This Privacy Notice explains how Whitlow Consultancy and its affiliates (“Whitlow”, “we”) collect and use personal information from visitors and applicants to our website and landing pages.
1. Notice at collection
We collect the categories of personal information listed below for the purposes described. We do not sell or share personal information for cross-context behavioural advertising. If that changes, we will update this notice and provide the right to opt out.
Categories we collect
● Identifiers and contact details – name, email, phone, postal address, date of birth
● Government ID and verification data – passport, driver’s licence, proof of address, selfie or liveness check, and, where strictly necessary, Social Security Number
● Background and screening data – sanctions and PEP screening, credit check results, directorship and insolvency history, and, where permitted by law, limited information about criminal convictions and offences
● Professional information – employment history, CV, references
● Internet or device information – IP address, browser and device data, cookie identifiers
● Financial information – bank details to pay fees or expenses, if applicable
● Communications – messages and documents you send us
Purposes of use
● Identity verification, due diligence and onboarding
● Background, sanctions and credit screening
● Communicating with you about your application and our services
● Detecting, preventing and investigating fraud, security incidents and illegal activity
● Website operation, diagnostics and analytics (only with your consent for non-essential cookies)
● Record keeping and compliance with the law
We retain KYC and due diligence records for a minimum of five years following the end of our relationship, unless required by law to do so. Other records are retained as long as needed for legal, accounting or operational purposes.
2. Sources
We collect personal information directly from you, from service providers that perform identity and background checks, and from public sources.
3. Disclosure of personal information
We disclose personal information to:
● Identity verification and background check providers
● Cloud hosting, email, CRM and helpdesk providers
● Professional advisers such as lawyers and accountants
● Regulators and law enforcement where required
● Group companies and service partners involved in your onboarding
We do not sell personal information. We do not share your personal information for cross-context behavioral advertising.
4. Sensitive personal information
We may collect sensitive personal information, such as government IDs or Social Security Numbers, only where strictly necessary for identity verification and screening purposes. We do not use sensitive personal information to infer characteristics about you.
5. Your privacy rights by state
Depending on where you live, you may have rights to access, correct, delete and obtain a copy of your personal information, to opt out of targeted advertising, the sale or sharing of personal information, and profiling for significant decisions, and to appeal our decision on your request. You can exercise your rights by emailing privacy@whitlowconsultancy.com or using any web forms we provide. We will verify your identity before responding to your request. You can also use an authorised agent where state law allows.
Opt out signals
Where required by law, we recognise browser-based opt-out preference signals such as Global Privacy Control for applicable opt-outs, for example, in Colorado and
Connecticut. If we ever sell or share personal information in California, we will also treat a valid browser signal as an opt-out of the sharing of that information.
6. Cookies and analytics
We use essential cookies to ensure the proper operation of our site. We will ask for your consent before setting analytics cookies. You can manage your preferences via our cookie banner or your browser settings.
7. Children
Our services are not intended for individuals under 21, and we do not knowingly collect personal information from them.
8. Security and international transfers
We use reasonable technical and organisational safeguards. We may transfer personal information to countries outside your state or country of residence, including to the United Kingdom and the European Union. When we do, we use legally recognised transfer safeguards where required.
9. Contact and complaints
If you have questions or would like to exercise your rights, contact us at privacy@whitlowconsultancy.com. If you believe we have not resolved your concern, you may have the right to complain to your state attorney general or privacy regulator.
10. Updates
We may update this notice. We will post any changes here and indicate the date of the latest revision.
Last updated: 9 August 2025