Continuum Advisory Partners Limited ("Continuum") respects your privacy and is committed to protecting your personal data. This Privacy and Cookies Policy (the "Policy") provides information about how we look after your personal data when you visit our website (regardless of where you visit it from) and any subsequent interactions which we may have, your privacy rights and how the law protects you.
This Policy is provided in a layered format so you can click through to the specific sections set out below. Please also refer to the Glossary to understand the meaning of some of the terms used in this Policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. COOKIES
5. HOW WE USE YOUR PERSONAL DATA
6. DISCLOSURES OF YOUR PERSONAL DATA
7. INTERNATIONAL TRANSFERS
8. DATA SECURITY
9. DATA RETENTION
10. YOUR LEGAL RIGHTS
11. GLOSSARY
Purpose of this Policy
This Policy sets out how Continuum collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to receive further information from us.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this 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 about you, so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.
Controller
Continuum is the controller and responsible for your personal data (collectively referred to as "Continuum", "we", "us" and "our" in this Policy). We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
If you have any questions about this Policy or our privacy practices, please contact our DPO at: Emily.Henderson@Continuum.Partners
You have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the Policy and your duty to inform us of changes
We keep our Policy under regular review. Updates will be made from time to time and will be effective on posting to Continuum’s website. This version was last updated on 9 May 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
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 or anonymised data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In such circumstances, we may have to decline or cease to provide the relevant service to you, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
What are cookies?
Cookies are small text files that are stored in the memory and drive(s) associated with the computer, mobile device or tablet you use to visit many web pages. They are used to enable websites to function or to provide information to the owners of a website, or to other third parties who receive data obtained from that website. This information may be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.
Why do we use cookies?
Cookies help us to provide customised services and information. We use cookies on our website to tell us, in general terms, how and when pages in our website are visited, what our users’ technology preferences are – such as what type of video player they use – and whether our website is functioning properly. Depending on their purpose, some cookies will only operate for the length of a single browsing session, whilst others have a longer life span to ensure that they fulfil their longer-term purposes (as explained in more detail below). Please note that, however long the cookies’ active life may be, you can delete cookies (and therefore stop any further data collection by them) as further described below.
In broad terms, we use cookies on our website for the following purposes:
Cookies used on this website
_ga
This is a Google analytics cookie and is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.
_gat
This is a Google analytics cookie, used to throttle the request rate - limiting the collection of data on high traffic sites. It expires after 10 minutes.
_gid
This is a Google session cookie, used to distinguish users. Default expiration time: 24 hours.
exp_csrf_token
This cookie protects against Cross Site Request Forgery (CSRF). A CSRF attack forces a logged-on victim’s browser to send a forged HTTP request, including the victim’s session cookie and any other automatically included authentication information, to a vulnerable web application. This allows the attacker to force the victim’s browser to generate requests the vulnerable application thinks are legitimate requests from the victim.
exp_tracker
Tracks the last 5 pages viewed by the user, and is used primarily for redirection after logging in etc. Affects guests and logged in users.
exp_last_activity
Every time the state is updated (the page reloaded) the last activity is set to the current datetime. Used to determine expiry. This is essential for logged in users, but not for guests - it is set for both.
exp_last_visit
Sets the datetime that the user last visited the site, and is set for both guests and logged in users. If not set, is automatically set to 10 years ago. Affects guests and logged in users.
CookiesAccepted
Sets a cookie to prevent the cookie consent warning appearing on each page once you have selected your preference.
You can view and update your consent preferences.
How to delete and block our cookies
If you wish to remove cookies set by our website from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Most web browsers allow some control of most cookies through the browser settings, which are usually found in the ‘options’ or ‘preferences’ menu of your web browser. In order to understand these settings, the ‘Help’ option in your internet browser will provide more details. Alternatively, the site https://www.whatarecookies.com includes instructions for managing cookies on many commonly used browsers, or you may consult the vendor documentation for your specific software.
However, cookies are necessary in order for you to be able to make full use of our Site. If you use your browser settings to block all cookies (including strictly necessary cookies), some of our Site’s functionality might be impaired. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit the Site.
Third party cookies
When you visit our Site, you may receive cookies that are set by third parties. These may include cookies set by Google Analytics. These cookies are used for the purposes described above in the “Why Do We Use Cookies?” section of this policy. We do not control the setting of these third party cookies, and their usage is regulated by each third party’s own privacy policy.
For more information about how Google Analytics collects and processes your data, please visit https://policies.google.com/technologies/cookies.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data except in respect of marketing or similar communications which we send to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Lawful basis for processing including basis of legitimate interest |
| To register you as a new client | Performance of a contract with you |
| To process and deliver our services to you including: (a) managing payments, fees and charges (b) collecting and recover money owed to us |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you, including notifying you about changes to our terms or Policy | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (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) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you, and measure or understand the effectiveness of any content we serve to you | Necessary for our legitimate interests (to understand how clients use our services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about services that may be of interest to you | Necessary for our legitimate interests (to develop our services and grow our business) |
| To create a record and analyse your application in respect of a position at Continuum | Necessary for our legitimate interests (to respond to an application) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your identity, contact, technical, usage and profile data to form a view of what may be of interest to you and decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information or purchased services from us, and you have not opted out of receiving that marketing.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at enquiries@continuum.partners at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in the course of providing our services to you.
Change of purpose
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 and that reason is compatible with the original purpose. If you wish for an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us using the email address above.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the foregoing, where this is required or permitted by law.
We may share your personal data with third parties, such as other advisors, accountants and other parties involved in your matters, or for the purposes set out in the table above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Certain of our advisers, suppliers and other service providers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us for further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need-to-know. They will only process your 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 notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your 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 your 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 relationship with you.
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 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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see section 10. Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of these rights, please contact enquiries@continuum.partners.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and your right to access your personal data (or to exercise any of your 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 contact you to ask you for further information in relation to your request 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 your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation to which we are subject.
THIRD PARTIES
External Third Parties
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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Continuum Advisory Partners Limited ("Continuum") is incorporated and registered in England and Wales with registered no. 14189636. Continuum is an appointed representative (Firm Reference Number 979923) of Kroll Securities Ltd., which is authorised and regulated by the Financial Conduct Authority.