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.

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.

Whichever 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).