Privacy notice for officers, shareholders and option-holders
Version
This Privacy Policy was last updated 29 December 2025.
Who is this notice for?
his privacy notice is for individual officers, shareholders and option-holders of companies within the Enate group of companies, and for individuals who are representatives of corporate officers, shareholders and option-holders:
- Enate Limited a company registered in England and Wales with company number 4077681 with its registered office at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
- Enate Technologies India Pvt Limited, a company registered in Karnataka with company number U72200KA2013FTC072544 with its registered office at WeWork Galaxy, 43, Residency Road, Bangalore560025, India
- Enate Group Limited a company registered in England and Wales with company number 16378901 with its registered office at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
- Enate Nominees Limited a company registered in England and Wales with company number 16378893 with its registered office at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
This privacy policy is maintained by Enate Limited. Insofar as the administration of each of the above companies is performed by employees of Enate Limited on behalf of the other entities, references to ‘Enate’ in the context of the entity processing your personal data mean Enate Limited. However, the context of the processing of your personal data will depend on your personal circumstances and may include more than one of the companies listed.
In this policy:
‘Officers’ means all individuals who are statutory office holders (usually, directors) in one of more of the Enate entities listed above, or who are individuals who represent a corporate office holder;
‘Investors’ means all individuals who have a shareholding or a share option holding (or both) in one of more of the Enate entities listed above, or who are individuals who represent a corporate shareholder or option-holder.
Background
This privacy notice tells you what to expect when Enate collects personal information about you.
Because this notice is mostly influenced by UK and EU data privacy laws, some of the content refers to specific legislation that might not be relevant in your jurisdiction (even though we implement it uniformly across all our operations). This means you might not be familiar with some of the content, but it also means you get additional protection that might not otherwise be relevant in your jurisdiction.
Data Controller
Enate Limited is the controller in respect of personal data processed about officers and shareholders of Enate Limited. Enate Limited is a processor acting on behalf of the companies listed above (who are the data controllers) when processing data about officers, shareholders or option-holders of those companies.
Enate has 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:
Email address:dpo@enate.net
Postal address: 167-169, Great Portland Street, 5th Floor, London, W1W 5PF.
If you are in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
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.
The Data We Collect About You
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).
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, title.
- Representative data includes your relationship to a corporate officer or investor.
- Contact Data includes your address, email address and telephone numbers.
- Investor data includes details of your ownership of shares in Enate companies or your interest in share options in Enate companies.
- Appointments data includes details of your appointment as an officer of any Enate companies.
- Contracts data includes copies of contracts between you and one or more Enate companies insofar as they pertain to your status as an officer, shareholder or option-holder.
We might also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
How is your personal data collected
We collect data from and about you when you may give us your identity and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you became an officer or investor.
How we use your personal data
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:
- Where we need to perform the contract we are about to enter into or have entered into with you. Performance of 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.
- 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. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to engage with our officers and investors. 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.
- Where we need to comply with a legal obligation. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. This typically includes our obligations to maintain records for governmental bodies who oversee regulation of companies, and for taxation.
Purposes for which we will use your personal data
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.
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.
* Enate is often asked to disclose details of officers and shareholders, but not option-holders. Typically, such requests are limited to shareholding above a specified level, which usually significantly restricts the number of individuals we need to name. We do not provide contact details of investors to customers.
Marketing
We do not use your personal data for marketing Enate or any third party products or services.
Change of purpose
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.
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.
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.
Disclosure of your personal data
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.
Your data is stored and processed using the services of the following third parties:
International Transfers
We do not transfer your personal data outside the UK except:
- One of the Enate companies is incorporated in India and official records for that company are therefore filed in India.
- Some customer due diligence requests may originate from organisations outside the UK and the EEA.
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 instruction 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.
Data retention
How long will you use my personal data for?
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 your legal rights below for further information.
In some circumstances we will 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Even if your jurisdiction does not grant such rights, Enate policy is to apply the same principles globally.
You have the right to:
- 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.
- 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.
- 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.
- 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.
- 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:
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- 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.
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer using the details above.
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.
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.