Privacy Policy

TALBOT CAPITAL LTD

Company Number 06736536

1st Floor, Nicholas House, 3 Laurence Pountney Hill, London, England, EC4R 0EU

6 August 2024

Website Privacy Policy

1 INTRODUCTION

1.1 Important information and who we are

Welcome to TALBOT CAPITAL LTD’s Privacy and Data Protection Policy (“Privacy Policy”).

At TALBOT CAPITAL LTD (“We”, “Us”, or “Our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

Customers
Business contacts
Employee/Staff Members
Third parties connected to your customers

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data

processed at any time by us.

1.2 Your Data Controller and Data Protection Officer

TALBOT CAPITAL LTD is your Data Controller and responsible for your Personal Data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the DPO using the details set out below:

Name: Patrick Ryan

Email: hello@joinodin.com

Postal address: 1st Floor, Nicholas House, 3 Laurence Pountney Hill, London, England, EC4R 0EU, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s

Office (ICO), the UK supervisory authority 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.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal

with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases

laid out in the GDPR (see 2.2 below for more information);

Ensure that Processors authorized to process Personal Data have committed

themselves to confidentiality or are under an appropriate statutory obligation of

confidentiality;

Implement appropriate technical and organisational measures to ensure a level of

security appropriate to the risk associated with the processing of Personal Data;

Obtain the prior specific or general authorisation of the Controller before engaging

another Processor;

Assist the Controller in the fulfilment of the Controller's obligation to respond to

requests for exercising the data subject's rights;

Make available to the Controller all information necessary to demonstrate

compliance with the obligations laid down in the GDPR and allow for and contribute

to audits, including inspections, conducted by the Controller or another auditor

mandated by the Controller;

Maintain a record of all categories of processing activities carried out on behalf of a

Controller;

Cooperate, on request, with the supervisory authority in the performance of its

tasks;

Designate a data protection officer where required by the GDPR, publish their

details and communicate them to the supervisory authority;

Support the data protection officer in performing their tasks by providing resources

necessary to carry out those tasks and access to Personal Data and processing

operations and to maintain their expert knowledge;

Ensure that any person acting under the authority of the Processor who has access

to Personal Data does not process Personal Data except on instructions from the

Controller; and

Notify the Controller without undue delay after becoming aware of a Personal Data

Breach.

2 LEGAL BASIS FOR DATA COLLECTION

2.1 Types of data / Privacy policy scope

“Personal Data” 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

data).

We may collect, use, store and transfer different kinds of Personal Data about you which

we have grouped together below. Not all of the following types of data will necessarily be

collected from you but this is the full scope of data that we collect and when we collect it

from you:

Profile/Identity Data: This is data relating to your first name, last name, gender, date

of birth.

Contact Data: This is data relating to your phone numbers, addresses and email

addresses.

Marketing and Communications Data: This is your preferences in receiving

marketing information and other information from us.

Billing Data: This is information relating to your debit and credit card information

such as the name attached to your payment details and your billing address.

Financial Data: These are your banking details e.g. your account number and sort

code.

Transactional Data: This is information of details and records of all payments you

have made for our services or products.

Technical Data: This is your IP address, browser type and version, time zone setting

and location, operating system and platform, and other technology on the devices

you use to engage with us.

Customer Support Data: This includes feedback and survey responses.

Usage Data: information about how you use our website, products and services.

KYC data: knowing who you are as a customer, including proof of identity, address,

control and tax information.

We also collect, use and share Aggregated Data such as amounts invested in aggregate by

company stage, sector and investment instrument. 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. 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 Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better

understand and serve you and others. For example, we may conduct research on your

demographics and usage. Although this aggregated data may be based in part on Personal

Data, it does not identify you personally. We may share this type of anonymous data with

others, including service providers, our affiliates, agents and current and prospective

business partners.

We do not collect any Special Categories of Personal Data about you (this includes details

about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,

political opinions, trade union membership, information about your health, and genetic

and biometric data). Nor do we collect any information about criminal convictions and

offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and

processing of Personal Data. The main avenues we rely on are:

“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.

“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.

“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.

“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3 HOW WE USE YOUR PERSONAL DATA

3.1 Our data uses

We will only use your Personal Data when the law allows us to.

Set out below is a table containing the different types of Personal Data we collect and the

lawful basis for processing that data. Please refer to section 2.2 for more information on

the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which

we use your data may be broader than described but we will never process your data

without a legal basis for doing so and it is for a related purpose. For further inquiries

please contact our Data Protection Officer.

3.2 Marketing and content updates

You will receive marketing and new content communications from us unless you

specifically request that you would not like to receive these communications. From time to

time we may make suggestions and recommendations to you about goods or services that

may be of interest to you.

3.3 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 to get an explanation as to how the

processing for the new purpose is compatible with the original purpose, please contact

our Data Protection Officer.

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 above rules, where this is required or permitted by law.

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in

relation to your personal data:

Right to be informed. You have a right to be informed about our purposes for

processing your personal data, how long we store it for, and who it will be shared

with. We have provided this information to you in this policy.

Right of access. This enables you to receive a copy of the personal data we hold

about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.5 below for more details on how you can make a data subject access request.

Right to rectification. You have a right to 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.

Right to erasure. You have the right to ask us to delete or remove personal data

where there is no good reason for us continuing to process it, 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.

Right to object. You can object to the processing of personal data we hold about

you. This effectively allows you to stop or prevent us from processing your personal

data. Note that this is not an absolute right and it only applies in certain

circumstances, for example:

(i) Where we are processing your personal data for direct marketing purposes.

(ii) 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.

(iii) In some cases, we may continue processing your data if we can demonstrate

that we have compelling legitimate grounds to process your information

which override your rights and freedoms.

Right to restrict processing. You have the right to request the restriction or

suppression of your personal data. Note that this is not an absolute right and it only

applies in certain circumstances:

(i) If you want us to establish the data's accuracy.

(ii) Where our use of the data is unlawful but you do not want us to erase it.

(iii) 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.

(iv) You have objected to our use of your data but we need to verify whether we

have overriding legitimate grounds to use it.

Right to data portability. You have the right to request the transfer of your

personal data to you or to a third party. If you make such a request, 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.

If you wish to make a request under any of these rights, please contact us at

hello@joinodin.com.

4.2 Your control over TALBOT CAPITAL LTD’s use of your Personal Data

You may delete your account at any time – this will remove your account page from our

systems and our related software.

We do not guarantee the ability to delete all stored data. If you would like us to delete

/correct personally identifiable data, let us know and we will action your request as soon

as practicable.

You can access information associated with your account by logging into your account you

created with us.

Your account information will be protected by a password for your privacy and security.

You need to prevent unauthorized access to your account and personal information by

selecting and protecting your password appropriately and limiting access to your

computer or device and by signing off after you have finished accessing your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California

residents are entitled to ask us for a notice identifying the categories of personal customer

information which we share with our affiliates and/or third parties for marketing purposes,

and providing contact information for such affiliates and/or third parties. If you are a

California resident and would like a copy of this notice, please submit a written request to

hello@joinodin.com.

4.3 How TALBOT CAPITAL LTD protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate

disclosure. We implement a variety of security measures to ensure the security of your

Personal Data on our systems, including making use of state of the art industry standard

encryption, certificate signing and security practices business-wide as well as strict security

policies and internal audits to ensure all our systems are continually reacting to new

threats and always at the highest level of security. Any Personal Data collected by us is

only accessible by a limited number of employees who have special access rights to such

systems and are bound by obligations of confidentiality. If and when we use

subcontractors to store your data, we will not relinquish control of your Personal Data or

expose it to security risks that would not have arisen had the data remained in our

possession. However, unfortunately no transmission of data over the internet is

guaranteed to be completely secure. It may be possible for third parties not under the

control of TALBOT CAPITAL LTD to intercept or access transmissions or private

communications unlawfully. While we strive to protect your Personal Data, we cannot

ensure or warrant the security of any Personal Data you transmit to us. Any such

transmission is done at your own risk. If you believe that your interaction with us is no

longer secure, please contact us.

4.4 Opting out of marketing promotions

You can ask us to stop sending you marketing messages at any time by contacting us at

any time.

Where you opt out of receiving these marketing messages, we will continue to retain other

Personal Data provided to us as a result of interactions with us not related to your

marketing preferences.

4.5 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other

rights). However, if your request is clearly unfounded, we could refuse to comply with your

request.

We may need to request specific information from you to help us confirm your identity

and ensure you have the 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.

5 YOUR DATA AND THIRD PARTIES

5.1 Sharing your data with third parties

We may share non-Personal Data with third parties. We may share your Personal Data

with subcontractors or affiliates, subject to confidentiality obligations to use it only for the

purposes for which we disclose it to them and pursuant to our instructions.

We may also share Personal Data with interested parties in the event that TALBOT CAPITAL LTD anticipates a change in control or the acquisition of all or part of our business or

assets or with interested parties in connection with the licensing of our technology.

If TALBOT CAPITAL LTD is sold or makes a sale or transfer, we may, in our sole discretion,

transfer, sell or assign your Personal Data to a third party as part of or in connection with

that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern

the further use of your Personal Data. In all other situations your data will still remain

protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to

enforce our terms or this Privacy Policy.

5.2 Third-Party Links

This Site 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 Site, we encourage you to read the privacy policy

of every website you visit.

6 HOW LONG WE RETAIN YOUR DATA

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes

we collected it for. We may retain your Personal Data for a longer period than usual in the event

of a complaint or if we reasonably believe there is a prospect of litigation in respect to our

relationship with you.

7 AGE LIMIT FOR OUR USERS

You must not use TALBOT CAPITAL LTD unless you are aged 18 or older. If you are under 18 and you

access TALBOT CAPITAL LTD by lying about your age, you must immediately stop using TALBOT CAPITAL LTD.

This website is not intended for children and we do not knowingly collect data relating to children.

8 INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the US or other countries or jurisdictions

outside the US where TALBOT CAPITAL LTD has facilities. By using TALBOT CAPITAL LTD, you are

permitting and consenting to the transfer of information, including Personal Data, outside of the

US.

9 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates here. This version is dated 6

August 2024.

By using TALBOT CAPITAL LTD, you consent to the collection and use of data by us as set out in this

acceptance of any modifications to this Privacy Policy.

10 INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated

examples are not intended to in any way limit the term which they serve to illustrate. Any email

addresses set out in this policy may be used solely for the purpose for which they are stated to

be provided, and any unrelated correspondence will be ignored. Unless otherwise required by

law, we reserve the right to not respond to emails, even if they relate to a legitimate subject

matter for which we have provided an email address. You are more likely to get a reply if your

request or question is polite, reasonable and there is no relatively obvious other way to deal with

or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff are not authorized to contract on behalf of TALBOT CAPITAL LTD, waive rights or make

representations (whether contractual or otherwise). If anything contained in an email from a TALBOT CAPITAL LTD address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any TALBOT CAPITAL LTD rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the TALBOT CAPITAL LTD legal department.

TERMS OF USE

Please also see our Terms of Use (www.joinodin.com/legal/terms-and-conditions) which set out the terms, disclaimers, and limitations of liability governing your use of TALBOT CAPITAL LTD.