Privacy Policy

1. About this policy

Foothold America Limited (“Foothold”, “we”, “us”, “our”) is committed to protecting and respecting your privacy. This policy applies to our website, https://www.footholdamerica.com/ (the “Site”), and to our wider business, including our subsidiary companies.

It explains what personal data we collect, why we collect it, who we share it with, how long we keep it, and what rights you have. We handle personal data in line with applicable data protection law, including the UK GDPR, the Data Protection Act 2018 and, where it applies, the EU GDPR.

Personal data means any information that can identify a living person, such as a name, address, email address, phone number, IP address, photo or date of birth. Processing means anything we do with it, including collecting, storing, using, sharing and deleting it.

2. Who we are and how to contact us

Foothold America Limited is the controller of your personal data.

• UK registered address: 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
• US headquarters: 68 Harrison Avenue, 6th Floor, Boston, MA 02111
• Data Protection Officer: Geanice Barganier, gbarganier@footholdamerica.com
• General enquiries: info@footholdamerica.com

If you have any questions about this policy or how we use your data, please contact our Data Protection Officer.

3. What personal data we collect

We collect personal data when you use the Site, contact us by email, phone or post, or meet with us. Depending on how you deal with us, this may include:

• Identity and contact details: your name, address, phone number and email address, including details you give when you register to receive updates.
• Technical data: your IP address, approximate location, browser type, the website that referred you, and which pages you visit and for how long.
• Service information: details of the services and materials we provide or plan to provide to you, and any information we need to deliver those services.
• Financial details that you provide to us.

We also process personal data about our suppliers, employees, independent contractors, advisers and professional experts.

Some personal data is mandatory for us to meet client due diligence and other legal requirements. If you cannot provide it, we may not be able to provide our services to you.

4. How we use your data and our legal basis

We only use your personal data where the law allows us to. The table shows the main ways we use it.

We keep accurate and up-to-date records about the services you receive so that we can give you the right advice, tell you about relevant new services, and investigate any concerns you raise. If we want to use your data for a new purpose, we will ask you first unless the law requires or allows otherwise.

5. Sensitive data

Some data is more sensitive, such as information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, or sex life or sexual orientation. We do not normally process this kind of information. If we ever need to, we will only do so with your explicit consent or where the law otherwise permits. If you withdraw consent, we may not be able to deliver all of our services.

6. Who we share your data with

Your information is seen by Foothold staff, contractors and others who help us deliver our services. We only share it when there is a legitimate need to. This may include:

• suppliers, business associates and professional advisers
• financial organisations and official bodies
• online service providers, such as TriNet, HubSpot, WordPress and Google

We may also disclose information about you:

• where the law requires it
• in connection with legal proceedings or prospective legal proceedings
• to establish, exercise or defend our legal rights, including to prevent fraud and reduce credit risk
• to a buyer or prospective buyer of any business or asset we are selling or considering selling

We do not sell or rent your personal data, and we never share it with other organisations for their own marketing.

7. Transfers outside your country

We operate in the UK and the US, and some of our service providers are based elsewhere. This means your data may be stored or processed outside the UK and the European Economic Area (EEA). Where we do this, we take steps to make sure your data stays protected in line with data protection law, using appropriate safeguards where they are required.

8. How we keep your data secure

We take care to treat your personal data securely. We use physical, electronic and organisational measures to prevent loss, misuse, alteration and unauthorised access. Personal data is stored on password- and firewall-protected servers, and electronic transactions containing sensitive information are encrypted using SSL technology. Every member of staff has a duty to keep information about you secure and confidential.

No method of sending data over the internet is completely secure, so we cannot guarantee the security of information you send to us online.

9. Marketing

We like to keep in touch with our clients and with people who have enquired about our services, to share news, promotions and useful information by email and newsletter. Every marketing message includes a way to unsubscribe, and you can opt out at any time by contacting us. We respect all valid opt-out requests.

10. How long we keep your data

We keep personal data only for as long as reasonably necessary for the purposes we collected it for, and to meet legal, accounting and regulatory requirements. When we no longer need it, we delete it or anonymise it. We may keep anonymised data, which no longer identifies you, for statistical purposes without a time limit.

11. Your rights

Under data protection law you have the following rights over your personal data. Some are subject to conditions and exemptions.

• Access: ask for a copy of the personal data we hold about you (a subject access request). You can ask in writing or verbally, but it helps if you put it in writing and say what you need, such as a particular time period. We may ask for proof of your identity, and for written consent and ID if someone is asking on your behalf.
• Rectification: ask us to correct inaccurate or incomplete data.
• Erasure: ask us to delete your data. We will do so unless we have a lawful reason to keep it, such as an archiving obligation.
• Restriction: ask us to limit how we use your data in certain circumstances.
• Portability: in certain circumstances, ask for your data in a structured, commonly used, machine-readable format, or ask us to transfer it to another provider.
• Objection: object to our processing, including for marketing, which we will always stop. For other processing we will comply unless we have a compelling legitimate reason to continue.
• Withdraw consent: where we rely on your consent, you can withdraw it at any time. This does not affect anything we did before you withdrew it.
• Automated decisions: we do not make decisions about you using only automated means. We may use third-party due diligence platforms that give automated recommendations, and a person reviews them.

To use any of these rights, contact our Data Protection Officer using the details in section 2. We try to keep the data we hold accurate and up to date, and we may check with you from time to time. If anything is wrong, ask us to change it.

12. Complaints

We would like the chance to put things right first, so please contact us with any concern. You also have the right to complain directly to the data protection authority in your country. In the UK this is the Information Commissioner’s Office.

13. Cookies

Our Site uses cookies and similar technologies to work properly, to understand how it is used and to improve it. We may also receive technical data about you if you visit other websites that use our cookies. You can control cookies through your browser settings. If you turn cookies off, some parts of the Site may not work properly. For full details, see our Cookie Policy.

14. Links to other websites

Our Site may link to websites run by other organisations. This policy applies only to our Site. We are not responsible for the privacy practices of other websites, so please read their privacy notices before you share your data with them.

15. Changes to this policy

We review our policies regularly and may update this one by posting a new version on our Site. The “Last updated” date at the top shows when it last changed. Please check this page from time to time. For significant changes, we may also tell you by email.