Privacy & Cookie Policies – July 2024

Privacy Notice

We are Titan Wealth Holdings Limited (“Titan Wealth”) and treating individuals and their personal information with respect reflects our core values as a business. Titan Wealth is committed to upholding the laws and guidance that protect you and your personal information, respecting your privacy and keeping your information safe. We also want you to be fully informed about what we do with your personal information and that is the purpose of this privacy notice.

You can find out full information about how and why we use your personal information by expanding each of the sections below.

If we collect your personal information in connection with recruitment activities you can see our privacy notice that is relevant to that activity here.

In this privacy notice any reference to “us”, “we”, “our” or “ourselves” is a reference to the Titan Wealth Group (being Titan Wealth Holdings Limited and our subsidiaries) and any reference to “you”, “your” or “yourself” is a reference to you as someone who has a relationship with us, contacted us or interacted with us in some way.

For the purposes of data protection laws and this privacy notice, we are the controller of your personal information, meaning that we are responsible for deciding how we hold and use your personal information. Titan Wealth’s registered office is at PO Box 264, Forum 4, Grenville Street, St Helier, Jersey, JE4 8TQ (company number: 132723), but our business address is at 101 Wigmore Street, London, W1U 1QU.

However, this privacy notice will cover you if you interact with us or we process your personal information for any other reason. For example, this privacy notice will cover someone who uses our website or who links to or follows our LinkedIn account, a director or key person on a prospective, new or existing investment, a member of the public who contacts us, or anyone else who is affected by our activities. This privacy notice provides details in accordance with data protection laws about how we collect and use personal information about you during and after your relationship with us.

As this privacy notice covers a wide range of individuals and different types of relationships and interactions with us, not all aspects of this privacy notice may apply to you depending upon the nature of your relationship, interactions with us and why we are processing your personal information.

If we collect your personal information in connection with recruitment activities you can see our privacy notice that is relevant to that activity here.

If you have any queries regarding your personal information you can email [email protected].

We are committed to being transparent about how we collect and use your personal information and in meeting our data protection obligations. Data protection laws say that the personal information we hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

To make sure this happens we are required under data protection laws to notify you of the information contained in this privacy notice. It is important that you read this document before you begin interacting with us or deal with us in any way so that you understand how and why we will process your personal information.

In connection with your relationship or interactions with us, we may collect and process a wide range of personal information about you. This includes:

  • Personal contact details such as name, title, address, email address and telephone number(s), date of birth, age, gender, marital status, next of kin, dependants, family members and emergency contacts.
  • Bank account details, financial transactions and payments.
  • Any communications between ourselves and you.
  • Details of services carried out by us or you in connection with our relationship with you or your organisation, details of your interest in and connection with any organisation to which we supply any services or which supplies any services to us, and information linked with any products or services supplied by or to us.
  • Business related information, such as where you are a sole trader, a partner or a company director or a key member of staff of a business we have a relationship with.
  • Publicly available personal information, including any which you have shared via a public platform, online or on social media and also non-public personal information where you have followed or linked to any of our social media.
  • Details of your education or work history including organisations, positions, roles, responsibilities.
  • Creditworthiness as we may undertake investigations in order to establish whether to enter into or continue a business relationship with you or your organisation.
  • How you use our website as we collect information about the pages you look at and how you use them, usernames, account details and passwords, IP addresses, entry and exit data when you look at or leave our website, details of services that may be of interest to you, online subscription information (for example when you ask to receive our updates) and browser related information.
  • Identification information including your driving licence and/or passport and background checks.
  • Details of any queries, complaints, claims and cases involving both us and yourself including any related communications.
  • Information from Companies House about you and non-public details of shareholdings, investments or other interests you may have and any dealings you may have in any of them.
  • You may give us personal data about you by filling in forms online, corresponding with us by phone, email, in person, or otherwise, or through other third parties.
  • Any other personal information you provide to us.

In cases where it is relevant, we may also collect criminal records information about you, for example an offence committed by you or alleged to have been committed by you that impacts on your relationship with us.

If you are providing us with details of any other individuals they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with them. They also have the same rights as set out in this privacy notice in relation to their personal information that we collect.

Our website, materials and other services we provide are not intended for use by anyone under the age of 18 years and we do not knowingly collect personal information relating to anyone under the age of 18 years old unless for some reason you provide it to us.

  • Often most of your personal information is collected directly from you, for example through contact with you, from your passport or other identity documents such as your driving licence; from correspondence with you, meetings or other interactions with us or other personal information you provide to us.
  • If you work for an organisation that has a relationship with us, then we may collect some of your personal information from them.
  • From our website, other websites, the internet, LinkedIn page or other platforms including public sources of information.
  • Third parties such as Companies House, professional or trade organisations.
  • From our website and information technology and communications systems, access control systems and suppliers we use in connection with them.
  • From third parties appointed by you, for example any financial or legal advisors.
  • From third parties appointed by us, for example legal advisors appointed by us or credit reference agencies, identity or background check providers, data cleansing service providers or market/data research providers, analysis service providers.
  • From government or government related bodies, such as the Jersey Financial Services Commission or other financial services regulators, the police, law enforcement authorities, the security services and Disclosure and Barring Service in respect of criminal convictions.
  • Third parties including governmental authorities (such as local tax authorities), your named referees who you’ve asked to provide us with references, other publicly available sources such as social media networking sites.

There are many ways we may need to use your personal information in the context of your relationship with us or our use of your personal information. We will only use your personal information when the law allows us to. This means we must have one or more legal bases to use your personal information.

We have set out the main uses below, and indicated the main applicable legal bases of processing, but there may be other specific uses which are linked to or covered by the uses below.

Use of data Legal basis
Carry out our regulatory activities in relation to you, an organisation you work for or an organisation of which you are a client or customer.
  • Pursuing our legitimate interests
  • Compliance with legal obligations
Conduct any business or other relationship we have with you, an organisation you work for or an organisation of which you are a client or customer.
  • Pursuing our legitimate interests
  • Compliance with legal obligations
  • Necessity to enter into or perform a contract you are a party to
  • We may also rely on your consent in some limited cases
Monitor, manage or record our relationship with you or an organisation which you work for, which may involve meetings, assessments, communications with you, and decisions regarding your relationship with us.
  • Necessity to perform a contract you are a party to
  • Pursuing our legitimate interests
Carry out investment due diligence.
  • Pursuing our legitimate interests
  • Compliance with legal obligations
Carry out background, identity or other checks in relation to you to decide whether to enter into a business relationship with you and in some cases to understand whether you are ‘fit and proper’.
  • Pursuing our legitimate interests
  • Compliance with legal obligations
  • We may also rely on your consent in some limited cases
Satisfy legal and regulatory obligations including  complying with data protection laws, making filings at Companies House, ensuring equality and equal opportunities or invoking other legal rights.
  • Compliance with legal obligations
  • Pursuing our legitimate interests
Keep and maintain proper records relating to your relationship with us or an organisation you work for and information about you which is relevant to that relationship.
  • Necessity to enter into or perform a contract you are a party to
  • Pursuing our legitimate interests
  • Compliance with legal obligations
Prevent, detect or prosecute criminal activity
  • Pursuing our legitimate interests
  • Compliance with legal obligations
  • Acting in the public interest
Respond to any query, complaint or enquiry received from you.
  • Pursuing our legitimate interests
  • Compliance with legal obligations
Gather evidence for and be involved in possible legal cases.
  • Necessity to enter into or perform a contract you are a party to
  • Pursuing our legitimate interests
  • Compliance with legal obligations
  • Establish, exercise or defend legal claims
Ensure effective general business administration and manage our business.
  • Necessity to enter into or perform a contract you are a party to
  • Pursuing our legitimate interests
  • Compliance with legal obligations
Monitor your use of our website and social media accounts to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
  • Pursuing our legitimate interests
  • Compliance with legal obligations
Conduct data analytics and analysis studies and improve our business, use of our website and social media which relates to us.
  • Pursuing our legitimate interests
  • Compliance with legal obligations
Carry out market research, so that we can better understand the organisations we regulate or provide services to.
  • Pursuing our legitimate interests
  • Compliance with legal obligations

Where we are processing any sensitive “special category” personal information about you (which covers personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning your sex life or sexual orientation) then we also need to have one or more of the following conditions for using your personal information. These include:

  • Where we have your explicit consent to do so.
  • Where it is necessary for us to comply with our obligations and exercise our rights in the field of employment law, social security law and social protection law.
  • Where we need to protect your vital interests (or someone else’s vital interests).
  • Where you have already made the personal information public.
  • In establishing, exercising or defending legal claims, whether those claims are by us or against us.
  • Where it is necessary in the public interest.

We will not usually process any of these types of special category personal information about you, and in cases where we do process special category personal information about you it will generally be to comply with legal obligations, where you have given your consent or to establish, exercising or defending legal claims. In some cases more than one legal bases may apply to our use of your personal information.

Where we process criminal records information about you, then we will either do so either to comply with legal obligations or with your consent.

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you by updating this privacy notice on our website, so please check back regularly for any updates.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. We will rarely need to rely on your consent to process any of your personal information.

Automated decision-making takes place when an electronic system uses personal information to make a decision about that person without any human intervention which produces legal effects concerning them or similarly significantly affects them. We do not currently use this type of automated decision making in our business in relation to you.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision making unless we have a lawful basis for doing so and we have notified you.

When using your personal information we may share it with third parties but we will only do so when it is appropriate and we have a legal basis for doing so. Third parties that we may share your personal information with include:

  • Any third party approved by you or where we need to do so to enter into or perform a contract with you.
  • An organisation you work for or that represents you if that organisation has a relationship with us.
  • Service or product providers to our business, for example information technology services suppliers, credit reference agencies, marketing and public relations service providers.
  • If you represent one of our suppliers, to other companies in the supply chain so they can contact you about any supply chain issues.
  • Third parties that process personal information on our behalf and in accordance with our instructions, usually suppliers of services to us.
  • Purchasers, investors, funders and their advisers if we sell all or part of our business, assets, shares or restructure whether by merger, re-organisation or in another way.
  • Other members of our group.
  • Our legal and other professional advisers, including our auditors or any professional advisors appointed by you, for example a legal advisor or an agency you work with.
  • Third party record keepers, for example to make filings at Companies House.
  • Social media and other online platforms where relevant to our relationship with you.
  • Governmental bodies, HMRC, other regulators (including the Jersey Financial Services Commission and sometimes the ICO), police, law enforcement agencies, security services, courts/tribunals.
  • We may also use other service providers for marketing purposes. Marketing use a third-party data partner to store personal data, contact data, and marketing preferences provided by you.

We do not disclose personal information to anyone else except as set out above unless we are legally entitled to do so.

It may be necessary to share your personal information outside of the UK and the European Economic Area (the “EEA”). We may typically do this when service providers to our business are located outside the UK or EEA. These transfers are subject to special rules under data protection laws and additional protections will be applied. For example, the jurisdiction outside of the UK or EEA to which personal information is transferred may be approved by the UK Government, the European Commission or another data regulator, or the recipient may have agreed to standard contractual clauses approved by the UK Government, European Commission or a data regulator that oblige them to protect the personal information.

In all circumstances, we will ensure that the transfer is compliant with data protection laws and all personal information will be secure.

Our directors and other key staff working for us may in limited circumstances access personal information from outside of the UK and EEA if they are on holiday abroad outside of the UK or EEA. If they do so they will be using our security measures and the same legal protections will apply that would apply to accessing personal information from our premises in the UK.

In limited circumstances the people to whom we may disclose personal information may be located outside of the UK and EEA and we will not have an existing relationship with them. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

For the purposes of UK and/or European data protection laws (where applicable), your personal information may also be processed outside the UK or EEA when we use suppliers who have global operations.

If you would like any more details about how we protect your personal information in relation to international transfers, including a copy of any standard data protection clauses entered into with recipients of your personal information, then please email [email protected].

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. We will hold your personal information for the duration of your relationship with us or the reason we were processing it, and then usually for a further period of up to 6 years after that. This may apply where you are a contact or client we provide services to. However, for some business relationships, for example those relating to land or our leases of premises, we may need to keep records for 12 years or more.

aWhichever time period normally applies, in some cases we may need to keep your personal information for longer, for example if it is still relevant to a dispute or legal case or claim or a regulatory matter.

We will not retain your personal information for longer than necessary for the purposes for which it was collected and it is being used. We do not guarantee to retain your personal information for the whole of the periods set out above; they are usually the maximum period, and in some cases we may keep your personal information for a much shorter period.

As an individual whose personal information we collect and process, you have a number of rights. You may:

  • Withdraw any consent you have given to us, which is an absolute right (although this will only be relevant where we are relying on your consent as a basis to use your personal information). Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes for which you originally gave your consent, but withdrawing consent will not affect use that has already happened.
  • Request details about how your personal information is being used. This right is linked with the right of access mentioned below.
  • Request access and obtain details of your personal information that we hold (this is commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This means that you can ask us to delete or stop processing your personal information, for example where we no longer have a reason to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (set out below). The right to have data erased does not apply in all circumstances.
  • Object to the processing of your personal information where we are relying on a legitimate interest (ours or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
  • Object to direct marketing where we are processing your personal information for direct marketing purposes. This is an absolute right.
  • Request the restriction of processing of your personal information. This enables you to ask us to stop processing your personal information for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing your personal information.
  • Request the transfer of your personal information to another party in certain circumstances.
  • Object to certain automated decision-making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your personal information to another service provider or the right to object to automated decision making, may not always apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal information which has legal or other significant effects for you. However, some of your rights have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

If you would like to exercise any of these rights, please contact us at [email protected].

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person or dealt with by a person who has no right to do so.

Generally, you are not obliged to provide us with any of your personal information. However, please note that in some cases failing to provide certain information may have an adverse impact on our ability to interact with you.

We keep our privacy notice under regular review and may update this privacy notice from time to time. The current version of this notice is available on our website at www.titanwh.com and by requesting a copy from [email protected]. If there are any material changes to this privacy notice in the future we will let you know, usually by updating the version on our website.

Our website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others. The personal data that you provide through these websites is not subject to this privacy notice and the treatment of your personal data by such websites is not our responsibility.

If you follow a link to any other websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites.

We are not required to appoint a data protection officer to oversee our compliance with data protection laws. If you have any queries regarding our use of your personal information or this privacy notice then please contact us at [email protected] or write to us at our business address at 101 Wigmore Street, London, W1U 1QU.

We hope you don’t have any reason to complain, and we will always try to resolve any issues you have, but you have a right to lodge a complaint with a data protection supervisory authority, in particular in the country where you are habitually resident, where we are based or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner’s Office (Tel: 0303 123 1113 or at www.ico.org.uk).

Cookie Policy

In this Cookies Policy, any reference to “us”, “we”, “our” or “ourselves” is a reference to the Titan Wealth Group (being Titan Wealth Holdings Limited and our subsidiaries).

This Cookie Policy explains how we and trusted third parties use cookies and similar technologies on this website (the “Website”), as well as your choices related to those cookies. Please review this Cookie Policy to learn more about the types of cookies we use, why we use them and how you can control or limit the use of cookies.

If we collect personal data via cookies or similar technologies, such personal data will be treated in accordance with our Privacy Notice. Please refer to our Privacy Notice for more information about our privacy practices.

Cookies are small text files that are installed on your browser, computer or mobile device. They allow a website to recognise your device. Cookies can serve several purposes: to ensure that the website takes the user’s preferences into account by storing language preferences, to collect statistical data and adapt the content. Cookies can help provide you with a good experience when you browse websites and also help improve website functionality.

When you visit the Website, we use cookies to collect certain information automatically. We may also use other technologies such as pixel tags, browser analysis tools, server logs, web beacons, and other tracking technologies for similar purposes as described in this Cookie Policy and we may include them on our sites, in marketing email messages or our newsletter and affiliated websites to determine whether messages have been opened and whether links have been clicked on. The information provided below about cookies also applies to these technologies.

We use different cookies for different things, such as:

  • analysing how visitors move through our Website, where they have come from and the pages they visit;
  • counting the number of visitors to our Website;
  • compiling reports and helping us improve the Website; and
  • providing details of services that may be of interest to you.

To find out more about the different kinds of cookies we use and how you can manage them, please see the sections below titled “Cookies we use” and “Managing cookies”.

We use the following categories of cookies on our Website:

  • Strictly necessary cookies. Strictly necessary cookies are cookies that are required for the operation of our Website and cannot be switched off in our systems. You can set your browser to block or alert you about these cookies, but some parts of the Website will not then work.
  • Functional cookies. These cookies enable our Website to provide enhanced functionality and personalisation. They may be set by us [or by third party providers whose services we have added to our pages].  If you do not allow these cookies then some or all of these services may not function properly.
  • Performance cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website. If you do not allow these cookies we will not know when you have visited our Website and we will not be able to monitor its performance.
  • Targeting cookies. These cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisings on other sites. If you do not allow these cookies, you will experience less targeted advertising.

Set out below is a list of the cookies, by category, we use on our Website.

Cookie name Cookie Owner & Purpose Duration of cookie

 

Strictly necessary cookies
ASP.NET_SessionId Used by ASP.NET to maintain session state by storing a unique identifier for the duration of the user’s session. This identifier allows session data associated with the user to be retrieved across multiple requests The cookie is extended for 4 hours after the user interacts with the websites
AspNet The cookie is used to store authentication information for users who have successfully logged in. The cookie is extended for 20 minutes after the user interacts with the website.
OpenIdConnect.nonce GBO Application

The cookie is used during user login to provide protection against replay attacks and maintain the integrity of the authentication process

Cookie exists for the duration of the login process and is cleared thereafter.
AspNetCore.Antiforgery The cookie is used by the application to provide protection against Cross-Site Request Forgery (CSRF) attacks. Exists for the duration of the authentication page while the user is logging in.
Functional cookies
_dd_s Datadog.

Cookie used to group all events generated from a unique user session across multiple pages. It contains the current session ID, whether the session is excluded due to sampling, and the expiration date of the session.

The cookie is extended for an extra 15 minutes every time the user interacts with the website, up to the maximum user session duration (4 hours).

You can choose whether to accept or reject to the use of cookies at any . For the GBO system, confirmation of an understanding of cookies used is required.

You can also use your browser settings to generally block cookies, remove existing cookies or change your cookie settings.  However please note that if you do this you may not be able to use the full functionality of the Website.

For more information on deleting or blocking cookies, please also visit: http://www.allaboutcookies.org.

We reserve the right to amend this Cookie Policy from time to time. We will inform you on any material changes via the Website.

If you have further questions about the Website or about this Cookie Policy, please contact us by email at [email protected].

© Titan Wealth Solutions 2024