Privacy Policy

Welcome to the Odin Capital MB privacy policy.

Odin Capital MB respects your privacy and is committed to protecting your personal data.This privacy notice will inform you as to how we look after your personaldata when you visit our website and application (regardless of where youvisit it from) and tell you about your privacy rights and how the lawprotects you.

This privacy notice is provided in a layered format so you can clickthrough to the specific areas set out below. Please also use the Glossaryto understand the meaning of some of the terms used in this privacy notice.


Purpose of this privacy notice

This privacy notice aims to give you information on howOdin Capital MB collects and processes your personal datathrough your use of this website and application, including any data youmay provide through its website and application when you sign up to ournewsletter, our editorial programme or take part in a competition.

Its website and application are not intended for children and we do notknowingly collect data relating to children.

It is important that you read this privacy notice together with any otherprivacy notice or fair processing notice we may provide on specificoccasions when we are collecting or processing personal data about you sothat you are fully aware of how and why we are using your data. Thisprivacy notice supplements the other notices and is not intended tooverride them.


Odin Capital MB is the controller and responsible for your personal data (collectivelyreferred to as " Odin Capital MB ", "we", "us" or "our";in this privacy notice).

Our website and application may include links to third-party website andapplications, plug-ins and applications. Clicking on those links orenabling those connections may allow third parties to collect or share dataabout you. We do not control these third-party website and applications andare not responsible for their privacy statements. When you leave ourwebsite and application, we encourage you to read the privacy notice ofevery website and application you visit.

The data we collect about you

Personal data, or personal information, means any information about anindividual from which that person can be identified. It does not includedata where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal dataabout you which we have grouped together follows:

• Identity Data includes:

• Full name

• User name or similar identifier

• Account verification information

• Contact Data includes:

• Email addresses

• Telephone number

• Technical Data includes:

• IP address

• Login data

• Browser type and version

• Operating system, platform, and other technology on the devices used toaccess this website and application

• Time zone setting and location

• Profile Data includes:

• Your username and password

• Title and name

• Your place of work or study

• Your country of residence

• Links to your social media profiles

• Feedback and survey responses

• Usage Data includes information about how you use our website,application, products and services.

• Marketing and Communications Data includes your preferences in receivingmarketing from us, third parties, and your communication preferences.

We also collect, use and share Aggregated Data such as statistical ordemographic data for any purpose. Aggregated Data may be derived from yourpersonal data but is not considered personal data in law as this data doesnot directly or indirectly reveal your identity. For example, we mayaggregate your Usage Data to calculate the percentage of users accessing aspecific website and application feature. However, if we combine or connectAggregated Data with your personal data so that it can directly orindirectly identify you, we treat the combined data as personal data whichwill be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (thisincludes details about your race or ethnicity, religious or philosophicalbeliefs, sex life, sexual orientation, political opinions, trade unionmembership, information about your health and genetic and biometric data).Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data where we need to collect personal databy law, or under the terms of a contract we have with you and you fail toprovide that data when requested, we may not be able to perform thecontract we have or are trying to enter into with you (for example, toprovide you with goods or services). In this case, we may have to cancel aproduct or service you have with us but we will notify you if this is thecase at the time.

How is your personal data collected?We use different methods to collectdata from and about you including through:

• Direct interactions. You may give us your Identity, Contact, and ProfileData by filling in forms or by corresponding with us by post, phone, emailor otherwise. This includes personal data you provide when you:

• apply for our products or services

• create an account on our website or application

• subscribe to our service or publications

• request marketing to be sent to you

• enter a competition, promotion or survey

• give us some feedback.

• Automated technologies or interactions. As you interact with our websiteand application, we may automatically collect Technical Data about yourequipment, browsing actions and patterns. We collect this personal data byusing cookies, server logs and other similar technologies. We may alsoreceive Technical Data about you if you visit other website andapplications employing our cookies.

• Third parties or publicly available sources. We may receive personal dataabout you from various third parties and public sources as set out below:

• Technical Data from the following parties:

1. Analytics providers, such as Google based inside and outside the EU2.Advertising networks, such as Facebook based inside and outside the EU3.Search information providers4. Identity and Contact Data from data brokersor aggregators based inside and outside the EU.

How we use your personal data

We will only use your personal data when the law allows us to. Mostcommonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or haveentered into with you.

• Where it is necessary for our legitimate interests (or those of a thirdparty) and your interests and fundamental rights do not override thoseinterests.

• Where we need to comply with a legal or regulatory obligation.

See below to find out more about the types of lawful basis that we willrely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing yourpersonal data other than in relation to sending third party directmarketing communications to you via email or text message.You have theright to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal dataWe have set out below adescription of all the ways we plan to use your personal data, and which ofthe legal bases we rely on to do so. We have also identified what ourlegitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful grounddepending on the specific purpose for which we are using your data. Pleasecontact us if you need details about the specific legal ground we arerelying on to process your personal data where more than one ground hasbeen set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basisof legitimate interestTo register you as a new member or user and createa member profile for you(a) Identity(b) Contact(a) Performance againstTerms of Service and/or contract with you(b) Necessary for our legitimateinterests (to develop our products/services and grow our business)Toregister you as a new customer(a) Identity(b) Contact Performance of acontract with youTo process and deliver your order including:(a) Managepayments, fees and charges(b) Collect and recover money owed to us(a)Identity(b) Contact(c) Financial(d) Transaction(e) Marketing andCommunications(a) Performance of a contract with you(b) Necessary forour legitimate interests (to recover debts due to us)To manage ourrelationship with you which will include:(a) Notifying you about changesto our terms or privacy policy(b) Asking you to leave a review or take asurvey(a) Identity(b) Contact(c) Profile(d) Marketing andCommunications(a) Performance of a contract with you(b) Necessary tocomply with a legal obligation(c) Necessary for our legitimate interests(to keep our records updated and to study how customers use ourproducts/services)To enable you to partake in a prize draw, competitionor complete a survey(a) Identity(b) Contact(c) Profile(d) Usage(e)Marketing and Communications(a) Performance of a contract with you(b)Necessary for our legitimate interests (to study how customers use ourproducts/services, to develop them and grow our business)To administerand protect our business and its website and application (includingtroubleshooting, data analysis, testing, system maintenance, support,reporting and hosting of data)(a) Identity(b) Contact(c) Technical(a)Necessary for our legitimate interests (for running our business, provisionof administration and IT services, network security, to prevent fraud andin the context of a business reorganisation or group restructuringexercise)(b) Necessary to comply with a legal obligationTo deliverrelevant website and(a) Identity necessary for our legitimateinterests(b) To application content and advertisements to you and measureor understand the effectiveness of the advertising we serve to you(c)Contact(d) Profile(e) Usage(f) Marketing and Communications(g)Technical study how customers use our products/services, to develop them,to grow our business and to inform our marketing strategyTo use dataanalytics to improve our website and application, products/services,marketing, customer relationships and experiences(a) Technical(b) UsageNecessary for our legitimate interests (to define types of customers forour products and services, to keep our website and application updated andrelevant, to develop our business and to inform our marketing strategy)Tomake suggestions and recommendations to you about goods or services thatmay be of interest to you(a) Identity(b) Contact(c) Technical(d)Usage(e) ProfileNecessary for our legitimate interests (to develop ourproducts/services and grow our business)MarketingWe strive to provideyou with choices regarding certain personal data uses, particularly aroundmarketing and advertising. We have established the following personal datacontrol mechanisms:

Promotional offers from usWe may use your Identity, Contact, Technical,Usage and Profile Data to form a view on what we think you may want orneed, or what may be of interest to you. This is how we decide whichproducts, services and offers may be relevant for you (we call thismarketing).

You will receive marketing communications from us if you have requestedinformation from us or purchased goods or services from us or if youprovided us with your details when you entered a competition or registeredfor a promotion and, in each case, you have not opted out of receiving thatmarketing.

fCookiesYou can set your browser to refuse all or some browser cookies, orto alert you when websites set or access cookies. If you disable or refuseall cookies, please note that you will not be able to sign in to thiswebsite. For more information about the cookies we use, please see ourcookie policy .

Change of purposeWe will only use your personal data for the purposes forwhich we collected it, unless we reasonably consider that we need to use itfor 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 newpurpose is compatible with the original purpose, please contact us .

If we need to use your personal data for an unrelated purpose, we willnotify 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 knowledgeor consent, in compliance with the above rules, where this is required orpermitted by law.

Disclosures of your personal dataWe may have to share your personal datawith the parties set out below for the purposes set out in the table inparagraph 4 above.

• Internal Third Parties as set out in the Glossary .

• External Third Parties as set out in the Glossary .

• Third parties to whom we may choose to sell, transfer, or merge parts ofour business or our assets. Alternatively, we may seek to acquire otherbusinesses or merge with them. If a change happens to our business, thenthe new owners may use your personal data in the same way as set out inthis privacy notice.

We require all third parties to respect the security of your personal dataand to treat it in accordance with the law. We do not allow our third-partyservice providers to use your personal data for their own purposes and onlypermit them to process your personal data for specified purposes and inaccordance with our instructions.

International transfersWe share your personal data within theOdin Capital MB Group. This will involve transferring yourdata outside the European Economic Area (EEA).

Many of our external third parties are based outside the European EconomicArea (EEA) so their processing of your personal data will involve atransfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similardegree of protection is afforded to it by ensuring at least one of thefollowing safeguards is implemented:

• We will only transfer your personal data to countries that have beendeemed to provide an adequate level of protection for personal data by theEuropean Commission. For further details, see European Commission: Adequacyof the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contractsapproved by the European Commission which give personal data the sameprotection it has in Europe. For further details, see European Commission:Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them ifthey are part of the Privacy Shield which requires them to provide similarprotection to personal data shared between the Europe and the US. Forfurther details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanismused by us when transferring your personal data out of the EEA.

Data securityWe have put in place appropriate security measures to preventyour personal data from being accidentally lost, used or accessed in anunauthorised way, altered or disclosed. In addition, we limit access toyour personal data to those employees, agents, contractors and other thirdparties who have a business need to know. They will only process yourpersonal data on our instructions andthey are subject to a duty ofconfidentiality.

We have put in place procedures to deal with any suspected personal databreach and will notify you and any applicable regulator of a breach wherewe are legally required to do so.

Data retentionHow long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfilthe purposes we collected it for, including for the purposes of satisfyingany legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, weconsider the amount, nature, and sensitivity of the personal data, thepotential risk of harm from unauthorised use or disclosure of your personaldata, the purposes for which we process your personal data and whether wecan achieve those purposes through other means, and the applicable legalrequirements.

By law we have to keep basic information about our customers (includingContact, Identity, Financial and Transaction Data) for six years after theycease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [Requesterasure] below for further information.

In some circumstances we may anonymise your personal data (so that it canno longer be associated with you) for research or statistical purposes inwhich case we may use this information indefinitely without further noticeto you.

Your legal rightsUnder certain circumstances, you have rights under dataprotection laws in relation to your personaldata. Please click on thelinks below to find out more about these rights:

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually requiredYou will not have to pay a fee to access yourpersonal data (or to exercise any of the other rights). However, we maycharge a reasonable fee if your request is clearly unfounded, repetitive orexcessive. Alternatively, we may refuse to comply with your request inthese circumstances.

What we may need from youWe may need to request specific information fromyou to help us confirm your identity and ensure your right to access yourpersonal data (or to exercise any of your other rights). This is a securitymeasure to ensure that personal data is not disclosed to any person who hasno right to receive it. We may also contact you to ask you for furtherinformation in relation to your request to speed up our response.

Time limit to respondWe try to respond to all legitimate requests withinone month. Occasionally it may take us longer than a month if your requestis particularly complex or you have made a number of requests. In thiscase, we will notify you and keep you updated.



Legitimate Interest means the interest of our business in conducting andmanaging our business to enable us to give you the best service/product andthe best and most secure experience. We make sure we consider and balanceany potential impact on you (both positive and negative) and your rightsbefore we process your personal data for our legitimate interests. We donot use your personal data for activities where our interests areoverridden by the impact on you (unless we have your consent or areotherwise required or permitted to by law). You can obtain furtherinformation about how we assess our legitimate interests against anypotential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessaryfor the performance of a contract to which you are a party or to take stepsat your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personaldata where it is necessary for compliance with a legal or regulatoryobligation that we are subject to.


Internal Third Parties

Other companies in the Odin Capital MB Group (being atpresent Odin Capital MB Limited whose registered addressis Unit 18 Poplar Drive Poplar Drive, Witton, Birmingham, United Kingdom,B6 7AD, Company Number: 12021691) acting as joint controllers or processorsand who are based in the EU and provide IT and system administrationservices and undertake leadership reporting.

External Third Parties

• Service providers acting as processors based in and outside the EU whoprovide IT, system administration and technology services.

• Professional advisers acting as processors or joint controllers includinglawyers, bankers, auditors and insurers based in andoutside the EU whoprovide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting asprocessors or joint controllers based in the United Kingdom who requirereporting of processing activities in certain circumstances.


You have the right to:

1. Request access to your personal data (commonly known as a "data subjectaccess request"). This enables you to receive a copy of the personal datawe hold about you and to check that we are lawfully processing it.

2. Request correction of the personal data that we hold about you. Thisenables you to have any incomplete or inaccurate data we hold about youcorrected, though we may need to verify the accuracy of the new data youprovide to us.

3. Request erasure of your personal data. This enables you to ask us todelete or remove personal data where there is no good reason for uscontinuing to process it. You also have the right to ask us to delete orremove your personal data where you have successfully exercised your rightto object to processing (see below), where we may have processed yourinformation unlawfully or where we are required to erase your personal datato comply with local law. Note, however, that we may not always be able tocomply with your request of erasure for specific legal reasons which willbe notified to you, if applicable, at the time of your request.

4. Object to processing of your personal data where we are relying on alegitimate interest (or those of a third party) and there is somethingabout your particular situation which makes you want to object toprocessing on this ground as you feel it impacts on your fundamental rightsand freedoms. You also have the right to object where we are processingyour personal data for direct marketing purposes. In some cases, we maydemonstrate that we have compelling legitimate grounds to process yourinformation which override your rights and freedoms.

5. Request restriction of processing of your personal data. This enablesyou to ask us to suspend the processing of your personal data in thefollowing scenarios:(a) if you want us to establish the datasaccuracy(b) where our use of the data is unlawful but you do not want usto erase it(c) where you need us to hold the data even if we no longerrequire it as you need it to establish, exercise or defend legal claims(d)you have objected to our use of your data but we need to verify whether wehave overriding legitimate grounds to use it.6. Request the transfer ofyour personal data to you or to a third party. We will provide to you, or athird party you have chosen, your personal data in a structured, commonlyused, machine-readable format. Note that this right only applies toautomated information which you initially provided consent for us to use orwhere we used the information to perform a contract with you7. Withdrawconsent at any time where we are relying on consent to process yourpersonal data. However, this will not affect the lawfulness of anyprocessing carried out before you withdraw your consent. If you withdrawyour consent, we may not be able to provide certain products or services toyou. We will advise you if this is the case at the time you withdraw yourconsent.