This notice covers Snowflow's website, enquiries, complaints and business relationships. An underlying account, payment, card or cryptoasset provider supplies its own privacy information for the data it handles. Your onboarding documents explain the relevant organisations and their responsibilities before you use a service.
1. Who is responsible for your information
SNOWFLOW CAPITAL LTD is the controller of personal information described in this notice. Snowflow is our trading style.
- Company number
- 16307119
- Registered office
- International House, 10 Beaufort Court, Admirals Way, London, Greater London, England, E14 9XL
- Privacy contact
- snowy@snowflow.co.uk
This notice applies to visitors, people who contact us, customers and prospective customers, business representatives, suppliers, professional advisers and other contacts.
2. The information we collect
Depending on how you interact with us, we may collect:
- Contact information such as your name, email address, telephone number and postal address.
- Business and professional information such as your organisation, role, sector, website, location and the nature of your requirements.
- Enquiry and correspondence information including the subject, message, attachments, call notes, preferences and our response.
- Complaint and rights-request information including facts, supporting material, identity-verification information and the outcome.
- Technical and security information such as IP address, device or browser information, request time, referring page, error and security logs, and information used to detect misuse.
- Consent and preference information including any marketing choice or communication adjustment you ask us to record.
- Public or third-party information relevant to legitimate due diligence, supplier management or business-to-business contact.
Please do not send passwords, PINs, full card or account details, security codes, identity documents, private keys, wallet recovery phrases, health information or other sensitive information through the general enquiry form unless we specifically request it through an appropriate secure channel.
3. How and why we use personal information
| Purpose | Typical information | Lawful basis |
|---|---|---|
| Respond to and manage enquiries | Contact, professional and correspondence information | Legitimate interests in communicating about genuine enquiries; steps requested before a possible contract where applicable |
| Develop our services and relationships | Requirements, sector, feedback and business information | Legitimate interests in developing and operating the business |
| Manage suppliers, advisers and business contacts | Contact, role, correspondence and due-diligence information | Legitimate interests; contract where applicable; legal obligation |
| Handle complaints and rights requests | Contact, complaint, request and verification information | Legal obligation; legitimate interests in resolving concerns and establishing legal claims |
| Protect the website and prevent misuse | Technical, security and interaction information | Legitimate interests in security, fraud prevention and service integrity; legal obligation where applicable |
| Meet legal, regulatory, tax or corporate obligations | Relevant contact, transaction-free business records and correspondence | Legal obligation; legitimate interests in demonstrating compliance and protecting legal rights |
| Send optional marketing | Contact details and preferences | Consent where required, or legitimate interests where permitted for appropriate business-to-business communications |
Where we rely on legitimate interests, we consider the need for the processing, its benefit and its effect on you. You can object to processing based on legitimate interests; see section 7.
If we ask for information required by law or needed to progress a request, we will explain this where appropriate. If it is not provided, we may be unable to respond fully or continue the interaction.
4. Where information comes from and who receives it
We usually receive information directly from you. We may also receive it from the organisation you represent, a person making an introduction, publicly available corporate or professional sources, website and security systems, or a supplier helping us operate the website.
We may share personal information, only where reasonably necessary, with:
- website hosting, infrastructure, security, email, communications and business-software suppliers;
- professional advisers including legal, compliance, accounting, tax and insurance advisers;
- strategic partners where needed for a service you request, with transparent and lawful sharing and the applicable privacy information;
- courts, law-enforcement bodies, regulators, government authorities or other parties where required by law or needed to protect legal rights; and
- a buyer, investor or successor involved in a genuine corporate transaction, subject to appropriate confidentiality and data-protection measures.
We do not sell personal information. Suppliers acting as processors may use it only to provide contracted services to us and must apply appropriate confidentiality and security measures.
5. International transfers
Some technology or professional-service suppliers may process information outside the United Kingdom. Where UK data-protection law restricts a transfer, we will use an approved mechanism such as an adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or another lawful safeguard.
Appropriate supplementary security and contractual measures will be considered where required. You may contact us for information about the safeguard used for a relevant transfer, although commercial or security-sensitive details may be redacted.
6. How long we keep information and how we protect it
We keep personal information only for as long as reasonably needed for the purpose for which it was collected, including legal, tax, accounting, security and dispute requirements. Our normal starting points are:
- general enquiries and relationship records: up to 24 months after the last meaningful interaction;
- complaints and material legal or corporate records: up to six years after closure or the end of the relevant relationship;
- routine website security and error logs: generally up to 12 months; and
- marketing preferences and suppression records: while the preference remains relevant and for as long as needed to respect an opt-out.
We may keep information for longer where required by law, needed for an actual or expected claim, or necessary to investigate fraud or security incidents. We may retain anonymised information that can no longer identify you.
We use proportionate organisational and technical measures designed to protect information from accidental loss, misuse, unauthorised access, alteration or disclosure. No internet or email system is completely secure, so use the contact form only for an initial conversation.
7. Your data-protection rights
Depending on the circumstances, UK data-protection law may give you the right to:
- ask whether we use your personal information and obtain a copy;
- correct inaccurate or incomplete information;
- ask us to delete information;
- restrict how information is used;
- object to processing based on legitimate interests or to direct marketing;
- receive information you provided in a portable format where the legal conditions apply; and
- withdraw consent at any time where processing relies on consent.
These rights are not absolute. We may need to verify your identity and may retain information where the law permits or requires it. We will normally respond within one month, but complex or multiple requests may lawfully take longer. We will tell you if an extension is needed.
We do not currently use personal information to make solely automated decisions that produce legal or similarly significant effects.
Send requests or privacy complaints to snowy@snowflow.co.uk. You also have the right to complain to the Information Commissioner's Office. We would appreciate the opportunity to address the concern first. Visit ico.org.uk/make-a-complaint or call 0303 123 1113.
Last updated: .