lawfully, and that appropriate security measures are in place to protect the integrity and security of the data we hold.  The objective of this document is to provide you with information so that you understand how personal data concerning you is collected, processed and retained by us and how you can exercise your rights in relation to your data.

Why do you gather personal data?

The principal activities of Key Capital are the provision of advisory services to corporate and high net worth clients. We also provide investment management services to institutional clients.  We require personal data to facilitate the provision and promotion of these services.

What personal data do you collect?

The type and level of personal data collected by us depends on the relationship we have with you.  In all cases the information collected will be adequate, relevant and limited to what is necessary in relation to the purposes for which it will be processed.  The personal data we require is predominantly obtained directly from you, however, it may also be obtained from publicly available sources or from relevant third parties such as your accountant, solicitor, other financial institutions or employers.   You should also be aware that telephone conversations on landlines may be recorded for verification purposes.

What will you use my personal data for?

The personal data we hold will be used for the following purposes:

  • to assess your requirements and provide relevant services and opportunities
  • to develop and deliver efficient services to you
  • to open and administer accounts or investments
  • to meet legal and regulatory obligations
  • to keep you informed of our products and services
  • for other related or compatible purposes

Who will it be disclosed to?

We do not disclose your information to anyone outside of Key Capital except where this is necessary to fulfil the above purposes or where we have your permission to do so. There may be circumstances where we are required or obliged to share your information with government entities or regulatory bodies in order that those entities may discharge their responsibilities and obligations or exercise their powers or functions.  There are measures in place to ensure that your information is only shared between the entities within the Key Capital group where there is a lawful basis for us to do so and it is required for the purpose of providing relevant services to you.

Will my personal data be transferred outside the EU?

We may transfer your information to other countries inside and outside the EU.  The transfer of information outside the EU will only occur where it is necessary for the provision of our services and we can reasonably ascertain that anyone to whom we pass it provides an adequate level of protection that is ensured within the EU. For example, if we transfer personal data to the United States, we will ensure that appropriate contractual clauses, Privacy Shield or other legitimising measures required by EU law are in place to govern the transfers.

How long will my personal data be retained for?

We will hold your information for the duration of your relationship with us and thereafter for the minimum periods set down by the various legislative requirements to which we are subject. Thereafter we will retain your data as documented in our Retention Policy.  In most cases, this will mean a minimum period of retention of at least 6 years after the expiry of our relationship, unless we are required to retain it for a longer period to meet legal, regulatory or evidential requirements.  On expiry of the relevant minimum period, and once it has been verified that there is no longer a known and lawful purpose for continued retention of your data, it will be scheduled for destruction. We may retain your contact details for the purposes of keeping you informed of our products and services where we have your consent to do so.

What rights as a data subject do I have?

The General Data Protection Regulation sets out the rights for individuals which include the rights to:

  • access your personal data that we retain and process
  • have inaccuracies corrected
  • have your personal data erased
  • object to processing of your personal data
  • data portability
  • withdraw your consent (e.g. to marketing contact)
  • lodge a complaint with the Data Protection Commission

These rights are not an absolute and do not apply where they would adversely affect the rights and freedom of others or where the controller is required to comply with a legal obligation which requires processing.  For example, due to the nature of our business, most of the information we hold is subject to other legal requirements so the right of erasure may not always apply.  We do not make automated decisions which produce legal effects.

How do I complain or submit requests?

Complaints and requests to exercise the above rights can be made directly to Key Capital by submitting your request to   When doing so, please provide us with relevant information to allow us to deal with your complaint or request.   We will acknowledge your request within 5 working days.

If you think that we are not meeting our data protection obligations, and if you are not satisfied with our response to your concerns, then you may complain directly to the office of the Data Protection Commission who will look into the matter for you.  Full details of their complaints process is available on their website.

How do I object to the processing of my personal data for marketing?

As a valued client or business contact of Key Capital, we would like to send you these notifications of upcoming events and news that we feel are relevant to you and may be of interest. We will respect your contact preferences so if you do not want to receive any further such notifications from us you can unsubscribe by clicking the unsubscribe button in any of our contact emails.  You can also unsubscribe at any time by emailing or telephoning us on 01 638 3838.

How secure is my data?

Key Capital takes its data security responsibilities seriously and employs appropriate physical and technical measures. Key Capital has suitable resources in place and reviews its IT security measures periodically including employing 3rd parties to carry out an independent audit. In the event of a personal data breach we will comply with our reporting obligations under applicable law.

What personal data is collected via your website?

Key Capital website does not collect personal information from you and you can visit our website without telling us who you are or revealing any information about yourself.  We only measure and analyse non-identifying, aggregate usage data in order to administer the site, and to constantly improve the quality of our service and site performance.  Key Capital may collect data from you on its website in the future but will only do so where you have chosen to give it to us in which case we will process it fairly and lawfully and for the purposes for which it is given or as outlined above.

Do you use cookies?

Cookies are small text files placed on your computer and are commonly used on the internet.  Key Capital use “temporary cookies” which are necessary for the operation of our website.  We use a web analytics tool which collects technical data when you visit our website.  Technical data includes IP addresses and web browser information. We use them to collect information that will help us understand visitors’ browsing habits on our website and compile statistical reports on website activity.   This information is exclusively for the use of Key Capital so we don’t share it with third parties.

Why do we use cookies?

The cookies we use cannot be used to identify you personally.
These pieces of information that we gather are used in the following ways:

  • We use cookies that are strictly necessary to enable you to move around the site or to provide certain basic features.
  • We also use cookies to help us to improve the performance of our website to provide you with a better user experience.We use a third party to monitor and analyse traffic to, from and within our website.
  • some pages on this site may also contain content embedded from, for example Vimeo, which sets its own cookies to track traffic to that particular video.

Types of Cookies

First Party Cookies

First party cookies are set by the website, you are visiting and they can only be read by that site.

Third Party Cookies

Third party cookies are set by a different organisation to the owner of the website you are visiting. For example, the website might use a third party analytics company who will set their own cookie to perform this service. The website you are visiting may also contain content embedded from, for example YouTube, Vimeo or Flickr, and these sites may set their own cookies. We do not controlhow these cookies are used and you should check the relevant third party’s website for more information.

Session Cookies

Session Cookies are stored only temporarily during a browsing session and are deleted from the user’s device when the browser is closed.

Persistent Cookies

This type of cookie is saved on your computer for a fixed period and is not deleted when the browser is closed. Persistent cookies are used where we need to know who you are for more than one browsing session.

How do I control how my browser interprets cookies?

All recent versions of browsers allow you to control how cookies are stored on your device. You can set your browser to accept or reject all cookies, or only accept certain types of cookies. Please note that some of the cookies necessary to enable you to move about the site, and if you disable them you may not be able to visit certain areas of the site or access certain content. For more information on how to control cookies please visit:

Cookies Used By Key Capital

At Key Capital we use cookies for the following purposes:

  1. to ensure the website works correctly,
  2. to remember any preferences you may have given the website, and
  3. to collect anonymous data which allows us to see how people arrive at our website and which content is viewed.

Below is a list of the main cookies used by Key Capital and what each is used for:

Cookie Name

Expiration Time



2 years

Used to distinguish visitors to site


24 hours

Used to distinguish visitors to site


10 minutes

Used to throttle request rate


10 minutes

Used to throttle request rate.

_ _utma

2 years from set/update

Used 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 Analytics.

_ _utmb

30 mins from set/update

Used 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 Analytics.

_ _ utmc

End of browser session

Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.

_ _utmz

6 months from set/update

Stores 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 Analytics.

Specific Cookies

The following cookies are used specifically on this site;

Cookie Name

Expiration Time



6 Months

Records if you have clicked in the Cookie Notification and therefore does not display notification for 6 months.



The PHPSESSID cookie is native to PHP and enables websites to store serialised state data. On the Action website it is used to establish a user session and to pass state data via a temporary cookie, which is commonly referred to as a session cookie. As the PHPSESSID cookie has no timed expiry, it disappears when the client is closed.



This is a test cookie, to see if cookies are enabled.

Where do I get further information?

If you have any questions in relation to this Privacy Statement or would like more information on the policies referenced herein please contact us on 01 638 3837 or email

Key Capital reserves the right to amend our Privacy Statement at any time. The up to date statement will be on our website at all times.

Key Capital,  Huguenot House, St. Stephen’s Green, Dublin 2, D02 NY63. Ireland.


The content of this website is for information purposes only is intended solely for persons who are permitted to receive such information under applicable laws and may not be reproduced, photocopied or disseminated to any other person without the express prior written consent of KC II Limited, Key Capital Private (KCP) or Key Capital Investment Management Limited (KCIML) (together “Key Capital”).  Information contained herein is subject to updating, completion, modification and amendment. ur website and newsletters may contain links to other websites. Key Capital however, is not responsible for the privacy policy or content of those websites

The alternative investment funds referenced on this website are not suitable for all investors and are not available for offer to the public Information provided is intended for the use of Institutional and Qualifying investors only.  The material on this website is not directed to any person who is located in any jurisdiction where Key Capital would be prohibited by any law from doing so.  Information on this website regarding these funds is provided to you on the understanding that you are a professional, sophisticated investor who has experience of investing in collective investment schemes and that you understand and accept the inherent limitations of the information contained herein.  You will not rely on it in making any investment decision with respect to any securities that may be issued, and will use it only for the purpose of discussing your preliminary interest.

No information or document on the website constitutes or forms part of an offer to sell or subscribe, or the solicitation of an offer or invitation to purchase or subscribe, any security or instrument or to participate in any trading strategy.  Any financial or other advice should be sought by the recipient as the recipient deems appropriate.  Past performance is not a reliable predictor of future performance.  Any financial illustrations and illustrative returns and cashflows contained herein do not constitute forecasts and should not be construed as such. The financial illustrations may not reflect current or future market expectations. The illustrations cover an extended period of time and the assumptions on which they are based are subject to many uncertainties. Some or all of these assumptions may turn out to be different from the actual position and the financial illustrations should not be relied upon as a guide to future financial performance but only as examples of possible outcomes. There can be no assurance, nor is there any guarantee (implied or otherwise), that the future financial performance set out in any illustrations will be met, or that any opinions contained in any document related to such illustrations are correct, and no reliance should be placed on such opinions or illustrations.  In addition, any investment in the Funds may entail additional investment risks, which will be set out in greater detail in the offering documents.  Any sale of securities will be on the basis of the prospectus, supplement, memorandum & articles of association and application form for the company and the relevant underlying fund.

The information herein is not intended to provide, and should not be relied upon for, accounting, legal, or tax advice or investment recommendations. Each recipient should consult its tax, legal and accounting or other advisers about the issues discussed herein and each recipient shall be solely responsible for evaluating the risks and merits involved.

Any descriptions contained herein are a summary of certain proposed terms and are for preliminary information purposes only. The information is not intended to be complete and is subject to change and does not constitute all the information necessary to adequately evaluate the consequences of investing in the securities or instruments.  No assurance or representation can be made as to actual returns or cashflows described herein. Certain information has been obtained from sources that are believed by Key Capital to be reliable. All such information including information obtained from sources believed by Key Capital to be reliable may be incorrect, incomplete or condensed; Key Capital does not accept any responsibility for, or guarantee, its accuracy. Accordingly, no representation or warranty, expressed or implied, as to the fairness, correctness, accuracy or completeness of this document (or any part) is made by Key Capital and no reliance may be placed on such information. Nothing contained herein should be relied upon as a promise or representation as to the future. None of Key Capital, their respective members, directors, officers, employees, agents or representatives nor any other person accepts any obligation or responsibility to advise any person of changes in the information set forth herein after the date hereof. To the extent permitted by law, none of Key Capital or any of their affiliates, their respective members, directors, officers, employees, agents or representatives nor any other person accepts any liability whatsoever for any losses howsoever arising from any use of or reliance on the information contained herein or otherwise arising in connection therewith. All material contained herein is for discussion purposes only. Key Capital is not acting as your adviser or fiduciary by providing this information.  Key Capital may have positions and may effect transactions in any underlying securities or investments described herein.   None of Key Capital its respective members, directors, officers, employees, agents or representatives nor any other person is making or will make any representation to any prospective investor in a transaction regarding the legality of an investment by any such person in the transaction.

By accessing any part of this site, you are deemed to have acknowledged and accepted these terms in full.

© Copyright KC II Ltd., trading as Key Capital. Registered address, Huguenot House, St. Stephen's Green, D02 NY63. Registered Number 390761. Privacy Statement, Cookie Policy & Disclaimer