Privacy Policy

1. Who We Are

Data Controller: Frontier Diagnostics Ltd
Company Number: 14416890
Registered in: England & Wales
Registered Address: First Floor, 690 Great West Road, Osterley Village, Isleworth, England, TW7 4PU
Contact: [email protected]

As the data controller, we are responsible for deciding how and why your personal data is processed.

2. What Personal Data We Collect

When you submit an investor factsheet request through our website, we collect the following personal data:

• First name and last name
• Email address
• Telephone number
• Indicative investment amount (selected from a range)
• Confirmation of investor status (High Net Worth Individual or Sophisticated Investor)
• Technical data: IP address, browser user agent, referring URL, and submission timestamp

We do not collect any special category data (such as health information, political opinions or biometric data) through this website.

3. How We Use Your Personal Data

We use the personal data you provide for the following purposes:

3.1 Delivering the Investor Factsheet

To send you the Frontier Diagnostics Investor Factsheet to the email address you provided. This is the primary purpose for which your data is collected.

3.2 Investor Relations Communications

To contact you regarding the investment opportunity, answer questions you may have, and provide updates relevant to the fundraising process.

3.3 Investor Eligibility Verification

To verify that you have confirmed your status as a qualifying investor (High Net Worth Individual or Self-Certified Sophisticated Investor) as required under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005.

3.4 Record-Keeping and Compliance

To maintain records of investor enquiries for regulatory and compliance purposes, including demonstrating that financial promotions were directed only at qualifying investors.

4. Legal Basis for Processing

We process your personal data on the following legal bases under UK GDPR:

• Legitimate interests (Article 6(1)(f)) - to manage investor relations, respond to your enquiry, and deliver the factsheet you requested. Our legitimate interests do not override your rights and freedoms.
• Legal obligation (Article 6(1)(c)) - to comply with applicable financial promotion regulations and maintain required records.
• Consent (Article 6(1)(a)) - where you have explicitly confirmed your investor status and agreed to receive the factsheet and related communications.

5. How We Store Your Data

Your personal data is stored securely on servers located within the United Kingdom and/or the European Economic Area. Submission records are stored in an encrypted, access-controlled environment and are not accessible to the public.

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or alteration, including:

• Encrypted storage of submission records
• Access controls limiting data access to authorised personnel only
• Regular review of data handling practices

6. How Long We Retain Your Data

We retain your personal data for as long as is necessary for the purposes set out in this policy, or as required by applicable law. In practice:

• Investor enquiry records are retained for up to 6 years from the date of submission, in line with standard UK regulatory record-keeping requirements.
• If you request deletion of your data and there is no overriding legal obligation to retain it, we will delete your data within 30 days of your request.

7. Who We Share Your Data With

We do not sell, rent or trade your personal data to third parties. We may share your data with:

• Service providers acting as data processors on our behalf (e.g. hosting and infrastructure providers), who are contractually bound to process data only on our instructions and in accordance with UK GDPR.
• Professional advisers (e.g. legal or compliance advisers) where necessary for regulatory compliance.
• Regulatory authorities or law enforcement agencies where required by law.

Any third parties with whom we share data are required to maintain appropriate security measures and to use your data only for the purposes we specify.

8. International Data Transfers

We do not routinely transfer your personal data outside the United Kingdom. Where any transfer outside the UK is necessary, we will ensure that appropriate safeguards are in place in accordance with UK GDPR, such as the use of UK International Data Transfer Agreements (IDTAs) or equivalent mechanisms.

9. Your Rights Under UK GDPR

You have the following rights in relation to your personal data:

• Right of access - to request a copy of the personal data we hold about you.
• Right to rectification - to request correction of inaccurate or incomplete data.
• Right to erasure - to request deletion of your personal data where there is no legitimate reason for us to continue processing it.
• Right to restriction - to request that we restrict processing of your data in certain circumstances.
• Right to data portability - to receive your data in a structured, commonly used and machine-readable format.
• Right to object - to object to processing based on legitimate interests.
• Right to withdraw consent - where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one calendar month.

10. Right to Lodge a Complaint

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: ico.org.uk
Helpline: 0303 123 1113

11. Cookies and Tracking

Our investor landing page does not currently use tracking cookies, analytics cookies, or third-party advertising cookies. We may use strictly necessary session data to support the operation of the website. If we introduce cookies in the future, this policy will be updated accordingly and appropriate consent mechanisms will be implemented.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date at the top of this page indicates when the policy was last revised. We encourage you to review this policy periodically.

Continued use of our website following any update constitutes acceptance of the revised policy.

13. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

Frontier Diagnostics Ltd
First Floor, 690 Great West Road, Osterley Village, Isleworth, England, TW7 4PU
Email: [email protected]