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Cookie Policy

Cookies Policy – Hampshire Capital Ltd.

Hampshire Capital LTD (“we”, “us”, “our”) is committed to ensuring compliance with the requirements set out under PECR and UK GDPR, as interpreted by the Information Commissioner’s Office (ICO), regarding the use of cookies and similar technologies.

1. What are cookies and similar technologies
“Cookies” (and similar technologies such as tracking pixels, local storage or device-fingerprinting, where applicable) are small text files placed on a user’s device (computer, mobile device, browser, or other terminal equipment) when visiting a website or using an online service. They enable the storage of information or access to information previously stored.  

Cookies may serve various purposes, such as enabling core functionality of the website, remembering user preferences, analysing site usage, or delivering relevant content or advertising.

2. Exemptions and when consent is required
Under PECR (as applied in the UK) certain cookies may be used without the user’s prior consent if they are “strictly necessary” for delivering a service explicitly requested by the user (e.g. session management, load-balancing, security, “remember me” functions). The exemption is interpreted narrowly: only cookies that are essential for the operation of the website or to carry out communication requested by the user qualify.

All other cookies or similar technologies (e.g. analytics, advertising, tracking, personalisation) are non-essential and require valid consent before being placed or accessed.

3. Standard for valid consent under UK GDPR
Where consent is required, it must meet the UK GDPR standard: freely given, specific, informed, and unambiguous. Consent must be given by a clear affirmative action (opt-in). Pre-ticked boxes, default settings, inactivity, or scrolling do not constitute valid consent.  

Consent must also be granular: users should be able to accept or reject non-essential cookies (or categories thereof) separately from strictly necessary cookies. “Accept” and “Reject / Decline” options must be presented with equal prominence. Dark-pattern design or manipulative defaults are non-compliant.

4. Transparency and information provision
Before cookies or similar technologies are set (except strictly necessary cookies with no consent requirement), users must be given “clear and comprehensive information” — i.e. a description of:

  • the types/categories of cookies/technologies used;

  • the purpose of each cookie/category;

  • whether cookies are first-party or third-party;

  • the duration for which they will remain on the device;

  • what data may be processed via those cookies;

  • how users can accept, reject or withdraw consent.

A cookie notice/banner should be clearly visible and link to a full Cookie Policy or Privacy Notice where more detailed information is available. The Cookie Policy should be easy to find, readable, and in clear plain language — not hidden inside long legal documents or difficult-to-access privacy policies.

5. Consent management and withdrawal of consent
Users must be able to withdraw their consent at any time, and withdrawing consent must be as easy as giving it. Consent preferences should be recorded and respected across the website. Once consent is withdrawn, non-essential cookies must be disabled or deleted.  

6. Responsibility and accountability
Hampshire Capital Ltd., as data controller (or in some cases data processor), is responsible for determining which cookies are strictly necessary, which are non-essential, and ensuring compliance with PECR and UK GDPR. We must ensure that any third-party cookies or technologies embedded via external services also comply, and that we maintain documentation (audit trail) of consent decisions and cookie inventories.

7. Regular review and updates
We will periodically review this Cookies Policy — and our cookie usage — to verify compliance with evolving legal requirements and regulatory guidance. Especially following changes such as the enactment of the Data (Use and Access) Act 2025 (DUA Act) which may impact PECR and consent obligations, or any update issued by the ICO.

8. User rights and contact information
Where personal data is processed via cookies or similar technologies, users have rights under UK GDPR (access, erasure, objection, complaint, etc.). For further information, or to exercise those rights, please consult our Privacy Policy or contact our Data Protection Officer at: dataprotection@hampshirecapital.com

Hampshire Capital Limited does not provide investment advice, investment management, arranging of investments, or any other regulated financial services within the United Kingdom.
All services described on this website relate solely to commercial consulting and strategic advisory activities delivered outside the UK.
Nothing on this website constitutes an offer, solicitation, or promotion of any financial product or investment opportunity.

Hampshire Capital Limited operates exclusively as a strategic consultancy and operational partner.
Where clients require regulated financial or investment services, such services are provided independently and directly by appropriately licensed third-party firms. Hampshire Capital Limited does not intermediate, promote, arrange, or participate in any regulated investment activity.

Date last updated: 29-11-2025

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