Privacy Policy
This Privacy Policy explains how Borrowdale collects, uses, discloses, and safeguards information when you visit our website or engage with our services. Please read this policy carefully. By using our site, you consent to the practices described below.
Last updated: This is a general draft policy and should be reviewed by qualified legal counsel before publication to ensure compliance with applicable laws in your jurisdiction.
1. Introduction
Borrowdale ("we", "us", or "our") is committed to protecting the privacy of individuals who visit our website or interact with our AI-driven data analysis and portfolio stewardship services. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
2. Information We Collect
We may collect and process the following categories of information:
- •Contact information — such as your name, email address, and telephone number, provided when you submit an enquiry or request an analysis.
- •Financial information — details you voluntarily share about your portfolio, holdings, or investment objectives for the purpose of generating an analysis.
- •Technical data — such as IP address, browser type, device identifiers, and pages visited, collected automatically through cookies and similar technologies.
- •Communications — records of correspondence if you contact us by email, form submission, or other means.
3. How We Use Your Information
We use the information we collect for purposes including:
- •Providing, operating, and improving our data analysis and portfolio review services.
- •Responding to enquiries and communicating with you about our services.
- •Maintaining the security and integrity of our website and systems.
- •Complying with applicable legal and regulatory obligations.
4. Legal Basis for Processing
Where applicable law requires a legal basis for processing personal data, we rely on one or more of the following: your consent, the necessity of processing to perform a contract with you, our legitimate interests in operating and improving our services, and compliance with legal obligations.
5. Sharing of Information
We do not sell personal information. We may share information with:
- •Service providers who perform functions on our behalf, such as hosting, analytics, and communication tools, subject to confidentiality obligations.
- •Professional advisors, where necessary for legal, accounting, or compliance purposes.
- •Regulatory or governmental authorities, where required by law or to protect our legal rights.
- •A successor entity in connection with a merger, acquisition, or sale of assets, subject to appropriate confidentiality arrangements.
6. Cookies and Tracking Technologies
Our website may use cookies and similar technologies to operate core functionality, remember preferences, and understand how visitors interact with our site. You can control cookies through your browser settings; disabling certain cookies may affect site functionality.
7. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. When information is no longer needed, we take reasonable steps to delete or anonymize it.
8. Data Security
We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. International Data Transfers
If your information is transferred to or processed in a country outside your own, we take steps intended to ensure that appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable law.
10. Your Rights
Depending on your jurisdiction, you may have rights regarding your personal data, which may include the right to:
- •Request access to the personal information we hold about you.
- •Request correction of inaccurate or incomplete information.
- •Request deletion of your personal information, subject to certain exceptions.
- •Object to or restrict certain processing activities.
- •Withdraw consent, where processing is based on consent.
To exercise any of these rights, please contact us using the details on our Contact page. We may need to verify your identity before responding to your request.
11. Children's Privacy
Our services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a minor, we will take steps to delete it.
12. Third-Party Links
Our website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of such third parties, and we encourage you to review their privacy policies independently.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the revised policy on this page and update the "Last updated" notice accordingly. We encourage you to review this page periodically.
14. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please get in touch via our Contact page.