Privacy & cookies policy

Introduction

Introduction

Continuum Advisory Partners Limited ("Continuum", "we", "us" or "our") respects your privacy and is committed to protecting your personal data. This Privacy and Cookies Policy (the "Policy") provides information about how we (and our processors on our behalf) process personal data relating to our current, former and prospective clients (including their employees and representatives), our business contacts such as our service providers and suppliers (including their employees and representatives) and our other business contacts that are not current, former or prospective clients, those that apply for employment and work experience with us (known collectively as job applicants) and users of our website (including when you visit our website (regardless of where you visit it from) and any subsequent interactions which we may have) ("you" or "your"). This Policy also provides you with information about your rights under UK data protection law. Where this Policy refers to processing of personal data by Continuum, this includes processing by Continuum's data processors which is conducted on behalf of Continuum.

This Policy is provided in a layered format so you can click through to the specific sections set out below.

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

1. Important information and who we are

Purpose of this Policy

This Policy sets out how Continuum collects and processes your personal data.

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 or notice 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 such notices and privacy policies and is not intended to override them.

Controller

Continuum is the controller in respect of the processing of personal data set out in this Policy. Continuum is a private limited company registered in England with registered number 14189636. Continuum is registered with the Information Commissioner's Office ("ICO") with ICO registration reference ZB502534.

Contact details

If you have any questions about this Policy or our privacy practices, please email enquiries@continuum.partners or write to Continuum at FAO: Karen Harte, Becket House, 36 Old Jewry,
London EC2R 8DD.

You have the right to make a complaint at any time to the 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 in September 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

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.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymised data (from which a person cannot be identified) or other types of non-personal data (i.e. data which does not relate to living individuals).

Depending on our relationship with you, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity data such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, national insurance number, gender and pronoun preference.
Contact data such as your address(es), email address(es) and telephone number(s).
Financial data such as your bank account details or invoicing details.
Transaction data including details of products and services you have purchased from us or we have purchased from you.
Technical data such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Please also note that we use cookies on our website as detailed in section 4 of this Policy.
Profile data such as your interests, preferences, feedback and survey responses.
Usage data including information about how you use our website, products and services.
KYC data may include copies of your passport and/or driving licence and utility bills, details of any disqualifications as a director or disqualifications from acting in company management or from conducting company affairs, data relating to insolvency proceedings involving you or entities you have been or are connected with, data received from client due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks) and data related to any public criticisms of you by statutory or regulatory authorities (including designated professional bodies) and fraud enquiries (for example, information from police reports).
Right to work data may include copies of documents which prove you have the right to work in the UK, including your passport, passport card, driving licence, utility bills and your share code (if you have a biometric residence card or permit or a frontier worker permit) and/or information obtained from the Home Office (if relevant, for example if the Home Office are contacted in order to receive a "Positive Verification Notice" to prove you have the right to work in the UK).
Criminal offence data including details of any unspent criminal convictions.
Career data may include information about your place(s) of work, job title(s), employment history, qualifications and/or information contained in your CV and cover letter or email, references (and information obtained from your referees) and other information provided and/or made available to us during the recruitment process, including details of your salary, bonuses and other emoluments, together with details of your performance record.
Marketing and communications data such as your marketing and communication preferences in respect of us and (where relevant) third parties associated and/or affiliated with us.

We will not usually collect any special categories of personal data about you (e.g. personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation), although we do process criminal offence data in certain circumstances as noted above.

We may also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. This Aggregated Data could be derived from your personal data but is not considered personal data under data protection laws 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, to employ your services or to allow you to access our website). In such circumstances, we may have to decline or cease to provide you with, or receive from you, the relevant service, but we will notify you if this is the case at the time.

3. How is your personal data collected?

Depending on our relationship with you, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity data such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, national insurance number, gender and pronoun preference.
Contact data such as your address(es), email address(es) and telephone number(s).
Financial data such as your bank account details or invoicing details.
Transaction data including details of products and services you have purchased from us or we have purchased from you.
Technical data such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Please also note that we use cookies on our website as detailed in section 4 of this Policy.
Profile data such as your interests, preferences, feedback and survey responses.
Usage data including information about how you use our website, products and services.
KYC data may include copies of your passport and/or driving licence and utility bills, details of any disqualifications as a director or disqualifications from acting in company management or from conducting company affairs, data relating to insolvency proceedings involving you or entities you have been or are connected with, data received from client due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks) and data related to any public criticisms of you by statutory or regulatory authorities (including designated professional bodies) and fraud enquiries (for example, information from police reports).
Right to work data may include copies of documents which prove you have the right to work in the UK, including your passport, passport card, driving licence, utility bills and your share code (if you have a biometric residence card or permit or a frontier worker permit) and/or information obtained from the Home Office (if relevant, for example if the Home Office are contacted in order to receive a "Positive Verification Notice" to prove you have the right to work in the UK).
Criminal offence data including details of any unspent criminal convictions.
Career data may include information about your place(s) of work, job title(s), employment history, qualifications and/or information contained in your CV and cover letter or email, references (and information obtained from your referees) and other information provided and/or made available to us during the recruitment process, including details of your salary, bonuses and other emoluments, together with details of your performance record.
Marketing and communications data such as your marketing and communication preferences in respect of us and (where relevant) third parties associated and/or affiliated with us.

If you fail to provide personal data

4. Cookies

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 often 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 personalised 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:

Analytical purposes: Analytical cookies allow us to recognise, measure and track visitors to our website and compile a record of this usage information. This helps us to improve and develop the way our website works, for example, by determining whether visitors to the website can find information easily, or by identifying the aspects of our website that are of the most interest to them.
Session management: The software that runs our website uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, authenticate users and determine the features of the site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for the website to function.

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

This cookie tracks the last 5 pages viewed by the user, and is used primarily for redirection after logging in etc. Used for both guests and logged in users.

exp_last_activity

Every time the site is updated (the page reloaded) the last activity is set to the current datetime. This cookie is used to determine expiry. This is essential for logged in users, but not for guests - it is set for both.

exp_last_visit

This cookie sets the datetime that the user last visited the site, and is set for both guests and logged in users. If not set, the datetime is automatically set to 10 years ago. Used for 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.

exp_flash

This cookie is a functionality cookie used to store user feedback messages, such as confirmation or error messages, in an encrypted format for security.

exp_visitor_consents

This cookie is used to store non-logged in visitor's choices regarding consent and cookie requests.

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, 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.

Please note that certain 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 essential 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. Details of the processing of personal data by a cookie provider in connection with their own usage (i.e. as a data controller) is required by law to be detailed in the relevant third party’s own privacy policy.

For more information about how Google Analytics collects and processes your data, please visit https://policies.google.com/te....

5. How we use your personal data

Lawful bases of processing

We will only use your personal data where we have a lawful basis to do so. Most commonly, we will use your personal data pursuant to one of the following lawful bases:

Where we need to process your personal data to perform the contract we have entered into with you, or in order to take steps at your request prior to entering into such a contract.
Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
Where we need to process your personal data to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data except in certain circumstances 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 or opt-out of marketing at any time by following the opt-out or "unsubscribe" links on any marketing message sent to you or by emailing us at enquries@continuum.partners or writing to Continuum at FAO: Karen Harte, Becket House, 36 Old Jewry, London EC2R 8DD.

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.

Please 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.

A. Clients

Purpose/Activity	Lawful basis for processing (including details of the relevant legitimate interest)	Categories of personal data
To register you as a new client	(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract (b) Necessary for our legitimate interests of generating and onboarding new business (c) Necessary to comply with a legal obligation (e.g. anti-money laundering legislation)	Identity data Contact data Financial data KYC data
To provide, or facilitate the provision of, services to you including managing payments, fees and charges and collecting and recovering money owed to us	(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract (b) Necessary for our legitimate interests (to manage our business and recover debts due to us)	Identity data Contact data Financial data Transaction data
To conduct our business, including in relation to advisory finance advice	(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract (b) Necessary for our legitimate interests of pursuing and developing our business	Identity data Contact data Financial data Transaction data
To carry out financial risk assessments, risk mitigation activities and for risk reporting and risk management	(a) Necessary to comply with a legal obligation (b) Our legitimate interests of pursuing and developing our business, and conducting risk management in respect of our business	Identity data Contact data Financial data Transaction data KYC data
To comply with our legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations, tax reporting obligations and FCA requirements	(a) Necessary to comply with a legal obligation (b) Our legitimate interests of ensuring compliance with laws and regulations in respect of our business	Identity data Contact data Financial data Transaction data KYC data
To scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems	(a) Necessary to comply with a legal obligation (e.g. data protection laws) (b) Our legitimate interests of ensuring compliance with laws and regulations, and for the administration of our business and management of our systems	Identity data Contact data Technical data
To prevent and respond to actual and potential fraud or illegal activities	(a) Necessary to comply with a legal obligation (b) Our legitimate interests of ensuring compliance with laws and regulations and risk management in respect of our business	Identity data Contact data Financial data Transaction data KYC data
To engage in marketing and business development activity	(a) Your consent (b) Our legitimate interests (where you have purchased services from us and have not opted-out of receiving such communications)	Identity data Contact data Marketing and communications data
To send you updates, news items, articles or other material which are not marketing material (i.e. service materials)	Our legitimate interests of pursuing and developing our business	Identity data Contact data
To send you invitations to events and seminars and the like which we think may be of interest to you	Our legitimate interests of pursuing and developing our business	Identity data Contact data
To aggregate and anonymise your data	Our (or our service providers') legitimate interests of improving the service offered to customers	Identity data Contact data Financial data Transaction data Profile data Usage data
Generally to manage the business activities of Continuum, including providing services ancillary to the services, managing and safeguarding our systems, executing our document storage and retention policies and procedures, and other ordinary course business activities. We may also share your personal data with third parties in certain circumstances including our third party service providers and in the context of a business re-organisation, sale or acquisition (see section 6 for further details)	(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract (b) Necessary for our legitimate interests of conducting our business	Identity data Contact data Financial data Transaction data Technical Data Profile data Usage data KYC data

Purpose/Activity

Lawful basis for processing (including details of the relevant legitimate interest)

Categories of personal data

To register you as a new client

(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract

(b) Necessary for our legitimate interests of generating and onboarding new business

Identity data

Contact data

Financial data

KYC data

To provide, or facilitate the provision of, services to you including managing payments, fees and charges and collecting and recovering money owed to us

(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract

(b) Necessary for our legitimate interests (to manage our business and recover debts due to us)

Identity data

Contact data

Financial data

Transaction data

To conduct our business, including in relation to advisory finance advice

(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract

(b) Necessary for our legitimate interests of pursuing and developing our business

Identity data

Contact data

Financial data

Transaction data

To carry out financial risk assessments, risk mitigation activities and for risk reporting and risk management

(a) Necessary to comply with a legal obligation

(b) Our legitimate interests of pursuing and developing our business, and conducting risk management in respect of our business

Identity data

Contact data

Financial data

Transaction data

KYC data

To comply with our legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations, tax reporting obligations and FCA requirements

(a) Necessary to comply with a legal obligation

(b) Our legitimate interests of ensuring compliance with laws and regulations in respect of our business

Identity data

Contact data

Financial data

Transaction data

KYC data

To scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems

(a) Necessary to comply with a legal obligation (e.g. data protection laws)

(b) Our legitimate interests of ensuring compliance with laws and regulations, and for the administration of our business and management of our systems

Identity data

Contact data

Technical data

To prevent and respond to actual and potential fraud or illegal activities

(a) Necessary to comply with a legal obligation

(b) Our legitimate interests of ensuring compliance with laws and regulations and risk management in respect of our business

Identity data

Contact data

Financial data

Transaction data

KYC data

To engage in marketing and business development activity

(a) Your consent

(b) Our legitimate interests (where you have purchased services from us and have not opted-out of receiving such communications)

Identity data

Contact data

Marketing and communications data

To send you updates, news items, articles or other material which are not marketing material (i.e. service materials)

Our legitimate interests of pursuing and developing our business

Identity data

Contact data

To send you invitations to events and seminars and the like which we think may be of interest to you

Our legitimate interests of pursuing and developing our business

Identity data

Contact data

To aggregate and anonymise your data

Our (or our service providers') legitimate interests of improving the service offered to customers

Identity data

Contact data

Financial data

Transaction data

Profile data

Usage data

Generally to manage the business activities of Continuum, including providing services ancillary to the services, managing and safeguarding our systems, executing our document storage and retention policies and procedures, and other ordinary course business activities. We may also share your personal data with third parties in certain circumstances including our third party service providers and in the context of a business re-organisation, sale or acquisition (see section 6 for further details)

(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract

(b) Necessary for our legitimate interests of conducting our business

Identity data

Contact data

Financial data

Transaction data

Technical Data

Profile data

Usage data

KYC data

B. Business contacts

Purpose/Activity

Lawful basis for processing (including details of the relevant legitimate interest)

Categories of personal data

To hold your personal data on our system and to contact you (including, in respect of suppliers, in connection with using the services that you provide)

(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract

(b) Our legitimate interests, including, in respect of suppliers, in connection with receiving the services that you provide

Identity data

Contact data

Financial data

Transaction data

In respect of suppliers, to allow us to process payments and orders in respect of any goods and services provided

Our legitimate interests, including in connection with receiving the services that you provide

(b) Performance of a contract to which you are a party, or in order to take steps at your request prior to entering into such a contract

Identity data

Contact data

Financial data

Transaction data

To conduct our business, including in relation to advisory finance advice

Necessary for our legitimate interests of pursuing and developing our business

Identity data

Contact data

Financial data

Transaction data

To provide, or facilitate the provision of, our services including advisory finance services (where you are connected to our client and it is relevant for the purposes of providing our advice (and/or other services) to our client)

(a) Our legitimate interests of providing services to our clients

(b) Our clients' legitimate interests of receiving the benefit of our services

Identity data

Contact data

Financial data

Transaction data

KYC data

To engage in marketing and business development activity

(a) Your consent

(b) Our legitimate interests (where you have purchased services from us and have not opted-out of receiving such communications)

Identity data

Contact data

Marketing and communications data

(a) Necessary to comply with a legal obligation

(b) Our legitimate interests of ensuring compliance with laws and regulations in respect of our business

Identity data

Contact data

Financial data

Transaction data

KYC data

(a) Necessary to comply with a legal obligation (e.g. data protection laws)

(b) Our legitimate interests of ensuring compliance with laws and regulations, and for the administration of our business and management of our systems

Identity data

Contact data

Technical data

To send you invitations to events and seminars and the like which we think may be of interest to you

Our legitimate interests of pursuing and developing our business

Identity data

Contact data

Generally to manage the business activities of Continuum, including managing and safeguarding our systems, executing our document storage and retention policies and procedures, and other ordinary course business activities. We may also share your personal data with third parties in certain circumstances including our third party service providers and in the context of a business re-organisation, sale or acquisition (see section 6 for further details)

(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract

(b) Necessary for our legitimate interests of conducting our business

Identity data

Contact data

Financial data

Transaction data

Technical Data

Profile data

Usage data

C. Job applicants

Purpose/Activity	Lawful basis for processing (including details of the relevant legitimate interest)	Categories of personal data
To assess your skills and qualifications, to consider your suitability for the position and to decide whether to enter into a contract with you.	(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract (b) Our legitimate interests of pursuing and developing our business and conducting recruitment activities	Identity data Contact data Right to work data Career data Criminal offence data
To carry out background and reference checks including contacting previous employers or colleagues, where applicable.	Compliance with our legal and regulatory obligations (b) Our legitimate interests of pursuing and developing our business and conducting recruitment activities	Identity data Right to work data Criminal offence data Career data
To communicate with you about the recruitment process.	Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract	Identity data Contact data
To keep records related to our hiring processes.	Compliance with our legal and regulatory obligations (b) Our legitimate interests of pursuing and developing our business and conducting recruitment activities, and to enable us to defend ourselves against any potential legal claims	Identity data Contact data Right to work data Career data Criminal offence data
To comply with our legal and regulatory requirements	Necessary to comply with a legal obligation	Identity data Contact data Right to work data Career data Criminal offence data
To scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems	(a) Necessary to comply with a legal obligation (e.g. data protection laws) (b) Our legitimate interests of ensuring compliance with laws and regulations, and for the administration of our business and management of our systems	Identity data Contact data Technical data
Generally to manage the business activities of Continuum, including managing and safeguarding our systems, executing our document storage and retention policies and procedures, and other ordinary course business activities. We may also share your personal data with third parties in certain circumstances including our third party service providers and in the context of a business re-organisation, sale or acquisition (see section 6 for further details)	(a) Performance of a contract with you, or in order to take steps at your request prior to entering into such a contract (b) Necessary for our legitimate interests of conducting our business	Identity data Contact data Technical Data KYC data Right to work data Career data

We envisage that we will process information about criminal convictions. We will collect information about your criminal convictions history if we would like to offer you the work or a position (conditional on checks and any other conditions, such as references, being satisfactory). We will only collect and use information about criminal convictions if it is appropriate given the nature of the role and where we have a lawful basis to do so.

D. Website users

Purpose/Activity	Lawful basis for processing (including details of the relevant legitimate interest)	Categories of personal data
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Our legitimate interests (of running our business, provision of administration and IT services, network security and to prevent fraud) (b) Compliance with our legal and regulatory obligations	Identity data Contact data Technical data Profile data Usage data
To deliver relevant website content and advertisements to you, and measure or understand the effectiveness of any content we serve to you	Our legitimate interests (to understand how people use our website, to develop (and inform the development of) our website, to grow our business and to inform our marketing strategy)	Identity data Contact data Technical data Profile data Usage data
To use data analytics	Our legitimate interests (to improve our website, products and services, marketing, customer relationships and experiences and to develop our business and to inform our marketing strategy)	Identity data Contact data Technical data Profile data Usage data
Where you subscribe to us via our website, to engage in marketing and business development activity	(a) Your consent (b) Our legitimate interests (where you have purchased services from us and have not opted-out of receiving such communications)	Identity data Contact data Marketing and communications data
Generally to manage the business activities of Continuum, including managing and safeguarding our systems. We may also share your personal data with third parties in certain circumstances including our third party service providers and in the context of a business re-organisation, sale or acquisition (see section 6 for further details)	Necessary for our legitimate interests of conducting our business	Identity data Contact data Technical Data Profile data Usage data

Marketing

We may send marketing communications to you, by email or text, if you have consented or opted-in to receiving these (including by subscribing to receive communications from us via our website) or have previously purchased services from us and you have not opted out of, or unsubscribed from, receiving such marketing. We may use third party service providers to store and manage personal data which is collected by us for marketing purposes. Our current service provider for this purpose is Campaign Monitor.

Opting out/Unsubscribing

You can require us to stop sending you marketing messages at any time by following the opt-out/unsubscribe links on any marketing message sent to you or by emailing us at enquiries@continuum.partners or by contacting us in writing at Continuum at FAO: Karen Harte, Becket House, 36 Old Jewry,London EC2R 8DD.

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 of this and, where required, obtain consent to do so.

6. Disclosures of your personal data

We may share your personal data with our affiliates or third parties, such as other advisors (including lawyers and accountants), service providers, providers of third party software, providers of document storage services, IT service providers, regulatory bodies (such as the FCA and HMRC), background, compliance, anti-money laundering and credit check agencies, and other parties involved in your matters, for the purposes set out in the tables above. We may also use third party service providers to store and manage personal data which is collected by us for marketing purposes. Where such data is provided to third parties, except if the third party acts as "controller" (such as a law firm or other corporate advisory firm) and is therefore bound to comply with data protection laws anyway, we will enter into agreements with such third parties to ensure that they process that data in accordance with the requirements of the data protection laws.

Please note that we may also share your personal data with third parties in the context of a business re-organisation, sale or acquisition.

7. International transfers

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 circumstances applies:

The country where the recipient is located has been deemed by the UK Secretary of State to provide an adequate level of protection for personal data.
Appropriate safeguards are in place (such as specific contracts approved by the UK Parliament).

Please contact us for further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. Data security

We have put in place what we consider to be appropriate security measures designed 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.

We have put in place procedures designed 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.

9. Data retention

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.

10. Your legal rights

In certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Request access to your personal data: 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 your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal data: This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

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. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request restriction of processing your personal data: This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request transfer of your personal data to another party.

Right to withdraw consent: If we are processing your personal data on the basis of your consent, you have the right to withdraw such consent at any time. Withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent or to opt out of, or unsubscribe from, receiving marketing communications, please email enquiries@continuum.partners or write to Continuum at FAO: Karen Harte, Becket House, 36 Old Jewry, London EC2R 8DD or follow the unsubscribe instructions included in each electronic marketing communication. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you wish to exercise any of these rights, please email enquiries@continuum.partners or write to Continuum at FAO: Karen Harte, Becket House, 36 Old Jewry,
London EC2R 8DD.

No fee usually required

You will not usually 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.

11. Glossary

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

Other individuals and entities affiliated with Continuum, in the UK and overseas.
Service providers based in the UK and EEA who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in the UK, US and EEA who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the UK and EEA who require reporting of processing activities in certain circumstances.

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:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.