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You are here:

 1. Home Home
 2. Data Privacy Notice


DATA PRIVACY NOTICE

This is the privacy policy (the “Data Privacy Notice”) of:

N.M. Rothschild & Sons Limited trading as Arrowpoint Advisory of registered
address New Court, St. Swithin's Lane, London EC4N 8AL (registered number
00925279) (“Arrowpoint Advisory”);

This Data Privacy Notice is issued on behalf of Arrowpoint Advisory ( “We”, “Us”
or “Our” in this Data Privacy Notice). We are part of the Rothschild & Co group.

We respect your privacy and are committed to protecting your personal data. This
Data Privacy Notice will inform you as to how We look after your personal data
when you visit Our website at https://arrowpointadvisory.com (the “Site”),
regardless of where you visit it from, and tell you about your privacy rights
and how the law protects you.

1. Important information and who we are

2. The data we collect about you

3. How is your personal data collected

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary


1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 Purpose of this data privacy notice

(a) This Data Privacy Notice aims to give you information on how We collect and
process your personal data through your use of the Site, including any data you
may provide through the Site when you:

i. register with Us;
ii. register for any of Our events;
iii. fill out Our online contact form;
iv. correspond with Us;
v. sign up to Our newsletter;
vi. purchase a product or service; and/or
vii. take part in a competition.

(b) This Site is not intended for children and We do not knowingly collect data
relating to children.

(c) It is important that you read this Data Privacy Notice together with any
other privacy notice or fair processing 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 Data Privacy
Notice supplements the other notices and is not intended to override them.

1.2 Controller

(a) N.M. Rothschild & Sons Limited trading as Arrowpoint Advisory is the
controller and responsible for the Site.
(b) We have appointed a data protection officer (the “DPO”) who is responsible
for overseeing questions in relation to this Data Privacy Notice. If you have
any questions about this Data Privacy Notice, including any requests to exercise
your legal rights, please contact the DPO using the following details:

Full name of legal entity: N.M. Rothschild & Sons Limited trading as Arrowpoint
Advisory
Name or title of DPO: Finance Director
Email address: data.protection@rothschildandco.com
Postal address: 15 Adam Street, London, WC2N 6RJ

(c) You have the right to make a complaint at any time to the Information
Commissioner's Office, the UK supervisory authority for data protection issues
(ico.org.uk) or to any equivalent body in the relevant jurisdiction
(collectively, the “ICO”). 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 Your duty to inform us of changes
This version was last updated on 1 August 2022.
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.

1.4 Third-party links
The 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 the Site,
We encourage you to read the data privacy notice of every website you visit.


2. THE DATA WE COLLECT ABOUT YOU

2.1 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 data).

2.2 We may collect, use, store and transfer different kinds of personal data
about you which We have grouped together as follows:

(a) “Identity Data” includes first name, maiden name, last name, username or
similar identifier, marital status, title, date of birth, photographs, job
title, national insurance number, age and gender;
(b) “Contact Data” includes billing address, residential address, delivery
address, email address, work address, social media handles, telephone numbers
and fax number;
(c) “Financial Data” includes bank account details;
(d) “Transaction Data” includes details about payments to and from you and other
details of products and services you have purchased from us;
(e) “Technical Data” includes 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, full 'Uniform Resource Locators'
clickstream to, through and from the Site (including date and time) and other
technology on the devices you use to access the Site;
(f) “Profile Data” includes your username and password, purchases or orders made
by you, your interests, preferences, feedback and survey responses, products you
viewed or searched for; page response times; download errors; length of visits
to certain pages; page interaction information (such as scrolling, clicks,
mouse-overs and methods used to browse away from the page);
(g) “Usage Data” includes information about how you use the Site, products and
services; and
(h) “Marketing and Communications Data” includes your preferences in receiving
marketing from us and Our third parties and your communication preferences.

2.3 We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data does not
directly or indirectly reveal your identity. For example, We may aggregate your
Usage Data to calculate the percentage of users accessing a specific Site
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 Data Privacy
Notice.

2.4 We may also collect personal data that includes “Sensitive/Special
Categories” of personal data, such as medical information.

2.5 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 goods or services). In this case, We may have to
cancel a product or service you have with Us but We will notify you if this is
the case at the time.


3. HOW IS YOUR PERSONAL DATA COLLECTED?

3.1 We use different methods to collect data from and about you including
through:

(a) Direct interactions. You may give Us your Identity Data, Contact Data and
Financial Data by filling in forms or by corresponding with Us by post, phone,
email or otherwise. This includes personal data you provide when you:

i. apply for Our products or services;
ii. register for any of Our events;
iii. create an account on the Site;
iv. subscribe to Our service or publications;
v. request marketing to be sent to you;
vi. enter a competition, promotion or survey; or
vii. give us some feedback.

(b) Automated technologies or interactions. As you interact with the Site, We
may automatically collect Technical Data about your equipment, browsing actions
and patterns. We collect this personal data by using cookies, server logs and
other similar technologies. We may also receive Technical Data about you if you
visit other websites employing our cookies. Please see Our Cookie Policy (the
“Cookie Policy”) for further details.
(c) Third parties or publicly available sources. We may receive personal data
about you from various third parties and public sources such as analytics
providers, search information providers, advertising networks, technical,
payment and delivery services, data brokers or aggregators and publicly
available sources such as Companies House and the Electoral Register based
inside the EU. Please Contact Us to find out more about the various third
parties and public sources from which We may receive personal data about you.


4. HOW WE USE YOUR PERSONAL DATA

4.1 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:

(a) Where We need to perform the contract We are about to enter into or have
entered into with you.
(b) 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.
(c) Where We need to Comply with a Legal or Regulatory Obligation.

4.2 Please Contact Us to find out more about the types of lawful basis that We
will rely on to process your personal data.

4.3 Generally, We do not rely on consent as a legal basis for processing your
personal data other than in relation to sending third party direct marketing
communications to you via email or text message. You have the right to withdraw
consent to marketing at any time by Contacting Us.

4.4 Purposes for which we will use your personal data:

(a) We have set out below, in a table format, 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 what Our Legitimate Interests are where appropriate.
(b) 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 Type of data Lawful basis for
processing including basis of Legitimate Interest Retention period
To register you as a new customer
(a) Identity Data
(b) Contact Data
Performance of a Contract with you
7 years
To provide our services to you including:
(a) processing instructions
(b) providing confirmation, advice and statements
(c) carrying out risk assessments for reporting and management (a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Marketing and
Communications Data (a) Performance of a
Contract with you
(b) Necessary for Our
Legitimate Interests (to
recover debts due to Us) 7 years To manage Our relationship with you which will
include:
(a) Notifying you about changes to Our terms or Data Privacy Notice
(b) Asking you to leave a review or take a survey (a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Marketing and
Communications Data (a) Performance of a Contract with you
(b) Necessary for Our
Legitimate Interests (to
study how customers use Our products/ services, to develop them and grow Our
business) 7 years To enable you to partake in a prize draw, competition or
complete a survey (a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Usage Data
(e) Marketing and
Communications Data (a) Performance of a
Contract with you
(b) Necessary for Our
Legitimate Interests (to
study how customers use
Our products/services, to
develop them and grow
Our business) 2 years To administer and protect Our business and the
Site (including troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data) (a) Identity Data
(b) Contact Data
(c) Technical 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 or Regulatory Obligation 2 years To deliver relevant Site content
and advertisements to you and measure or understand the  effectiveness of
the advertising We serve to you (a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Usage Data
(e) Marketing and
Communications Data
(f) Technical Data Necessary for Our
Legitimate Interests (to
study how customers use
Our products/services, to
develop them, to grow Our business and to inform Our marketing strategy) 2 years
To use data analytics to improve the Site and Our products/services,
marketing, customer relationships and experiences (a) Technical Data
(b) Usage Data Necessary for Our
Legitimate Interests (to
define types of customers
for Our products and
services, to keep the Site
updated and relevant, to
develop Our business and
to inform Our marketing
strategy) 2 years To make suggestions and recommendations to you about goods or
services that may be of interest to you (a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Profile Data Necessary for Our
Legitimate Interests (to
develop Our products/services and grow Our business) 2 years

 

Marketing & Measurement Type of data Lawful basis for
processing including basis of Legitimate Interest Third parties involved
in processing To use data analytics to improve our website, products/services,
marketing, customer relationships and experiences (a) Technical
(b) Usage Necessary for our
legitimate interests (to
define types of customers
for our products and services, to keep our website updated and
relevant, to develop our
business and to inform our marketing strategy). For further information please
see Google's Privacy & Terms https://policies.google.com/ Google Analytics To
send Email Marketing messages about services we offer, and content that we
create (a) Identity
(b) Contact
(c) Marketing and Communications Users can opt out of marketing activity by
clicking the unsubscribe link in the emails they receive, or by contacting us
directly. Records of consent are maintained in our CRM (Salesforce). Adestra,
Salesforce To target display advertising to users that have previously visited
our website and shown interest in our products and services (a) Technical
(b) Usage
(c) Profile Necessary for our legitimate interests (to define customer types and
serve relevant messaging to users that are interesting in our products &
services).

No Identity or contact data is used in this process. Users can opt out of
processing in this way by blocking cookies. Google Adwords, Google Analytics To
analyse user's sessions
on our website, by recording their mouse movements and website behaviours to
identify website issues and improve the users experience (a) Technical
(b) Usage
(c) Profile Necessary for our
legitimate interests (to
keep our website updated, free from issues, and provide the best possible user
experience. We use this data to measure how users are interacting with our site,
which elements of the site are causing problems with the user experience, and if
there are any errors with the site. This also includes replaying sessions and
watching interactions back. No Contact or Identity information is recorded or
processed. Users can opt out by blocking cookies. Hotjar To measure interactions
with, and how you share our content on social networks (a) Technical
(b) Usage
(c) Profile Necessary for our legitimate interests (to allow users to click
through to, follow and like, or share our content on social media).
Data is collected by social media platforms when users use their share, like and
follow buttons. For access to this information, or to opt out, users can adjust
their account settings on the relevant platforms. LinkedIn

 

4.5 Automated decision making
We do not use your personal data to make automated decisions.

4.6 Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.

4.7 Promotional offers from us

(a) We may use your Identity Data, Contact Data, Technical Data, Usage Data and
Profile Data to form a view on what We think you may want or need, or what may
be of interest to you. This is how We decide which products, services and offers
may be relevant for you (We call this marketing).
(b) You will receive marketing communications from Us if you have requested
information from Us or purchased goods or services from Us or if you provided Us
with your details when you entered a competition or registered for a promotion
and, in each case, you have not opted out of receiving that marketing.

4.8 Third-party marketing
We will get your express opt-in consent before We share your personal data with
any company outside Arrowpoint Advisory for marketing purposes.

4.9 Opting out

(a) You can ask us or third parties 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 any time.
(b) Where you opt out of receiving these marketing messages, this will not apply
to personal data provided to us as a result of a product/service purchase,
product/service experience or other transactions.

4.10 Cookies
You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of the Site may become inaccessible or not function
properly. For more information about the cookies We use, please see Our Cookie
Policy.

4.11 Change of purpose

(a) 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 Us.
(b) 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.
(c) 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.


5. DISCLOSURE OF YOUR PERSONAL DATA

5.1 We may have to share your personal data with the parties set out below for
the purposes set out in the table in paragraph 4.4 above.

(a) Internal Third Parties as set out in paragraph 10.2(a) below.
(b) External Third Parties as set out in paragraph 10.2(b) below.
(c) Specific third parties listed in the table in paragraph 4.4 above.
(d) Third parties to whom We may choose to sell, transfer, or merge parts of Our
business or Our assets. Alternatively, We may seek to acquire other businesses
or merge with them. If a change happens to Our business, then the new owners may
use your personal data in the same way as set out in this Data Privacy Notice.

5.2 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.


6. INTERNATIONAL TRANSFERS

6.1 We share your personal data within the Rothschild & Co group as necessary.
This may involve transferring your data outside the European Economic Area (the
“EEA”).

6.2 Some internal third parties and external third parties may be based outside
the EEA so our processing of your personal data may involve a transfer of data
outside the EEA. Such destinations may not have laws which protect your
information to the same extent as in the EEA.

6.3 Whenever We transfer your personal data out of the EEA, We ensure a similar
degree of protection is afforded to it by ensuring at least one of the following
safeguards is implemented:

(a) We will only transfer your personal data to countries that have been deemed
to provide an adequate level of protection for personal data by the European
Commission. For further details, see European Commission: Adequacy of the
protection of personal data in non-EU countries.
(b) Where We use certain service providers, We may use specific contracts
approved by the European Commission which give personal data the same protection
it has in Europe. For further details, see European Commission: Model contracts
for the transfer of personal data to third countries.
(c) Where We use providers based in the US, We may transfer data to them if they
are part of the Privacy Shield which requires them to provide similar protection
to personal data shared between the Europe and the US. For further details, see
European Commission: EU-US Privacy Shield.

6.4 Please Contact Us if you want further information on the specific mechanism
used by Us when transferring your personal data out of the EEA.


7. DATA SECURITY

7.1 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 business
need to know. They will only process your personal data on Our instructions and
they are subject to a duty of confidentiality.

7.2 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.


8. DATA RETENTION

8.1 How long will you use my personal data for?

8.2 We will only retain your personal data for as long as necessary to fulfil
the purposes We collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements.

8.3 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 requirements.

8.4 Details of retention periods for different aspects of your personal data are
set out in the table in paragraph 4.4 above.

8.5 By law We have to keep basic information about Our customers (including
Contact Data, Identity Data, Financial Data and Transaction Data) for seven
years after they cease being customers for tax purposes.

8.6 In some circumstances you can ask Us to delete your data: see Request
erasure below for further information.

8.7 In some circumstances We may 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.


9. YOUR LEGAL RIGHTS

9.1 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: 

(a) Request access to your personal data.
(b) Request correction of your personal data.
(c) Request erasure of your personal data.
(d) Object to processing of your personal data.
(e) Request restriction of processing your personal data.
(f) Request transfer of your personal data.
(g) Right to withdraw consent.

9.2 If you wish to exercise any of the rights set out in paragraph 9.1 above,
please Contact Us.

9.3 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 may refuse to
comply with your request in these circumstances.

9.4 What we may need from you
We may need to request specific information from you to help Us confirm your
identity and ensure 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.

9.5 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it
may 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.


10. GLOSSARY

10.1 Lawful basis

(a) “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.
(b) “Performance of a 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.
(c) “Comply with a Legal or Regulatory Obligation” means processing your
personal data where it is necessary for compliance with a legal or regulatory
obligation that We are subject to.

10.2 Third parties

(a) Internal third parties:

Other companies in the Rothschild & Co group.

(b) External third parties:

i. Service providers acting as processors who provide IT, system administration,
CRM, collaboration, marketing automation, market research, public relations and
email communication services.
ii. Professional advisers including lawyers, bankers, auditors and insurers who
provide consultancy, banking, legal, insurance and accounting services.
iii.HM Revenue & Customs, regulators and other authorities in the relevant
jurisdictions acting as processors or joint controllers who require reporting of
processing activities in certain circumstances.
iv: to third parties relevant to the services outlined in our contract with you
or which with you are connected. this may include counterparties to
transactions, stock exchanges or regulators.

10.3 Your legal rights

You have the right to:

(a) 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.
(b) 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.
(c) 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.
(d) 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.
(e) 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: (a) if you want Us to establish the data's accuracy; (b) where Our
use of the data is unlawful but you do not want Us to erase it; (c) 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; or (d) you have objected to Our use
of your data but We need to verify whether We have overriding legitimate grounds
to use it.
(f) 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.
(g) 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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