Each of Finsbury Growth & Income Trust PLC and Frostrow Capital LLP (the “Company", or “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), when you interact with us through our website and when you contact us in any other way whether by telephone email or otherwise.  Examples include: (i) when you request a copy of the Annual Report of Finsbury Growth & Income Trust PLC be sent to your home or business address; and (ii) (individuals at FCA regulated firms only) when you request a Factsheet be sent to your professional email address by Frostrow Capital LLP. This policy will tell you about your privacy rights and how the law protects you. 

It is also relevant to the Directors of Finsbury Growth & Income Trust PLC from whom we collect diversity and inclusion information, in anonymised form, in order to satisfy diversity disclosure requirements in the Listing Rules.

In addition, we collect identity verification data from our Directors and as best practice approach we wish to refer to this in our privacy notice. All such individuals can refer to the particular sections about this below.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Except in the sections relevant to our Directors, in this privacy notice “you” means website users and individuals who interact with us that through our website.

1. Important information and who we are

2. The data we collect about you

3. How is your personal data collected

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary



This privacy notice aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you register for email alerts and/or complete and submit a contact form. 

In legal terms, we are a “controller” of this information. This means that we make decisions about how and why we process your personal data and, because of this, we are responsible for making sure it is used in accordance with data protection laws.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 


Finsbury Growth & Income Trust PLC, together with Frostrow Capital LLP (Finsbury Growth & Income Trust PLC’s Alternative Investment Fund Manager) who operates this website ( are together collectively referred to as the “Company”, "we", "us" or "our" in this privacy notice.  We are both “controllers” of your personal data, which is a legal term meaning we decide how and why your personal data is processed.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below. 


Our full details are:

Registered office address:  Finsbury Growth & Income Trust PLC, 50 Lothian Road, Festival Square, Edinburgh EH3 9WJ.

Correspondence address:  Frostrow Capital LLP, 25 Southampton Buildings, London WC2A 1AL.


You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues, regarding the treatment of your personal data.


Address:  Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Tel:  0303 123 1113

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we would encourage you to please contact us in the first instance. 


We may change this policy by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


This website may include links to third-party websites, plug-ins and applications or store cookie files on your computer in order to deliver its service(s). Clicking on those links or enabling those connections may allow third parties to collect, store or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.


Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which are detailed as follows: 

  • Identity Data including:
    • Website users: first name and last name,
    • Directors of Finsbury Growth & Income Trust PLC:  first name, last name, gender, date of birth, national insurance number, home and business address, passport details or other identity documents,
  • Contact Data of website users including home or business address, personal or business email address, personal or business phone number, company name and job title.
  • Contact Data of Directors of Finsbury Growth PLC including home or business address, personal or business email address or personal or business phone number.
  • Special Category Data of Directors of Finsbury Growth & Income Trust PLC limited to race and ethnicity in accordance with Listing Rules requirements. This is collected anonymously via a survey, though there may be times the data is identifiable on an incidental basis.
  • Employment history of Directors of Finsbury Growth & Income Trust PLC including your CV or referral information.
  • Technical Data of website users including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data of website users includes information about how you use our website, products and services. 
  • Marketing Data of website users including your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Communications Data of website users includes all communications we have with you whether by email, post, phone or otherwise.  

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Data will be aggregated (also known as anonymised) in such a way as to ensure that you are not identified or identifiable from it. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We rely on our legitimate interests to aggregate your data and use it for our own reporting or analysis purposes.


We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • subscribe to our service or publications; and
    • request marketing to be sent to you;

We monitor and record telephone calls for regulatory and security purposes. We will do this for compliance with our legal or regulatory obligations, for quality control and staff training, and when we need to see a record of what has been said.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie declaration for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
    • Technical Data from the following parties:

a. Analytics, storage, tools and media providers; 
b. IP tracking service providers;
c. automated quality control tools;
d. automated security and compliance tools;
e. social media and media networks such as Twitter, LinkedIn, Instagram, YouTube and Vimeo; and
f. email distribution and survey providers;

  • Identity and Contact data from third party service providers.


We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to fulfil your instruction to receive email alerts including Factsheets (this is relevant to individuals working at FCA regulated firms only), or for us to send you by post our Annual Reports and/or responding to your enquiry.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation. For example, where we need to collect certain information about Directors of Finsbury Growth & Income Trust PLC in order to comply with our obligations under the Listing Rules (more on this below).

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email.

For example, we rely on your consent if you ask us to send you a copy of the Annual Report to your home or business address. If you reach out to us in this way, with your consent your details are shared with Finsbury Growth & Income Trust PLC’s Registrar who maintains the mailing list on our behalf.

You have the right to withdraw consent to marketing at any time by contacting us.


We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

1. To manage our relationship with you 

This includes:

(a) Notifying you about changes to our terms or privacy policy
(b) Answering any queries you may have

Type of data

(a) Identity
(b) Contact
(c) Marketing and Communications

Lawful basis for processing including basis of legitimate interest.

(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated, to study how website users interact with us, and to deal with your enquiries)

2. To administer and protect our business and this website 

This includes troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

(a) Identity
(b) Contact
(c) Technical

Lawful basis for processing including basis of legitimate interest.

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

3. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data

(a) Technical
(b) Usage

Lawful basis for processing including basis of legitimate interest.

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

4. To provide Factsheets (only if you are are a professional, working for an FCA regulated firm)  via an automated email alert service or posting the Annual Report to you

Type of data

(a) Identity
(b) Contact

Lawful basis for processing

We rely on your consent to send you our Factsheets or posting the Annual Report to you (where you have asked us to do so) .

5. To respond to queries on our Q&A platform

If you email a question to Finsbury Growth & Income Trust PLC’s Q&A feature, we will post your question to the Company’s website as well as the response provided. We will not post your identity or contact details to the website, only your question.

6. To provide gender and ethnicity information about the composition of the Board of Finsbury Growth & Income Trust PLC as part of the Listing Rules

The Listing Rules require us to collect certain information in relation to individuals on the listed Company’s Board. The information required relates to gender and ethnicity.

We only collect information on an anonymous basis through a third party service provider. We cannot see individual responses and do not use the information for anything other than our reporting obligations under the Listing Rules. 

We include this anonymous diversity and inclusion information in our Annual Reports.

It is possible that when this diversity and inclusion information is included in our Annual Reports the identity of the Director(s) concerned will be discernible to the reader (particularly if the reader is a fellow Director).  This is incidental information which they (the reader) understand.  It is not personal data which we choose to process.  

To the extent that we become aware of this from reading the Annual Reports, our lawful basis for that unintended processing is as follows.

Lawful basis for processing including basis of legitimate interest.

(a) Necessary to comply with a legal obligation (the Listing Rules)
(b) Necessary for our legitimate interests (of reporting this information in accordance with the Listing Rules)

In addition, this processing would be for a substantial public interest.

We will not process this data for any other purposes.

7. To verify the identity of our Directors

In addition, we collect identity verification data from our Directors so that we can do relevant checks in compliance with the legal and regulatory regime to which we are subject.

Lawful basis for processing including basis of legitimate interest.

(a) Necessary to comply with a legal obligation (anti-money laundering legislation)
(b) Necessary for our legitimate interests (of verifying our own clients’ identities in accordance with the regulatory regime to which we are subject)


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications. We have established the following personal data control mechanisms:


We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have consented to those.

For example, if you contact us directly and want to sign up to receive a copy of our Annual Report by post. In this case, we will ask you for your address (whether that is home address or otherwise) in order to send it to you.

With consent, we will send Factsheets to individuals at FCA regulated firms.  


We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes. 


You can ask us or third parties to stop sending you marketing messages at any time by contacting us. If you’ve given us a consent you can withdraw that consent in the same way.


Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site about aspects of your visit. For more information about the cookies we use and how you can control them, please see our cookie declaration.


We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


We may have to share your personal data with the parties set out below for the purposes as described in section 4 above.

  • Internal Third Parties as set out in the Glossary
  • External Third Parties as set out in the Glossary
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.




Wherever possible we do not transfer your personal data outside the United Kingdom and European Economic Area (EEA).

Some of our external third parties are based outside the United Kingdom and European Economic Area (EEA) so their processing of your personal data may sometimes involve a transfer of data outside the United Kingdom and EEA.

Whenever we transfer your personal data out of the United Kingdom and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data, without pre-approved transfer mechanisms, to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or United Kingdom (as appropriate).
  • Where we use providers based in the US, or in other countries outside the United Kingdom and EEA which are not deemed to provide adequate protections for personal data, we may transfer data to them on the basis of a transfer mechanism which has been approved by the European Commission and / or UK Government, as relevant, such as the EU Standard Contractual Clauses together with the UK International Data Transfer Addendum, or the UK’s International Data Transfer Agreement.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA. 


We have security arrangements in place to guard against unauthorised access, improper use, alteration, destruction or accidental loss of your personal information.

We take appropriate organisational and technical security measures and have rules and procedures in place to ensure that any personal information we hold on computer systems is not accessed by anyone it shouldn’t be. 

When we use third party organisations to process information on our behalf, we ask them to demonstrate their compliance with our security requirements and any instructions we may give them and their compliance with relevant data protection legislation throughout the time of their relationship with the Company.  These organisations take their instructions from us and their obligations with regard to what information they process and what they can do with it are agreed in the contracts we have with them.



We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: Request erasure of your personal data below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 



Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 

If you wish to exercise any of the rights set out above, please contact us.


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 us 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 our response.


We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 



Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.


Internal Third Parties

Frostrow Capital LLP of 25 Southampton Buildings, London WC2A 1AL, Finsbury Growth & Income Trust PLC’s Alternative Investment Fund Manager, who acts as a separate controller and operates this website on behalf of Finsbury Growth & Income Trust PLC. 

External Third Parties

  • Third party service providers such as telephone providers, email providers, IT service providers, website hosting providers, registrars, printers and fund administrators.
  • Professional advisers, including lawyers, bankers, auditors and insurers and compliance consultants.
  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Fraud prevention agencies.
  • Event organisation companies and venues for events.



You have the right to:


Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.


Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.


Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 


Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.


Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 


Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 


Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Last updated: January 2023