1. Who we are
This Privacy Policy explains how New Frontier Holdings Ltd, trading as Frontier Botanics (Company No. 12111072), of First Floor, 690 Great West Road, Osterley Village, Isleworth, England TW7 4PU (“Frontier Botanics”, “we”, “us”) collects and uses personal data when you visit frontierbotanics.com, contact us, or enquire about investing. We are the “controller” of your personal data under the UK GDPR and the Data Protection Act 2018.
Our ICO registration number is [ICO registration number]. You can contact us about this policy or your data at info@frontierbotanics.com or by post at the address above, marked “Data Protection”.
2. The personal data we collect
We collect only what we need. Depending on how you interact with us, this may include:
- Enquiry details: your name, email address, telephone number, the message you send, and the plan or topic you are interested in.
- Investor status declaration: which category you tell us you fall into (high net worth investor, sophisticated investor, or general enquiry only). We use this to decide whether we can send you investment materials.
- Correspondence: emails, call notes and other communications with our team.
- Technical data: IP address, browser type, device information and pages viewed, collected by our hosting systems and, only if you consent, by analytics.
- Your privacy choices: a record of your cookie and analytics preferences, stored in your browser.
If you proceed to invest, we will separately collect the identity, eligibility and financial information needed to complete your subscription and to meet legal obligations (for example anti-money-laundering checks). We will tell you what is needed at that stage.
Please do not send us sensitive information (such as health details) through the website form.
3. How and why we use your data
We must have a lawful basis for using personal data. Ours are set out below.
| Purpose | Data | Lawful basis |
|---|---|---|
| Responding to your enquiry and sending information you request | Enquiry details, correspondence | Legitimate interests (answering enquiries); steps at your request before entering a contract |
| Checking whether you are an eligible investor before sharing investment materials | Investor status declaration, enquiry details | Legitimate interests (acting within financial promotion rules); legal obligation where applicable |
| Processing a subscription, onboarding and investor relations | Identity, contact and investment details | Performance of a contract; legal obligation (including anti-money-laundering and company law) |
| Keeping the site secure and working | Technical data | Legitimate interests (security and reliability) |
| Understanding how the site is used (optional analytics) | Technical data | Consent, which you can withdraw at any time |
| Sending updates about the company or funding round | Name, email | Consent, or where lawful, legitimate interests in business-to-business communications, with an easy opt-out in every message |
| Meeting legal and regulatory duties, and establishing or defending legal claims | Any relevant data | Legal obligation; legitimate interests |
We do not use your data for automated decision-making that has legal or similarly significant effects on you.
4. Who we share data with
We do not sell your personal data. We share it only where necessary with:
- Our Lesotho subsidiary, Frontier Botanics Lesotho (Proprietary) Limited, where relevant to your enquiry or investment.
- Service providers acting on our instructions, such as website hosting, email and communications, form handling, document signing, and customer-relationship or investor-management software.
- Professional advisers such as lawyers, accountants, auditors and compliance consultants, who are bound by confidentiality.
- Regulators, law-enforcement and public authorities where we are required or permitted by law to do so.
- Prospective buyers or investors in our business, under confidentiality, if our business or assets are reorganised or sold.
We require our service providers to protect your data and to use it only for the services they provide to us.
5. International transfers
Because we operate in the UK and Lesotho and use international service providers, your data may be transferred outside the UK. Where it is, we use appropriate safeguards required by UK data protection law, such as transfers to countries recognised as providing adequate protection, or the ICO’s International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses. You can contact us for more information about these safeguards.
6. How long we keep your data
We keep personal data only for as long as needed for the purposes above:
- General enquiries: up to 24 months after our last contact with you.
- Investor records (including eligibility declarations and subscription documents): for the period required by law and, in any event, up to six years after our relationship ends, to meet legal, accounting and regulatory obligations and to deal with claims.
- Marketing preferences: until you unsubscribe or withdraw consent, plus a minimal suppression record so we do not contact you again.
- Technical logs: for a short period consistent with security needs, then deleted or anonymised.
7. Security
We use appropriate technical and organisational measures to protect personal data, including encrypted connections (HTTPS), access controls and confidentiality obligations for staff and providers. No online service is completely secure, so please take care when sending information to us. If we become aware of a personal data breach that is likely to result in a risk to your rights, we will notify you and the ICO as required by law.
8. Your rights
Under UK data protection law you have the right to:
- be informed about how we use your data (this policy);
- access a copy of the personal data we hold about you;
- rectify inaccurate or incomplete data;
- erase your data in certain circumstances;
- restrict our use of your data in certain circumstances;
- data portability for data you provided to us, where we process it by consent or contract;
- object to processing based on legitimate interests, and to direct marketing at any time; and
- withdraw consent at any time where we rely on it, without affecting earlier processing.
To exercise a right, email info@frontierbotanics.com. We may need to verify your identity and will normally respond within one month. There is usually no fee.
9. Cookies and similar technologies
We use minimal browser storage. Details, including how to change your choices at any time, are in our Cookie Policy.
10. Third-party content and links
Our site may embed a video from YouTube. To protect your privacy, the video loads only when you press play, using YouTube’s privacy-enhanced mode. Once it loads, YouTube may set cookies and process data under its own policies. Our site also links to social networks and other sites we do not control; please read their privacy notices before sharing data with them.
11. Children
Our website and investment information are intended for adults. We do not knowingly collect personal data from anyone under 18.
12. Complaints
If you have a concern, please contact us first so we can try to put it right. You also have the right to complain to the UK Information Commissioner’s Office (ICO): ico.org.uk/make-a-complaint, telephone 0303 123 1113.
13. Changes to this policy
We may update this policy from time to time. The “last updated” date at the top shows when it last changed. If we make significant changes, we will take reasonable steps to let you know.