Privacy Policy

1. Important information and who we are

(a) Privacy policy

This privacy policy gives you information about how Longevity Partners Limited (“Longevity”) collects, uses and protects your personal data in compliance with the UK and EU General Data Protection Regulation (“GDPR”) and other applicable data protection laws in the jurisdictions in which Longevity operates.

In particular this privacy policy outlines:

  • Information we collect and how we process your personal data.
  • Why we do this.
  • Your rights and how you can exercise them.
  • Who to contact in the event you require further assistance.

Longevity and its subsidiaries (“Group”) are made up of different legal entities. This privacy policy is issued on behalf of the Group so when we mention “Longevity”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Group responsible for processing your 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, please contact the DPO using the information set out in the contact details section (paragraph 10).

2. Types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

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

  • Identity Data includes first name, last name, any previous names, username or similar identifier, title and date of birth.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • 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, device ID and other technology on the devices you use to access this website and our platform services.
  • Profile Data includes your username and password and services provided to you via our platform services.
  • Usage Data includes information about how you interact with and use our website, platform services and our other services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature or our platform services in order to analyse general trends in how users are interacting with our website to help improve the website and our service offerings.

3. How is your personal data collected?

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

  • Your interactions with us. You may give us your personal data by filling in online forms, completing onboarding documentation (including any due diligence or compliance checks) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • request our services;
    • email enquiries to us or attend meetings or calls with us;
    • exchange contact information at networking events or through mutual contacts;
    • subscribe to our service or publications;
    • pay us for our services;
    • request marketing to be sent to you;
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website and platform services, we will automatically collect Technical Data about your 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 here for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Technical Data is collected from analytics providers, advertising networks or search information providers such as Microsoft 365, Microsoft Teams, Microsoft Entra ID, SharePoint, OneDrive which may be based outside the UK. :
    • Contact, Financial and Transaction Data is collected from providers of technical and payment services such as NetSuite, HubSpot, Quickbooks, Divvy, Xero, Pleo and various banks such as HSBC and Chaser based inside and outside the UK.
    • Identity and Contact Data is collected from publicly available sources such as Companies House and overseas registries.

4. How we use your personal data

(a) Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you a secure customer experience. We aim to consider and balance any potential impact on you and your rights (both positive and negative) 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).
  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to a newsletter.

(b) Purposes for which we will use your personal data

We have set out below a description of all the ways we may use the various categories of 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.

Purpose/Use

Type of data

Legal basis

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver the services, including:

(a) communicating with you regarding our services and invoicing

(b) managing payments, fees and charges

(c) collecting and recovering money owed to us

(d) ensuring we have the relevant subcontractors in place to allow us to deliver our commitments

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communication

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) notifying you about changes to our terms or privacy policy

(b) Dealing with your requests, complaints and queries

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)

To administer and protect our business, our platform services and this website (including troubleshooting, 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, 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 obligation

To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing

(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)

To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Consent, having obtained your prior consent to receiving direct marketing communications.

To allow authorised users to access our various platform services

(a) Identity

(b) Contact

(c) Profile

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to provide platform services as part of running our business)

In order to pay salaries, administer benefits and overall manage our obligations as an employer

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(a) Necessary for our legitimate interests (ensuring we are complying with our obligations as an employer in order to run our business).

(b) Necessary to comply with a legal obligation.

(c) Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which services and offers may be of interest to you so that we can then send you relevant marketing communications.

(d) Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

(e) Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

(f) Cookies

For more information about the cookies we use and how to change your cookie preferences, please see https://longevity-partners.com/cookie-policy/.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below in the course of delivering our services for the purposes set out in the table under paragraph 4(b) above.

  • Our IT service provider, IOIT, provides offsite backup services for us.
  •  
  • Gusto and BDO operate payroll on our behalf.
  • PeopleHR provides us a cloud-based HR management system, to help us administer employee records.
  • We may share information with members of the Leon Capital and Nuveen group companies to support us in day-to-day business administration.
  • We use the Office365 suite provided by Microsoft to handle our email and other office automation.
  • Oyster HR Inc is our employer of record service provider.
  • We use DocuSign to electronically sign various documents.
  • We use certain AI-enabled tools licensed to us under an enterprise agreement (i.e. Chat GPT) to support our internal operations, such as data organisation, workflow assistance, and analysis. Where these tools process personal data, they do so solely on our instructions and in compliance with applicable data protection laws. These tools are operated under contractual and technical safeguards.
  • Perk is our travel management company that assists with tracking our travel and any travel related expenses.
  • Marsh is our global insurance broker.
  • A list of our key sub-processors can be found here.
  • 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 privacy policy.

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

We share your personal data within the Longevity Group. This will involve transferring your data outside the UK to our overseas offices in several countries in Europe, Japan and United States of America.

Whenever we transfer your personal data out of the UK, we always ensure that a similar degree of protection is afforded to it.  The Longevity Group has an Intra-Group Personal Data Sharing and Transfer Agreement in place to enable compliance with applicable data protection laws and adherence to GDPR standards globally.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

  • We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
  • We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.

7. Data security

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.

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

(a) How long will you use my personal data for?

Details of retention periods for different aspects of your personal data are set out in our Data Retention Policy.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data – see paragraph 9 below for further information.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

Right

Explanation

Request access to you personal data (also known as a 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.

Request correction of the personal data 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.

Request erasure of your personal data in certain circumstances

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.

Object to processing your personal data

·        Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

·        You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see “Opting out of marketing” in paragraph 4 above for details of how to object to receiving direct marketing communications).

Request the transfer of your personal data to you or 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.

Withdraw consent at any time where we are relying on consent to process your personal data

Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 above for details of when we rely on your consent as the legal basis for using your 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.

Request restriction of processing of your personal data

This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

·        If you want us to establish the data’s accuracy;

·        Where our use of the data is unlawful but you do not want us to erase it;

·        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

·        You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise of any of the rights set out above, please contact us via our contact details below (paragraph 10). 

(a) 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 could refuse to comply with your request in these circumstances.

(b) 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.

(c) Time limit to respond

We will respond to valid requests without undue delay and in any event within one month of receipt. Where permitted by applicable law, this period may be extended (for example, if the request is complex or numerous), in which case we will inform you of the extension and the reasons for it.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO via dpo@longevity.co.uk.

All European data protection queries can be sent to our EU Representative via eurep@longevitypartners.nl.   

11. Complaints

You have the right to make a complaint to the following authorities:

  • If you are located in the UK, the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (ico.org.uk).
  • If you are located in the European Economic Area (EEA), you may lodge a complaint with your local supervisory authority for data protection matters in the EU Member State where you reside, work, or where the alleged infringement occurred.
  • If you are located in the US, you may raise concerns with the relevant state Attorney General or such competent state authority, which is responsible for enforcing applicable US data protection and privacy laws.
  • If you are located in Japan, you may make a complaint to the Personal Information Protection Commission (PPC), Japan’s data protection regulator.

However, before making a complaint please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. You can find our complaints procedure via our Feedback Policy here.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 30 January 2026. Historic versions be obtained by contacting us.

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, for example a new address or email address.

13. Third-party links

This website 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 website, we encourage you to read the privacy policy of every website you visit.

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