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.
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.
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
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:
- The right to access – you have the right to request that Tailwind provides to you copies of your personal data which is being processed.
- 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.
- The right to be informed – you have a right to know how personal data concerning you is collected, used, shared or otherwise processed.
- The right to erasure – you have the right to request that Tailwind erases your personal data without undue delay, subject to certain conditions.
- 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.
- The right to object to processing – you have the right to object to Tailwind’s processing of your personal data, under certain conditions.
- 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.
- The right not to be subject to automated processing – you have right not to be subject to automated processing and profiling.
How to contact us
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: