Welcome to Snowdon Advisory’s privacy policy
Snowdon Advisory respects privacy and is committed to protecting personal data. This privacy policy will explain how we look after personal data and set out applicable privacy rights.
This privacy policy is provided in a layered format. Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to provide information on how Snowdon Advisory collects and processes personal data, including any data provided when our services are purchased.
It is important to read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data to ensure full awareness of how and why we are using data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Snowdon Advisory Limited is the controller and responsible for personal data (referred to as the “company”, “we”, “us” or “our” in this privacy policy) collected and processed as part of our business.
Any questions about this privacy policy, including any requests to exercise legal rights, should be addressed to us using the contact details set out below.
Contact details
Please contact us in the following ways:
Full name of legal entity: Snowdon Advisory
Email address: [email protected]
Postal address: 73 Cornhill, London, EC3V 3QQ
Complaints can be made at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with any concerns before approaching the ICO so please contact us in the first instance.
Changes to the privacy policy and the duty to inform us of changes
We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
It is important that the personal data we hold is accurate and current. For those that have a relationship with us, please keep us informed of any personal data changes.
The data we collect
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 which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details, payments we have received and other details of services purchased from us.
- Transaction Data includes details about current and prospective investments made by existing or prospective investors and investees within our network.
- Profile Data includes details of the services that we have provided, interests, preferences, feedback and survey responses.
- Marketing and Communications Data includes preferences in receiving marketing from us and communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from personal data but is not considered personal data in law as this data will not directly or indirectly reveal identity. However, if we combine or connect Aggregated Data with personal data, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Failing to provide personal data
Where we need to collect personal data by law, or under the terms of a contract, and that data is not provided when requested, we may not be able to provide our services. In this case, we may also have to cancel existing services but we will send a notification if this is the case at the time.
How is personal data collected?
We use different methods to collect data including through:
- Direct interactions. We may receive information about Identity, Contact, Financial and Transaction Data where forms are filled in or through corresponding with us by post, phone, email or otherwise. This includes personal data provided when:
- applying for our services or to become part of our network;
- subscribing to our services or publications;
- requesting marketing to be sent;
- entering a survey; or
- giving us feedback or contacting us.
- Contact, Financial and Transaction Data from providers of payment services.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
How we use personal data
We will only use personal data when the law allows us to. Most commonly, we will use personal data in the following circumstances:
- Where we need to perform a contract we are about to enter into or have entered into a contract.
- Where it is necessary for our legitimate interests (or those of our client or another third party) and interests and fundamental rights of data subjects do not override those interests.
- Where we need to comply with a legal obligation.
The types of lawful basis that we will rely on to process personal data are set out below.
Generally, we do not rely on consent as a legal basis for processing personal data although we will generally obtain before sending third party direct marketing communications via email or text message. Consent to marketing can be withdrawn at any time by contacting us.
Purposes for which we will use personal data
We have set out below, in a table format, a description of all the ways we plan to use 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 personal data for more than one lawful ground depending on the specific purpose for which we are using data. Please contact us if details are required about the specific legal ground we are relying on to process personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register a new or prospective investor or investee with our network | (a) Identity
(b) Contact (c) Financial |
(a) Performance of a contract
And/or (b) Necessary for our legitimate interests (to grow our business by helping existing and prospective investors and investees find the right investment options for them) |
| To understand:
(a) existing and prospective investor needs and interests; (b) existing and prospective investee needs and interests |
(a) Identity
(b) Contact (c) Financial (d) Transaction |
(a) Performance of a contract
And/or (b) Necessary for our legitimate interests (to grow our business by helping existing and prospective investors and investees find the right investment options for them) |
| To process and deliver our services including collecting and recovering money owed to us | (a) Identity
(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract
And/or (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationships which will include:
(a) managing our network of existing and prospective investors and investees (b) notifying about changes to our terms or privacy policy
|
(a) Identity
(b) Contact (c) Profile (d) Financial (e) Transaction (f) Marketing and Communications |
(a) Performance of a contract
And/or (b) Necessary to comply with a legal obligation And/or (c) Necessary for our legitimate interests (to keep our records updated, to grow our business by helping existing and prospective investors and investees find the right investment options for them and to study how investors and investees use our services) |
| To enable completion of a survey | (a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract
And/or (b) Necessary for our legitimate interests (to study how existing and prospective investors and investees may use our services and our network, develop our services and network, and grow our business) |
| To administer and protect our business (including system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact
|
(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)
And/or (b) Necessary to comply with a legal obligation |
Marketing
We strive to provide choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Offers from us
We may use Identity, Contact, Profile, Financial, Transaction and Marketing and Communications Data to form a view on what we think an existing or prospective investor or investee may want or need, or what may be of interest. This is how we decide which services and offers may be relevant (we call this marketing).
We will send marketing communications where information is requested from us or services are purchased from us and the recipient has not opted out of receiving that marketing.
Third-party marketing
We will get express opt-in consent before we share personal data with any third party for marketing purposes.
Opting out
We can be contacted at any time to stop sending marketing messages.
Opting out of receiving these marketing messages will not apply to personal data provided to us as a result of a service purchase or other transactions with us.
Change of purpose
We will only use 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. Please contact us to get an explanation as to how the processing for the new purpose is compatible with the original purpose.
If we need to use personal data for an unrelated purpose, we will send a notification and we will explain the legal basis which allows us to do so.
Please note that we may process personal data without knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of personal data
We may share personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use personal data) above.
- Companies in our group (that is to say, our subsidiaries or parent companies, and other companies which are subsidiaries of our parent company or wholly-owned by the same beneficial owner).
- 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 personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with our instructions.
International transfers
Many of our external third parties are based outside the EEA so their processing of personal data will involve a transfer of data outside the EEA.
Whenever we transfer personal data out of the 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 personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us for further information on the specific mechanism used by us when transferring personal data out of the EEA.
Data security
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will send a notification of a breach where we are legally required to do so.
Data retention
How long will you use personal data for?
We will only retain personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationships.
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 personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Legal rights
Under certain circumstances, rights under data protection laws arise in relation to personal data to:
- Request access to personal data.
- Request correction of personal data.
- Request erasure of personal data.
- Object to processing of personal data.
- Request restriction of processing personal data.
- Request transfer of personal data.
- Withdraw consent.
Please contact us to exercise any of the rights set out above (if applicable).
No fee usually required
A fee to access personal data (or to exercise any of the other rights) is not required. However, we may charge a reasonable fee if a request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with a request in these circumstances.
What we may need
We may need to request specific information to help us confirm identity and ensure the right to access personal data arises (or to exercise any 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 ask for further information in relation to requests to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if a request is particularly complex or we have received a number of requests. In this case, we will send a notification.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give the best service and the best and most secure experience. We make sure we consider and balance any potential impact (both positive and negative) and rights before we process personal data for our legitimate interests. We do not use personal data for activities where our interests are overridden (unless we have consent or are otherwise required or permitted to by law). Further information about how we assess our legitimate interests against any potential impacts in respect of specific activities can be obtained by contacting us.
Performance of Contract means processing data where it is necessary for the performance of a contract or to take requested steps before entering into such a contract.
Comply with a legal obligation means processing personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Service providers who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
LEGAL RIGHTS
Legal rights include the right to:
Request access to applicable personal data (commonly known as a “data subject access request”).
Request correction of applicable personal data that we hold. We may need to verify the accuracy of the new data provided to us.
Request erasure of applicable personal data which involves deleting or removing personal data where there is no good reason for us continuing to process it. The right to ask us to delete or remove personal data may also arise if a right to object to processing (see below) is successfully exercised, where we may have processed information unlawfully or where we are required to erase personal data to comply with local law. Note, however, that we may not always be able to comply with a request of erasure for specific legal reasons of which we will send notification, if applicable, at the time of a request.
Object to processing of applicable personal data where we are relying on a legitimate interest (or those of a third party) and there is something about a particular situation which gives rise to an objection to processing on this ground if it impacts on fundamental rights and freedoms. A right to object may also arise where we are processing personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process information which overrides rights and freedoms.
Request restriction of processing of applicable personal data. We can be asked to suspend the processing of personal data in the following scenarios:
- To establish the data’s accuracy.
- Where our use of the data is unlawful but we have been requested not to erase it.
- Where we are asked to hold the data even if we no longer require it as the data is needed to establish, exercise or defend legal claims.
- Where there is an objection to our use of data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of applicable personal data. We will provide data to requested parties in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which we initially received consent to use or where we used the information to perform a contract.
Withdraw consent at any time where we are relying on consent to process applicable personal data. However, this will not affect the lawfulness of any processing carried out before consent is withdrawn. If consent is withdrawn, we may not be able to provide certain services that were provided before the relevant consent was withdrawn. We will advise if this is the case at the time that consent is withdrawn.