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Privacy Policy

At Elite Capital and Management Services Limited, we are committed to maintaining the trust and confidence of visitors to our website. We want to assure you that we do not sell, rent, or trade your personal data with other companies for their own marketing purposes.

This Privacy Policy outlines when and why we collect your personal information, how we use it, the limited circumstances under which we may disclose it to others, and how we keep it secure.

Who Are We?

Bayuti is a product owned and promoted by Elite Capital and Management Services Limited (“we,” “us,” or “our”), a company incorporated in the United Kingdom with its registered office at 809 Salisbury House, 29 Finsbury Circus, London EC2M 7AQ, and Companies House number 10347767.

Elite Capital and Management Services Limited is authorised and regulated by the Financial Conduct Authority (FCA) in the UK under Firm Reference Number: 822039. As the data controller, Elite Capital and Management Services Limited determines the purposes for which, and the manner in which, your data is processed under the Data Protection Act 2018 (“DPA”) and the UK General Data Protection Regulation (“UK GDPR”).

We are registered with the Information Commissioner’s Office (ICO) to process your personal data under registration number ZA218720.

Summary

Elite Capital and Management Services Limited is committed to protecting your personal data and privacy. Unless otherwise required by law or to perform our contract with you, we will process your personal data only as described in this policy or as you direct.

This policy, together with the Investor Terms & Conditions, explains how any personal data we collect from you, or that you provide to us, will be processed by us or any processor on our behalf. It applies to our contract with you, so please read it carefully.

This policy applies only to the actions of Elite Capital and Management Services Limited and any agents acting on their behalf. It does not extend to any third-party websites, even if accessible via our website.

What Data Do We Collect?

  • Contact Information: Name, address, phone number, and email.
  • Know Your Customer (KYC) / Anti-Money Laundering (AML) Information: Identity verification and source of funds details for regulatory compliance.
  • Financial/Investment Information: Bank account details, financial transactions, and other necessary investment information.
  • Communications: Email and other exchanges with us or third parties acting on our behalf.
  • Website Usage: Usage data via cookies, as detailed in our Cookie Policy.
  • Suitability Information: Quiz responses and declarations to assess suitability for investments.
  • Consents: Marketing preferences and other consents.
  • Marketing Engagement Information: Whether you open or click on our marketing emails and other messages, and related device and approximate location data.
  • Website Security Information: Account details, including username and password.
  • Technical Information: IP address and URL data for security and analytical purposes.

We collect this information directly from you, through your use of our website and services, and, where necessary for KYC/AML checks, from identity verification providers, credit reference agencies and public registers.

How Do We Use Your Data?

We only use your personal data where we have a lawful basis to do so. These are:

  • Performance of a Contract: To open and administer your account, process your investments and transactions, and provide our services to you.
  • Legal Obligation: To carry out KYC and AML checks, assess suitability, keep records required by the FCA, and respond to requests from regulators, law enforcement or other authorities.
  • Legitimate Interests: To operate and secure our website, prevent fraud, improve our services and tell existing customers about similar products, provided these interests are not overridden by your rights.
  • Consent: To send you marketing communications where consent is required, and to use non-essential cookies. You may withdraw your consent at any time.

Marketing

With your consent, or where otherwise permitted by law (for example, where you are an existing customer and have not opted out), we may send you information about Bayuti and our products and services by email and other channels.

To manage and send our marketing communications, we use Customer.io, a customer engagement platform. We share your name, contact details, marketing preferences and information about your use of our services with Customer.io for this purpose, and Customer.io records how you interact with our messages. Customer.io acts as our data processor: it processes your data only on our instructions and under a written data processing agreement, and may not use it for its own purposes. Further information is available in Customer.io’s GDPR statement at customer.io/legal/gdpr.

You can opt out of marketing at any time by clicking the “unsubscribe” link in any marketing email or by contacting us at admin@bayuti.com. Opting out will not stop us sending you service messages about your account or investments.

Who Do We Share Your Data With?

We may share your personal data with:

  • Service Providers: Third parties who provide services to us, such as identity verification and AML screening providers, IT and hosting providers, payment and banking partners, and our marketing partners, such as but not limited to, Customer.io and HubSpot (see “Marketing” above).
  • Professional Advisers: Our lawyers, auditors and accountants.
  • Regulators and Authorities: The FCA, HMRC, the ICO, law enforcement and other authorities where required by law.
  • Business Transfers: A buyer or successor in the event of a sale, merger or reorganisation of our business.

Service providers acting on our behalf are bound by contract to keep your data secure and to use it only in accordance with our instructions.

International Transfers

Some of our service providers, including Customer.io, are based outside the UK, including in the United States. Where your personal data is transferred outside the UK, we ensure it is protected by appropriate safeguards, such as the UK Extension to the EU-U.S. Data Privacy Framework (the “UK-US data bridge”), UK adequacy regulations, or the International Data Transfer Agreement or Addendum issued by the ICO. Please contact us if you would like more information about these safeguards.

How Long Do We Keep Your Data?

We keep your personal data only for as long as necessary for the purposes set out in this policy. In most cases, we keep customer records for at least five years after our relationship with you ends, as required by anti-money laundering legislation and FCA rules, and longer where the law requires or where needed to deal with a complaint or legal claim. Marketing data is kept until you unsubscribe or ask us to delete it, after which we keep a record of your opt-out so that we do not contact you again.

How Do We Keep Your Data Secure?

We use appropriate technical and organisational measures to protect your personal data against unauthorised access, loss or misuse, including encryption, access controls and staff training. We require our service providers to apply equivalent protections.

Your Rights

Under the DPA and UK GDPR, you have rights, including:

  • The Right to Be Informed: Information provided in this Privacy Policy.
  • The Right of Access: Access your data within one month of request.
  • The Right to Rectification: Request data correction if inaccurate.
  • The Right to Erasure: Request deletion of data, subject to legal limitations; for example, we must keep certain records to meet our regulatory obligations.
  • The Right to Restrict Processing: Restrict data processing in certain circumstances.
  • The Right to Data Portability: Receive your data in an electronic format.
  • The Right to Object: Object to data processing for specific purposes.
  • The Right to Withdraw Consent: Where we rely on your consent, such as for marketing, you may withdraw it at any time. This will not affect processing already carried out.
  • Rights Related to Automated Decision-Making: Request human review of any decision made solely by automated means that has a legal or similarly significant effect on you.

To exercise these rights, contact us at Compliance@bayuti.com or call +44 204 519 5563.

We will respond to your request within one month, which may be extended by up to two further months for complex requests. We may need to verify your identity before acting on your request.

Complaints

We are committed to resolving complaints promptly and professionally. If you have any concerns regarding our service, please contact us at:

If unresolved, you may contact the Financial Ombudsman Service (FOS) at:

  • Address: Financial Ombudsman Service, Exchange Tower, Harbour Exchange, London, E14 9SR
  • Phone (UK):
  • Phone (International):

If you are unhappy with how we have handled your personal data, please contact us first so that we can try to resolve your concern. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator:

  • Website: ico.org.uk/make-a-complaint
  • Phone: 0303 123 1113
  • Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Changes to This Policy

We may update this policy from time to time. The latest version will always be available on our website, and we will notify you of any significant changes. This policy was last updated on 30th October 2026.