Tailwind Privacy Policy

Tailwind Entertainment Limited, Tailwind Music Fund Limited and Tailwind Music Trading Limited care about the privacy of your personal information. This Privacy Policy explains what information Tailwind collects about you, why, what we do with that information and how we handle that information.

Tailwind entities are classified as data controllers under the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), implemented in the UK through the Data Protection Act 2018; in Guernsey through the Data Protection (Bailiwick of Guernsey) Law, 2017; and in Ireland through the Data Protection Act 2018.

  • Tailwind Entertainment Limited is registered with the Information Commissioners Office (ICO) in the UK, registration number ZA751023.
  • Tailwind Music Fund Limited is registered with the Data Protection Authority in Guernsey, registration number 63912.
  • Tailwind Music Trading Limited is not required to register the organisation or a Data Protection Officer with the Data Protection Commission in Ireland.

All staff are required to read, understand, and accept the Privacy Policy and the procedures that relate to personal data that they may handle.

How we collect information about you

How we collect information about you: Tailwind may collect Personal Information about you, such as your email address, name, physical address, telephone number or employment information. This information may be collected:

  • directly from you or from another person on your behalf;
  • in relation to a transaction between Tailwind and you;
  • from our Administrator or Sub-Administrator in relation to investor KYC and AML requirements;
  • from third parties, including service providers, credit reference and background check agencies or relevant legal and regulatory authorities; or
  • if you make contact through our website contact page.
Please note that any information that you provide to Tailwind through our website contact page will be used solely for communication with you and will not be shared with third parties.

Why we collect information about you and how we use your data

We will only collect and process your personal data when permitted by law. Generally, we will process your personal data where it is necessary for our legitimate interests, for example, we may collect and use your personal information:

  • in the ordinary course of managing and administering the relationship between us;
  • to market our products and services to you or your business;
  • to fulfil our regulatory and legal obligations as it relates to anti-money laundering, fraud prevention, “know your client” checks and other due diligence processes;
  • to analyse potential investment opportunities; or
  • to manage risks to which our business is exposed
The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes. A refusal to provide us with personal information may result in us not being able to communicate with you, not being able to complete a transaction with you, potential termination of services or contractual arrangements between us, or, where we have a reasonable suspicion of illegal activity, we may be required to report to regulatory or enforcement agencies.

Information shared with third parties

Tailwind will not disclose your personal information to any third party, except as permitted by law, or as necessary to provide services to you or execute a transaction with you, such as:

  • our affiliates or entities that are part of our group;
  • regulators, courts of law, governmental, regulatory or law enforcement agencies, when we have an obligation to do so;
  • certain third parties and service providers used in the course of our business such as payroll administrators, employee benefits providers, legal advisers, placement agents or distributors and administrators of our funds;
  • credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty or investment due diligence;
  • any person as directed by you; or
  • third parties involved in the due diligence of an investment opportunity such as legal counsel, or accountants, where permitted via a non-disclosure agreement.

Transfers of personal data outside of the EEA

Due to the international nature of Tailwind’s business, personal data may be transferred to countries outside of the EEA, such as jurisdictions where we conduct business or engage with a third-party service provider. In some cases, these territories may not have the same level of data protection as that afforded by the EU GDPR and other data protection rules applicable to Tailwind. In these circumstances, Tailwind will take steps to seek to ensure that the recipient keeps your information confidential and that it is held securely in accordance with standards we maintain in the UK, Guernsey and Ireland.

Data storage and retention

Tailwind securely stores your data electronically. The retention period for your personal information will be determined by various criteria, including the purposes for which we are processing your personal information as well as legal and regulatory obligations. Tailwind reviews data held on an annual basis.

What are your data protection rights?

Tailwind would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

  1. The right to access – you have the right to request that Tailwind provides to you copies of your personal data which is being processed.
  2. The right to rectification – you have the right to request that Tailwind corrects any information you believe is inaccurate. You also have the right to request that Tailwind completes information you believe is incomplete. The right to rectification is restricted in certain circumstances under Section 60 of the Data Protection Act 2018.
  3. The right to be informed – you have a right to know how personal data concerning you is collected, used, shared or otherwise processed.
  4. The right to erasure – you have the right to request that Tailwind erases your personal data without undue delay, subject to certain conditions.
  5. The right to restrict processing – you have the right to request that Tailwind restricts the processing of your personal data, under certain conditions. Where Tailwind proposes to lift a restriction, you have a right to be informed that the restriction will be lifted.
  6. The right to object to processing – you have the right to object to Tailwind’s processing of your personal data, under certain conditions.
  7. The right to data portability – you have the right to request that Tailwind transfers the data that we have collected to another organisation, or directly to you, under certain conditions.
  8. The right not to be subject to automated processing – you have right not to be subject to automated processing and profiling.

Use of Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. Tailwind uses cookies in a range of ways to improve your experience on our website. The Tailwind Cookie Policy can be found here: https://www.tailwindentertainment.com/cookies

Changes to our privacy policy

Tailwind keeps its privacy policy under regular review and places any updates on this webpage. This privacy policy was last updated on 22nd September 2020.

How to contact us

If you have any questions about our Privacy Policy, the data we hold on you, or if you wish to exercise one of your data protection rights, please do not hesitate to contact us through our website.

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Tailwind has not addressed your concern in a satisfactory manner, you may contact the following authorities: