Legal
Privacy Notice
Last updated: September 2026
This privacy notice (“Privacy Notice”) applies to all personal information processing activities carried out by Low Observable Technology Ltd and (where relevant) all entities within the LO:TECH Group (“LO:TECH”, “LO:TECH Group” “we,” “us,” “our”). It is to be read in conjunction with our Regulatory and Legal Notice, Terms and standalone Cookie Notice.
LO:TECH’s data protection contact is Tim Meggs, Data Protection Lead. Email: dataprotection@lo.tech Postal address: 101 New Cavendish Street, 1st Floor South, London, United Kingdom, W1W 6XH
LO:TECH is a data controller with regard to the personal data that we process in the course of carrying out our business (including the products and services that we provide). LO:TECH is committed to protecting your privacy and complying with your choices, and processes data in accordance with its responsibilities under the UK General Data Protection Regulation and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025 (together, the “UK GDPR”). Both personal and non-personal information collected is safeguarded according to the privacy and data protection standards adopted worldwide.
This Privacy Notice outlines how we collect and use personal data in the course of carrying out our business, including providing services to, and conducting business with, counterparties, and data relating to a counterparty’s employees, officers or other associated individuals. “Personal data” is any information relating to an identified or identifiable living person.
We may update this Privacy Notice from time to time. When we do, we will communicate any material changes to you and make the updated Privacy Notice available.
Data we process
In providing our services, we collect, use, store and otherwise process (“process”) various categories of personal data about you, or those you work with. We will limit the collection and use of your personal data to what is adequate, relevant and necessary for one or more legitimate purposes, as outlined in this notice. Personal data typically includes:
– Basic personal information, including name, address, and date of birth;
– Financial information, including occupation, bank account numbers, bank statements, financial assets, liabilities and trading information;
– Contact information, including email address and telephone number;
– Contract notes;
– Records of our discussions, including records of phone and video calls and messaging apps, such as Slack, WhatsApp and Telegram;
– Where you are, or are being considered as, a client or counterparty of our market making, market data, or (once live) OTC/Agency Execution services: identity verification, source-of-funds/source-of-wealth and other onboarding due diligence data, collected as part of our Know Your Customer, anti-money laundering and sanctions screening obligations.
– Enquiries submitted via our Contact page (your name, email address, company, and the content of your message); and the email address you provide when subscribing to our newsletter, The LO:DOWN.
We do not normally process special categories of personal data. Any processing of special categories of personal data will only take place once we’ve obtained your explicit consent or are otherwise lawfully permitted to do so.
Special categories of personal data include:
– Information about racial or ethnic origin;
– Religious or philosophical beliefs;
– Trade union membership;
– Physical or psychological health details or medical conditions; and
– Biometric information, relating to the physical, physiological or behavioural characteristics of a person.
Where permitted by law, LO:TECH may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with law relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions.
Tracking technologies and Cookies
We use Cookies and similar tracking technologies to track activity on our Site and store certain information. Tracking technologies used are beacons, tags and scripts, used to collect and track information and to improve and analyse our Site.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Site.
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your device after you go offline, while Session Cookies are deleted as soon as you close your web browser.
We use both session and persistent Cookies, across the following categories: Essential Session Cookies, Notice Acceptance Cookies, Functionality Cookies, and Tracking and Performance Cookies (administered by third parties). Further detail on each category, the specific Cookies within it, and how to manage your preferences category-by-category, is set out in our separate Cookie Notice.
We are currently updating the consent mechanism on our Site so that non-essential Cookie categories can be accepted or rejected individually, rather than as a single all-or-nothing choice; see our Cookie Notice for full detail as this rolls out.
How we obtain data
Your data is made up of all the personal data we collect and hold about you. It includes:
– Data you give to us;
– Data that we receive from third parties; and
– Data that we gather from publicly available sources, such as company websites and online search engines, social media and professional profile and networking platforms such as LinkedIn.
How we use your data
We use this information for carefully considered purposes which also benefit our customers, including but not restricted to:
– providing and facilitating our services and products;
– communicating with you;
– providing you with news, updates, promotions, offers and information relating to products, events and/or services provided by LO:TECH or any of its group companies or other connected parties that may be of interest to you;
– to provide support for our services and products;
– to create a “lookalike audience” or “matched audience” of (prospective) customers for targeted advertising on social media platforms;
– identifying and directly contacting potential clients and counterparties through professional social media and networking platforms (including LinkedIn), using your publicly available name, job title, employer and other professional profile information (where published);
– analysing use of our Site, measuring ad impressions, and protecting the interests, rights, safety or property of LO:TECH or any of its group companies or others, and monitoring compliance with and enforcing the terms of any agreement with LO:TECH or any of the LO:TECH Group companies or others;
– monitoring to detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, and holding those responsible for that activity;
– onboarding, verifying and conducting due diligence on prospective clients and counterparties to our market making, market data and (once live) OTC/agency execution services, including identity verification, AML/CFT and sanctions screening, and, where applicable, transaction monitoring, in connection with the regulatory obligations of companies within the Low Observable Group and
– responding to enquiries submitted via our Contact page, and sending you The LO:DOWN, our newsletter, where you have subscribed to receive it.
The lawful bases we rely on for the purposes set out above are: our legitimate interests, in providing and improving our products, services and this Site, and in communicating with and about our business; your consent, for non-essential Cookies and for any marketing communications you opt in to; and, for onboarding, AML/CFT, sanctions screening and related regulatory engagement, our legal obligations together with our legitimate interests.
If you want to opt out of receiving offers, updates, promotional and marketing emails, event invitations, text messages, posts and other forms of communication from us (or our promotional partners), you can always click “unsubscribe” at the bottom of an email we send you. If you’d prefer not to be contacted by us via LinkedIn or other social media, simply let us know and we will stop and note your preference.
Your rights
Access
You have a right to get access to the personal data we hold about you. Please submit a request at dataprotection@lo.tech.
Rectification
If you believe any of the data we hold about you is inaccurate, you have the right to request that we limit the use of that data and to rectify the inaccurate personal data.
Erasure
You have a right to request the deletion or removal of your personal data, and subject to the relevant law or regulation, we have to comply with that request where:
– we no longer need to use your personal data for the purposes for which it was originally collected;
– we have requested your consent to use your personal data and you wish to withdraw that consent; or
– we are not using your information in a lawful manner.
Restriction
You may request us to restrict the use of your personal data if you believe that:
– any of your personal data is inaccurate, for a period enabling us to verify its accuracy;
– we no longer need your personal data for the purposes for which it was provided, but you require the information to establish, exercise or defend a legal claim; or
– you have objected to us using your data, pending verification of whether our legitimate grounds override your rights.
Portability
Where we have requested your consent to use your personal data, or you have provided us with data for the purposes of entering into a contract with us, you have a right to receive the personal data you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your personal data, which will be governed by their agreement with you and any privacy statement they provide to you.
Objection
In certain circumstances, you have a right to object to the processing of your personal data, and to request that we limit its use, unless we can evidence legitimate grounds for the use which override your own interests, or we need to process your information to investigate and protect us or others from legal claims or regulatory responsibilities.
Withdrawal of consent
Where we rely on your consent to process your personal data, you have a right to withdraw that consent at any time. We will always make it clear where we require your consent to carry out specific uses of your personal data. There may be legal, regulatory or other reasons why we would need to keep using your personal data, and LO:TECH will inform you of those reasons if applicable.
Automated decision-making and profiling
Where our onboarding process uses automated AML or sanctions screening, a member of our compliance team reviews any potential match before a decision is made about you; you may contact us using the details in this Privacy Notice to query or request human review of any such decision.
Submit complaints
Should you wish to exercise any of these rights, have any questions about how we use your personal data, or would like to make a complaint, please contact us at dataprotection@lo.tech. If it is a complaint, the Data Protection Lead/or a suitable designated senior manager will investigate the matter. We will endeavour to acknowledge your complaint within 30 days and respond to it without undue delay. You can also contact the Information Commissioner’s Office (ICO) at ico.org.uk. LO:TECH is not registered with the FCA.
In some circumstances, if you do not agree to the way we use your data, we may no longer be able to provide certain products and/or services to you.
Sharing data with third parties
LO:TECH may share your personal data:
– with regulatory bodies, government agencies and law firms, where required;
– with auditors, accountants, regulatory bodies, judicial bodies, government entities and tax authorities;
– with other companies within the Low Observable Group (including Low Observable Technology (BVI) Limited), which provide shared trading, compliance and technology infrastructure to LO:TECH under intercompany arrangements including any outsourced service providers of those such entities;
– with selected third-party providers providing services to us, such as corporate and natural person director appointments, anti-money laundering screening, onboarding due diligence or transaction monitoring services; and/or
– with selected third-party contractors or service providers that may process your personal data for us, such as marketing agencies and event co-sponsors,
in each case where it is permitted by law, necessary for our legitimate interests or those of a third party, and not inconsistent with the purposes listed above.
We do not sell your personal data. If we sell, transfer or restructure parts of our business, your data may transfer to the new owner on the same terms as this Notice.
Transferring information overseas
LO:TECH may transfer your data to organisations in other countries outside of the UK and/or European Economic Area (“EEA”) on the basis that anyone to whom we pass it protects it in the same way we would, and in accordance with applicable laws. In particular, because the LO:TECH Group includes Low Observable Technology (BVI) Limited, personal data relating to client and counterparty due diligence may be transferred to and processed in the British Virgin Islands, on the basis of the safeguards described below.
LO:TECH may also store your personal data via third party web-based applications, cloud services, or web-based storage providers, some of whom may be based outside of the EEA.
Where your personal data is sent outside the UK and/or EEA, and the transfer is not necessary for the performance of a contract or a legal or regulatory process, LO:TECH will ensure that at least one of the following is in place:
– the UK government or the European Commission has decided that the country or organisation we are sharing your information with protects it adequately;
– the transfer has been authorised by the Information Commissioner’s Office;
– we have entered into a contract with the organisation to ensure your information is adequately protected;
– the transfer is required to meet our contractual or pre-contractual obligations with you, or to complete a contract with a third party in your interest;
– the transfer is a matter of important public interest or is necessary for the establishment, exercise or defence of legal claims;
– we are protecting your vital interests; and/or
– where none of the above apply, we have obtained your explicit consent after informing you of the possible risks in the absence of an adequacy decision and appropriate safeguards.
Retention
In the course of our relationship with you, we create and store records of your personal data on a variety of media (physical or electronic) and formats. We maintain these records to carry on our business effectively and to comply with legal and regulatory requirements. Retention periods are determined by the type of record and the applicable legal or regulatory requirements.
LO:TECH usually keeps your data for up to six years following the termination of all agreements between LO:TECH and the counterparty, unless:
– we are required to retain the data for longer to comply with a legal or regulatory obligation; or
– it is impractical, for technical or operational reasons, to delete the data (for example, data written to offline back-up storage) in which case LO:TECH reserves the right to retain that back-up data indefinitely.
Changes to this notice
If we make changes to this Privacy Notice, we will post the changes here so that you are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If we decide to use your information in a manner materially different from that stated at the time it was collected, we will notify you by email.
Questions or comments
If you have questions or comments about this Privacy Notice, your rights to access your personal data, or any concerns about how your data is processed, please email us at dataprotection@lo.tech.