Website Privacy Policy

Overview

This privacy policy (“Privacy Policy”) explains how Titanbay Ltd, a company incorporated in England and Wales with company number 12175760 and registered office at 3rd Floor Elsley House, 20/30 Great Titchfield Street, London, W1W 8BF (“Titanbay”, “we”, “us” or “our”), collects, uses, shares and otherwise processes your Personal Data (defined below) in connection with your relationship with us in accordance with applicable data privacy laws, including the UK General Data Protection Regulation, as defined in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018 (“UK GDPR”), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”). Unless you are otherwise advised via any other documentation or notification received from us or our affiliates, we shall be the data controller in respect of the Personal Data (as defined below) described in this Privacy Policy (the “Data Controller”). A Data Controller is the person or organisation that determines the purposes and means of the processing of Personal Data, and is responsible for that processing under the UK GDPR.

The information set out herein applies to the personal information (also known as “Personal Data”) that we collect about you when you visit our website.

This Privacy Policy applies only to Personal Data we collect through this website. If you are an investor or prospective investor in a fund managed or advised by another member of the Titanbay group, or you otherwise use the Titanbay platform, please refer to the Platform Privacy Policy.

What is Personal Data?

The term “Personal Data” as used in this Privacy Policy means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier. This definition provides for a wide range of personal identifiers which may constitute Personal Data, including name, business address, identification number, location data or online identifier. Personal Data does not include data from which you can no longer be identified such as anonymised aggregate data.

Cookies

What are cookies and how do we use them?

Cookies are small text files that can be used by websites to make a user’s experience more efficient. This website uses cookies which are unique to your web browser. They will contain some information such as a unique identifier and some digits and numbers.

Some cookies are strictly necessary for our website to work and to provide the service you have requested. These are placed without your consent, as permitted by PECR. Certain analytics and functionality cookies are also exempt from consent under PECR, where they are used solely for statistical or functionality purposes; we do not currently rely on those exemptions, and we treat all analytics cookies as requiring consent. All other cookies, including performance, analytics, functionality and marketing cookies, will only be used on our website (www.titanbay.com) if you consent to them through our cookie banner, in accordance with PECR and, for visitors in the EEA, applicable national laws implementing the ePrivacy Directive (Directive 2002/58/EC). You may withdraw or change your consent at any time through the cookie banner.

How to change or delete cookies?

If you want to restrict or block the cookies set by our website, you can do so through the cookie banner or through your browser settings. Alternatively, you can visit www.allaboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers and devices. You will find general information about cookies and details on how to delete cookies from your device.

How do we collect personal data and what kind of information do we collect?

A detailed description of why and on what legal basis we process Personal Data, and the types of Personal Data we process for each purpose, is set out below (see “Detailed Description of Processing”).

General browsing will utilise cookies as outlined above. In the event you fill out a “contact us” or demo request form on our website, subscribe to our newsletter, or otherwise correspond with us, the kinds of Personal Data we may collect include information such as:

  • your contact details (such as your business address, email address and telephone number). In most cases, we will collect the Personal Data directly from you but may also obtain it from other sources (such as your professional profile on LinkedIn, other publicly available sources and/or third-party business information providers);
  • limited employment information, such as your employer or the institution you represent, your position or job title, and your business location;
  • sales and marketing information, including your marketing preferences and your engagement with our communications;
  • records of correspondence and other communications between you, your representatives and us, including the content of any enquiry or demo request you submit;
  • complaints or disputes you may have had with us or other members of the group (where applicable);
  • information that we need to support our legal and regulatory obligations; and
  • any other information you asked and authorised us to collect for or about you.

We do not knowingly collect any special categories of Personal Data (such as data revealing health, racial or ethnic origin, political opinions, religious beliefs or trade union membership) through this website, and ask that you do not submit such information to us.

What do we do with your data?

We do not make decisions about you based solely on automated processing, including profiling, which produce legal effects concerning you or which similarly significantly affect you. We do, however, carry out profiling for marketing purposes. In particular, we analyse how you engage with our website and with our communications so that we can tailor and send you information about our products and services, or those of our affiliates and business partners, that we consider may be of interest to you. Where this profiling relies on our legitimate interests, you have the right to object to this profiling at any time, including where it is carried out for direct marketing purposes, in which case we will stop processing your Personal Data for that purpose. You may exercise that right using the contact details set out below. Where the profiling relies on cookies placed with your consent, you may withdraw that consent at any time through our cookie banner.

We may aggregate or anonymise information collected through our website so that it no longer relates to an identified or identifiable individual and is therefore no longer Personal Data within the meaning of the UK GDPR. We apply aggregation and anonymisation in a manner intended to be irreversible, and we do not attempt to re-identify individuals from data that has been anonymised. We may use and share such aggregated or anonymised data — for example, aggregate statistics on website traffic and engagement — for research, reporting and marketing purposes. We do not sell your Personal Data. Save as described under "Third-Party Tools and Cookies" below, we do not enable third parties to collect your Personal Data for their own advertising purposes.

We will process your Personal Data if and to the extent applicable law provides us with a lawful basis to do so. Therefore, we will only process your Personal Data on the following grounds:

  • Consent — you have consented to us using your data;
  • Contract — we need it to perform the contract we have entered into with you, or to take steps at your request before entering into a contract;
  • Legal Obligation — we need it to comply with a legal obligation; or
  • Legitimate Interest — we (or a third party with whom we work) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Legitimate interest may include the provision of services by us (e.g. responding to enquiries about our platform), administrative or operational processes within Titanbay (e.g. keeping our website secure and available) and certain direct marketing activities (e.g. growing our institutional client base, subject to the requirements of PECR set out below). We will use your Personal Data to respond to your enquiries and to deliver services to you and/or to work or act for you. We may also use your Personal Data to inform you about us and our services or otherwise communicate with you.

Where we rely on our legitimate interests, we have carried out an assessment to satisfy ourselves that those interests are not overridden by your interests, rights and freedoms. You may request further information about that assessment using the contact details set out below.

Where we send you direct marketing by electronic mail, we will do so in accordance with PECR where you are in the United Kingdom, as described in the remainder of this paragraph. Where you are in the EEA, we will do so in accordance with the applicable national rules, which may require your prior consent even where you receive marketing in a business capacity. Where you are a corporate subscriber (for example, a limited company or a limited liability partnership), we may send you marketing by electronic mail in reliance on our legitimate interests. Where you are an individual subscriber (including a sole trader or an unincorporated partnership), we will send you marketing by electronic mail only where you have consented to receive it, or where we obtained your details in the course of negotiations for, or the provision of, our services, the marketing relates to similar services, and you were given a simple means of refusing such marketing at the point your details were collected and in every subsequent communication (the “soft opt-in”). You may opt out of marketing communications at any time by using the unsubscribe link in any communication or by contacting us using the details set out below.

Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Detailed Description of Processing

Purpose of ProcessingCategories of Personal Data ProcessedLegal Basis for Processing
To respond to enquiries, “contact us” submissions and demo requests;

To communicate with, keep records for, contract with, and provide information about our services to companies and their representatives, prospective and current clients, vendors, partners, or other contacts;

To perform marketing and research activities, including sending newsletters and other marketing communications;

To administer, improve and secure our website; and

To meet relevant legal and regulatory requirements.
Contact Information
including name, telephone number, business address, email address, marketing preferences, and the content of your enquiry or correspondence with us
Legitimate interests – responding to enquiries and demo requests; communicating with companies and their representatives; marketing and research activities; administering, improving and securing our website

Performance of a contract, or steps taken at your request before entering into a contract, where you contract with us in your own name (where our contract is with the organisation you represent, we rely on legitimate interests)

Compliance with a legal obligation – meeting relevant legal and regulatory requirements

Consent – where required under PECR for marketing by electronic mail, and for non-exempt cookies
To understand the organisation you represent and your role within it, so that we can direct and respond to your enquiry appropriately and tailor the information we provide;

To perform marketing and research activities; and

To meet relevant legal and regulatory requirements.
Employment Information
including employer or institution, position/title or role, and business location
Legitimate interests – understanding the organisation you represent and your role within it; marketing and research activities

Compliance with a legal obligation – meeting relevant legal and regulatory requirements

Consent – where required under PECR for marketing by electronic mail

Information Collected Automatically

As is true of most websites, we may gather certain information automatically when you use our website. This information may include browser, device, cookie and similar data that we collect as follows:

Purposes of ProcessingCategories of Personal Data ProcessedLegal Basis for Processing
To maintain the security of the Titanbay website, for fraud detection, and to protect Titanbay’s rights.Internet or other electronic network activity
including IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data
Legitimate interests
To manage the Titanbay website and email messages and to collect and track information about user activities online over time and across different websites and social media channels to personalise content.Cookies, Analytics and Related TechnologiesConsent, obtained through our cookie banner in accordance with PECR
To offer certain location-based services, such as delivering marketing that is location-relevant, and to conduct analytics to improve the Titanbay website.Location Information
including approximate location derived from your IP address, together with date and time (the precision of this data varies greatly and is determined by factors controlled by your device or internet service provider)
Consent, obtained through our cookie banner in accordance with PECR
To measure the effectiveness of our advertising on third-party platforms and to build audiences for future advertising campaigns.Advertising and Related Technologies
including IP address, device and browser characteristics, pages viewed and timestamps, collected through the LinkedIn Insight Tag and Google Ads
Consent, obtained through our cookie banner in accordance with PECR

Information we may need from you

What might we need from you?

We may need to request specific information from you to help us confirm your identity and ensure your right of access to your Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. Where we reasonably require that information, or further information to clarify the scope of your request, the period for responding to your request does not begin until we have received it.

Accuracy of information

It is important that the Personal Data we hold about you is accurate and current. Please let us know promptly if your Personal Data changes during your relationship with us.

What if you do not provide the Personal Data we request?

It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to respond to your enquiry or demo request, send you information about us (e.g. marketing materials), accept an engagement from you to provide all or some of our services or, to enter into a contract with you.

Change of purpose and anonymisation

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 which is compatible with the original purpose. 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.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

With whom will we share your information?

When using your Personal Data for the purposes and on the legal basis described above we may share your Personal Data with other service providers we work with. This includes but may not be limited to, other entities within the Titanbay group of companies. We may also have to share your Personal Data with regulators, public institutions, courts or other third parties.

Category of RecipientsPersonal Data SharedPurposes for which the Personal Data is Shared
Service Providers, AgentsContact Information
including name, telephone number, business address and email address

Employment Information
including employer or institution, position/title or role, and business location
To anyone providing a service to us or acting as our agent, as data processors, or for the purposes of providing services to us and on the understanding that they will keep the personal data confidential and only process it in accordance with our instructions and the UK GDPR.
Auditors, Legal Advisors, Other AdvisorsContact Information
including name, telephone number, business address and email address

Employment Information
including employer or institution, position/title or role, and business location
Where we need to share personal data with our auditors, legal and other advisors.
Regulatory bodies, law enforcement, courts and other public authoritiesContact Information
including name, telephone number, business address and email address

Employment Information
including employer or institution, position/title or role, and business location
Where we are required or requested to share information with a regulatory or oversight body, or where disclosure is necessary to comply with a legal obligation, court order or other legal process.
Advertising platforms (joint controllers)Advertising and Related Technologies
including IP address, device and browser characteristics, pages viewed and timestamps
Where you accept marketing cookies, information is collected through the LinkedIn Insight Tag and Google Ads and transmitted to LinkedIn and Google respectively, with each of whom we are joint controllers for that collection and transmission. See “Third-Party Tools and Cookies” below.

Some of our service providers, including our website analytics and advertising providers, are located in the United States. The United States is the subject of UK adequacy regulations in respect of organisations certified under the UK Extension to the EU-US Data Privacy Framework, and we transfer Personal Data to those providers in reliance on those regulations. We check that each provider’s certification remains active and covers the categories of Personal Data concerned. For the purposes described above, from time-to-time, we may have to transfer your Personal Data from the United Kingdom to a third party outside of the United Kingdom in a jurisdiction which is not the subject of UK adequacy regulations made under the Data Protection Act 2018. Details of any such jurisdictions are set out in the Appendix hereto, which may be updated from time to time. In such cases, we will always ensure that there is a legal basis and a relevant safeguard method for such data transfer – such as the International Data Transfer Agreement or the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses issued by the Information Commissioner, supported by a transfer risk assessment – so that your Personal Data is treated in a manner that is consistent with and respects UK law and other applicable laws and regulations on data protection. You may request a copy of the safeguards we have put in place by contacting us using the details set out below.

EEA Visitors

If you access this website from the European Economic Area (“EEA”), the General Data Protection Regulation (EU) 2016/679 ("EU GDPR") also applies to our processing of your Personal Data, in addition to the UK GDPR. References in this Privacy Policy to Personal Data, Data Controller and related terms carry the same meaning under the EU GDPR, and the rights described under "Your rights in relation to your information" below are available to you, subject to any differences under the EU GDPR. In particular, under the EU GDPR you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, other than in the circumstances permitted by Article 22 of the EU GDPR.

As Titanbay Ltd is established in the United Kingdom and has no establishment in the European Union, we have appointed Titanbay Ireland Limited as our representative in the European Union under Article 27 of the EU GDPR. You may contact our EU representative, in addition to us, on any matter relating to our processing of your Personal Data, at 26/27 Pembroke Street Upper, D02 F5Y6, Dublin, Ireland.

In addition to your right to complain to the UK Information Commissioner's Office as described below, you have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work, or the place of the alleged infringement.

Where we transfer your Personal Data outside the EEA, including to the United States, we do so on the basis of an EU adequacy decision (such as certification under the EU-U.S. Data Privacy Framework) or another appropriate safeguard recognised under the EU GDPR, such as the European Commission's Standard Contractual Clauses. You may request a copy of the safeguards we have put in place by contacting us using the details set out below.

Disclosure of Personal Information to Affiliates

Titanbay may share Personal Data with other entities within the Titanbay group of companies, including our Irish and Luxembourg group entities, to the extent necessary or appropriate for those entities to perform services for your benefit or to support the operation and administration of our business. Those entities are required to keep such Personal Data confidential to the same extent as Titanbay and to process it in accordance with this Privacy Policy and applicable data protection law.

Third Parties

The website may, from time to time, include links to third-party websites or enable individuals the opportunity to disclose information directly to third parties. This Privacy Policy does not apply to such third-party websites or organisations. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

Third-Party Tools and Cookies

This website uses the third-party tools and cookies listed below to help it function, to understand how the website is used, and, where you consent, for advertising. Cookiebot manages your consent choices in accordance with the UK GDPR and PECR (and, for visitors in the EEA, the EU GDPR and applicable national ePrivacy laws): strictly necessary tools operate without your consent; all others operate only once you accept the relevant category of cookies through our cookie banner, and you can withdraw that consent at any time through your cookie settings. Withdrawal takes effect for the future only. Details of the specific cookies set by each tool, including their duration, are available in our cookie banner.

1. Cookiebot

Cookiebot, provided by Usercentrics A/S (including its Cybot A/S branch), Havnegade 39, 1058 Copenhagen, Denmark, is the consent management platform we use to record and manage your cookie consent choices, and to block non-essential cookies from loading until you have consented to them. This is strictly necessary for the website to comply with PECR and does not require your consent. Further information: https://www.cookiebot.com/en/privacy-policy/.

2. Google Analytics and Google Ads

Google Analytics and Google Ads are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) (“Google”). Where Personal Data is transferred to Google's servers in the United States, we rely on Google's certification under the UK Extension to the EU-U.S. Data Privacy Framework or, where that does not apply, the International Data Transfer Agreement (IDTA) or the UK Addendum to the European Commission's Standard Contractual Clauses.

Google Analytics uses cookies to help us understand how visitors use this website (for example, pages viewed, time on site and referring pages), so that we can improve it. Based on your consent to analytics cookies, given through our cookie banner (in accordance with PECR and the UK GDPR), Google processes this data under the Google Ads/Analytics Data Processing Terms. Further information: https://policies.google.com/technologies/partner-sites.

Google Ads is used, based on your consent to marketing cookies, to measure the effectiveness of our advertising on Google's network and to build audiences for future campaigns, in a similar way to the LinkedIn Insight Tag described below. We and Google are joint controllers in respect of the collection of that information through Google’s tags on our website and its transmission to Google, on the same basis as described for LinkedIn below. Google’s subsequent use of the information, including for its own advertising purposes, is determined by Google alone and is governed by Google’s privacy policy. Further information: https://policies.google.com/technologies/partner-sites.

3. LinkedIn Insight Tag

With your consent to marketing cookies, we use the LinkedIn Insight Tag, provided by LinkedIn Ireland Unlimited Company and LinkedIn Corporation (together, “LinkedIn”). It allows us to measure the effectiveness of our LinkedIn advertising (e.g. whether visitors who arrived from a LinkedIn ad completed a particular action) and to build audiences for future campaigns. When active, it collects information such as your IP address, device and browser characteristics, the pages you view, and timestamps, and, if you are signed in to LinkedIn, it may link this information to your LinkedIn account. This information is sent directly to LinkedIn. We and LinkedIn are joint controllers in respect of the collection of that information through the tag and its transmission to LinkedIn. Our role is limited to that stage, and we receive only aggregated reporting on the performance of our campaigns; we do not receive individual-level data from LinkedIn. LinkedIn’s subsequent use of the information, including for its own advertising and platform purposes, is determined by LinkedIn alone and is governed by LinkedIn’s privacy policy. You may exercise your data protection rights in relation to the collection and transmission stage against either us or LinkedIn, using the contact details in this Privacy Policy or those set out in LinkedIn’s privacy policy. In essence: we decide to embed the tag on our website and control whether it loads, through your consent via our cookie banner; LinkedIn decides the technical means by which the tag operates and by which your information is collected and transmitted to its servers. As between LinkedIn and us, each of us is responsible for our own part of this arrangement, and neither of us is responsible for the other’s processing outside the collection and transmission stage. This allocation does not limit your ability to exercise your rights against either of us. We load the tag and set its cookies only if you accept marketing cookies via our cookie banner; you can withdraw consent at any time through the cookie settings, after which the tag no longer loads. Withdrawal operates for the future only and does not affect information already transmitted to LinkedIn; you can manage that information through your LinkedIn account settings or by contacting LinkedIn. To opt out of LinkedIn's use of your data for advertising: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. Further information is set out in LinkedIn's own privacy notice: https://www.linkedin.com/legal/privacy-policy.

4. Spotify

Where this website embeds Spotify content (for example, a podcast player), Spotify AB, Regeringsgatan 19, 111 53 Stockholm, Sweden (“Spotify”) may set cookies to enable the embedded player to function and to remember your playback preferences. Based on your consent, given through our cookie banner, Spotify processes this data under its own privacy policy. Further information: https://www.spotify.com/uk/legal/privacy-policy/.

5. Vimeo

Where this website embeds Vimeo video content, Vimeo.com, Inc., 330 West 34th Street, 10th Floor, New York, NY 10001, USA (“Vimeo”) sets a bot-detection cookie (__cf_bm) used to distinguish human visitors from automated bots in order to protect the embedded player against malicious automated traffic. This is strictly necessary for the embedded content to function securely and does not require your consent. Vimeo has appointed the European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium, as its EU representative. Further information: https://vimeo.com/privacy.

Your rights in relation to your information

You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

  • request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
  • request rectification of your Personal Data;
  • request the erasure of your Personal Data;
  • request the restriction of processing of your Personal Data;
  • object to the processing of your Personal Data where we are relying on our legitimate interest(s) (or those of a third party) as a lawful basis for such processing;
  • object at any time to the processing of your Personal Data for direct marketing purposes;
  • request the transfer of your Personal Data to another organisation, or directly to you, under certain conditions; and
  • where we make a decision about you based solely on automated processing, including profiling, that produces a legal effect or other similarly significant effect on you: to be given information about the decision, to make representations about it, to obtain human intervention on our part and to contest the decision. Further restrictions apply where such a decision involves special category Personal Data.

How to complain

If you are unhappy with how we have collected or used your Personal Data, you have the right to complain to us. You may do so by contacting us using the details set out under “Further information” below. We will accept your complaint however you choose to submit it, and you do not need to use any particular form or wording.

We will acknowledge receipt of your complaint within 30 days of receiving it, take appropriate steps to investigate it, and inform you of the outcome without undue delay. Where we need longer to complete our investigation, we will keep you updated on our progress.

You also have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues, using the contact form at https://ico.org.uk/make-a-complaint/ or by telephone on 0303 123 1113. You do not need to complain to us before complaining to the Information Commissioner’s Office, but we would welcome the opportunity to address your concerns first.

If you wish to receive a copy of the Personal Data we hold about you, this can be made available on request. We will respond as soon as we can and in any event within one calendar month, which runs from the date we receive your request or, where we reasonably require further information to verify your identity or to clarify the scope of your request, from the date we receive that information. We are required to carry out only reasonable and proportionate searches for your Personal Data. Where your request is complex or you have made a number of requests, we may extend that period by up to two further months, in which case we will tell you within one calendar month of receipt of your request and explain why the extension is necessary.

We will not charge you a fee for providing a copy of your Personal Data. However, where a request is manifestly unfounded or excessive, in particular because it is repetitive, we may either charge a reasonable fee based on the administrative costs of complying with the request or refuse to act on the request. We may also charge a reasonable fee based on administrative costs for any further copies of the same Personal Data that you request.

Right to withdraw consent

In case you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent (which will not affect the lawfulness of any processing done before the consent was withdrawn). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. In case we processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such marketing purposes.

How long will we retain your information?

We will only retain your Personal Data for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements, or to enforce our terms and conditions or for the protection of our rights in the context of legal claims, litigation, arbitration or similar proceedings.

To determine the appropriate retention period for your Personal Data, we will 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. In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.

Changes to this Privacy Policy

Titanbay reserves the right to update this Privacy Policy at any time, and we will make an updated copy available on our website. Where we make material changes to this Privacy Policy, we will notify you by appropriate means before those changes take effect — for example, by a prominent notice on our website or, where we hold your contact details and it is appropriate to do so, by email. The “Last updated” date at the top of this Privacy Policy indicates when it was most recently revised.

Further information

In our capacity as Data Controller for this website, if you have any queries, questions, concerns or require any further information in relation to the Privacy Policy or you wish to exercise any of your rights, please do not hesitate to contact us at compliance@titanbay.com, or write to us at Titanbay Ltd, 3rd Floor Elsley House, 20/30 Great Titchfield Street, London, W1W 8BF, United Kingdom.

We endeavour to respond to all legitimate requests within one calendar month. Where your request is complex or you have made a number of requests, we may extend that period by up to two further months. In that case, we will notify you within one calendar month of receiving your request, explain why the extension is necessary, and keep you updated.

Appendix

Jurisdictions outside of the United Kingdom not being the subject of UK adequacy regulations to which your data may be transferred:

  • None.