Privacy Policy

Astor HoldCo Limited (“Astor”, “we”, “us” or “our”) values your privacy. Astor operates as a powered land and data centre development platform, and this Privacy Policy (“Policy”) explains how we collect, use and protect personal data in connection with your use of www.astor.network (the “Website”) and your other interactions with Astor, and describes your rights under applicable data-protection law.

By accessing or using the Website, or otherwise providing personal data to us, you acknowledge that you have read and understood this Policy.

WHO WE ARE

Astor HoldCo Limited is incorporated in England and Wales (Company No. 17085621) with its registered office at 84 Brook Street, London, W1K 5EH.

We act as the controller in respect of personal data processed for the purposes described in this Policy. Applicable data-protection laws include the UK General Data Protection Regulation (the “UK GDPR”), as amended by the Data (Use and Access) Act 2025, the Data Protection Act 2018 and related legislation.

To the extent that Astor processes personal data in circumstances where the EU General Data Protection Regulation (EU 2016/679) (the “EU GDPR”) applies, such processing is also subject to the EU GDPR.

For any questions or requests regarding this Policy or your personal data, please contact us at enquiries@astor.network.

INFORMATION WE COLLECT

We collect and process personal data in connection with the Website and our interactions with Website visitors, prospective investors, tenants and prospective tenants, job applicants and other individuals who contact or engage with Astor.

Depending on how you interact with us, this may include:

  • your full name;
  • your email address;
  • your telephone number;
  • your job title and organisation;
  • information that you include in an enquiry, message or other correspondence with us;
  • information provided in connection with investor, tenant or other business enquiries;
  • where you apply for a role with Astor, information relating to your application, including your CV, employment history, qualifications and other information that you provide as part of the recruitment process; and
  • information about your use of the Website collected through cookies and similar technologies, as described below.

We obtain this information directly from you when you complete an online form, correspond or otherwise interact with us, or apply for a role with Astor.

We do not collect more personal data than is necessary for these purposes.

HOW WE USE PERSONAL DATA

We process personal data only where a lawful basis applies under data-protection law. These bases, and how they apply to our activities, are set out below:

  • Website and general enquiries. We use personal data to receive, review and respond to enquiries submitted through the Website, by email or otherwise. We do this where necessary for our legitimate interests in communicating with individuals who contact Astor and managing our business relationships.
  • Newsletters and updates. Where you sign up to receive Astor updates, we use your email address to send those updates to you. We do this with your consent. You can unsubscribe at any time using the unsubscribe link in any email or by contacting us at enquiries@astor.network.
  • Investor enquiries. We use personal data to respond to prospective investor enquiries, provide information concerning Astor and its activities and manage prospective investor relationships. We do this where necessary for our legitimate interests in operating, financing and developing Astor’s business and, where relevant, to take steps at an individual’s request before entering into a contract.
  • Tenant and other commercial enquiries. We use personal data to respond to tenant, prospective tenant and other commercial enquiries and manage existing or prospective business relationships. We do this where necessary for our legitimate interests in developing and operating Astor’s business and, where relevant, to take steps at an individual’s request before entering into a contract.
  • Recruitment. We use personal data to receive and assess applications, communicate with job applicants and administer recruitment processes. We do this where necessary to take steps at an individual’s request before entering into an employment contract and, where applicable, for our legitimate interests in recruiting personnel.
  • Business administration and corporate transactions. We may use personal data in connection with the administration of Astor’s business and actual or proposed financings, investments, reorganisations or other corporate transactions. We do this where necessary for our legitimate interests in managing, financing and developing Astor’s business.
  • Legal and regulatory compliance. We use personal data where necessary to comply with applicable legal and regulatory requirements and respond to lawful requests from regulators, law-enforcement agencies and other public authorities.
  • Website operation, security and improvement. We use personal data to operate, secure and improve the Website and understand how it is used, including through cookies and similar technologies as described below. The applicable legal basis depends on the particular technology and the purpose for which it is used.

We do not make decisions about you based solely on automated processing or profiling.

Where processing is based on consent, you may withdraw that consent at any time by contacting us using the details above or, in the case of cookies, through the “Manage Preferences” control described below. Withdrawal does not affect the lawfulness of processing carried out before consent is withdrawn.

Where processing relies on legitimate interests, we will only process personal data where those interests are not overridden by your interests, rights and freedoms.

COOKIES AND TRACKING TECHNOLOGIES

The Website uses cookies and similar technologies to support its operation, remember user preferences and help us understand how the Website is used.

Cookies are small text files stored on your device when you visit a website. Similar technologies may also store information on, or access information from, your device.

STRICTLY NECESSARY COOKIES

We use cookies and similar technologies that are necessary for the secure and reliable operation of the Website. These may include technologies used for security, session management, page navigation and secure form submission. These technologies do not require your consent.

ADDITIONAL COOKIES AND SIMILAR TECHNOLOGIES

The Website may also use analytics, functional and other cookies and similar technologies. Where consent is required, these technologies will not be used unless and until you provide that consent.

The additional cookies and similar technologies used on the Website are set out below:

ANALYTICS

We use Google Analytics cookies _ga and _ga_*, which last for 2 years. The first distinguishes users and measures how visitors interact with the website; the second maintains session information and measures user engagement.

FUNCTIONAL

We use MailerLite cookies (mailerlite:webform:shown, mailerlite:session_id, mailerlite:forms:submitted:[form ID]) to operate embedded or pop-up sign-up forms, including remembering whether a form has been shown or submitted. These last for the duration of the session, or for the period configured in the relevant form's display settings.

MANAGING YOUR COOKIE CHOICES

When you first visit the Website, we provide information about our use of cookies and similar technologies and, where consent is required, give you the option to accept or reject those technologies or manage your individual choices.

Cookies and similar technologies for which consent is required will remain disabled unless and until you provide the relevant consent. Categories requiring consent will not be enabled by default.

You can review or change your choices at any time using the “Manage Preferences” control available on the Website, including by withdrawing consent previously given.

You can also adjust your browser settings to block or delete cookies. Please note that disabling strictly necessary cookies may affect how the Website functions.

We may update this section where the cookies and similar technologies used on the Website change.

SHARING OF PERSONAL DATA

We only share personal data where necessary and in accordance with applicable data-protection law.

We may disclose personal data:

  • to service providers that support the operation and maintenance of the Website and Astor’s business systems;
  • to professional advisers such as lawyers, accountants and auditors who are subject to confidentiality obligations;
  • to prospective or actual investors, lenders, business partners, purchasers or successor entities where reasonably necessary in connection with a financing, investment, corporate transaction or other business relationship concerning Astor, subject to appropriate safeguards;
  • to regulators, law-enforcement agencies or authorities where required by law; or
  • to others where you have given consent or we otherwise have a lawful basis to do so.

We do not sell or rent personal data. Where a service provider processes personal data on our behalf, we require it to process that information in accordance with our instructions and applicable data-protection law.

INTERNATIONAL TRANSFERS

We use service providers located in the United Kingdom and other countries, including the United States, to host and maintain the Website, process enquiries and otherwise support our operations. These include providers of website hosting, form submission, email and analytics services.

Where personal data is transferred outside the United Kingdom to a country that is not covered by applicable UK adequacy regulations, we will ensure that an appropriate safeguard or other lawful transfer mechanism is used where required by applicable data-protection law.

DATA RETENTION

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy or to comply with our legal obligations.

SECURITY OF PERSONAL DATA

We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure or destruction. These measures include encrypted communications, restricted access controls and secure hosting arrangements.

Access to personal data is limited to personnel who need it to perform their roles and who are subject to confidentiality obligations.

In the event of a personal-data breach, we will notify affected individuals and the Information Commissioner’s Office where required by law.

YOUR RIGHTS

You have a number of rights under UK data-protection law, subject to certain conditions and exemptions. These include the rights to:

  • access the personal data we hold about you;
  • rectify inaccurate or incomplete information;
  • erase personal data where there is no lawful basis for us to retain it;
  • restrict our use of your personal data in certain circumstances;
  • object to processing based on our legitimate interests;
  • receive your personal data in a structured, commonly used electronic format and transmit it to another controller (“data portability”); and
  • withdraw consent at any time, where processing is based on consent.

To exercise any of these rights, please contact us at enquiries@astor.network.
If you have a concern about how we use your personal data, please contact us using the details below so that we can consider your concern. You also have the right to lodge a complaint with the Information Commissioner’s Office.

CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect changes in law, regulation or our data-processing practices. Any updates will be published on this page with an updated “Last updated” date. We encourage you to review this Policy periodically.

CONTACT AND FURTHER INFORMATION

For any queries, requests or complaints regarding this Policy or our data practices, please contact:

DATA PROTECTION CONTACT

Astor HoldCo Limited
84 Brook Street
London W1K 5EH
United Kingdom
Email: enquiries@astor.network

We will respond to requests in accordance with the timeframes required by applicable data-protection law.

SCOPE OF THIS POLICY

This Policy applies to personal data processed in connection with the Website and Astor’s interactions with Website visitors, prospective investors, tenants and prospective tenants, job applicants and other individuals who contact or engage with Astor.

We use some essential cookies to make this website work. We’d also like to use additional cookies so we can remember your settings, understand how people use the website and make improvements.