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 describes your rights under applicable data-protection law.
By accessing or using the Website, you acknowledge that you have read and understood this Policy. If you do not agree with its terms, please discontinue use of the Website.
If you are an investor in a Margaux Platforms special purpose vehicle (SPV), please refer to the separate privacy notice made available through the relevant investor portal, which governs the processing of your personal data in that context.
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 collected through this Website and comply with applicable data-protection law in the United Kingdom, including the UK General Data Protection Regulation, the Data Protection Act 2018 and related legislation.
To the extent that Astor processes personal data of individuals located in the European Economic Area, such processing is also carried out in accordance with the EU General Data Protection Regulation (EU 2016/679). Where required, Astor may appoint an EU representative for that purpose.
For any questions or requests regarding this Policy or your personal data, please contact us at enquiries@astor.network.
INFORMATION WE COLLECT
We collect limited personal data that you choose to provide via our online form, typically including your:
We obtain this information directly from you when you complete the online form. We do not collect personal data about you from other sources.
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:
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. Withdrawal does not affect the lawfulness of processing carried out before consent is withdrawn.
Where processing relies on legitimate interests, we conduct balancing assessments to ensure that those interests are not overridden by your rights and freedoms. You may request further information on these assessments at any time.
COOKIES AND TRACKING TECHNOLOGIES
The Website uses cookies and similar technologies to ensure that it functions securely and reliably. These include strictly necessary cookies which enable core features such as page navigation, session management and secure form submission. These cookies are essential to the operation of the Website and do not track users across other websites or collect analytics data.
If we introduce additional categories of cookies in the future—such as analytics or performance cookies—we will update this section accordingly and display an updated banner or settings panel to obtain your consent where required by law.
MANAGING COOKIES
You can adjust your browser settings to block or delete cookies if you prefer. Most browsers automatically accept cookies, but you can usually modify your settings to decline them. Please note that disabling essential cookies may affect how the Website functions.
We periodically review the cookies and similar technologies used on this Website to ensure that they remain appropriate and proportionate. Further information is available through the cookie banner on our Website.
SHARING OF PERSONAL DATA
We only share personal data where necessary and always in accordance with applicable data-protection law.
We may disclose personal data:
We do not sell or rent personal data and we require anyone who handles it on our behalf to do so securely and lawfully. All third parties with whom we share personal data are required to handle it in accordance with our written instructions and applicable law.
Our Website is hosted on servers located in the United Kingdom. We use reputable UK-based service providers to maintain the Website and process enquiries, each of whom acts as our data processor under a written contract.
We do not transfer personal data outside the United Kingdom. Should this change, we will ensure that any transfer is made subject to appropriate safeguards in accordance with applicable 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. As a general principle, we keep personal data only for as long as it is needed for the purposes for which it was collected 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.
Our approach to information security and operational resilience is guided by applicable regulatory expectations for financial-services firms.
While no online system can be entirely secure, we continually review and update our security measures to reflect appropriate industry standards and regulatory expectations.
In the unlikely 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:
You also have the right not to be subject to decisions based solely on automated processing.
To exercise any of these rights, please contact us at enquiries@astor.network.
If you are dissatisfied with how we handle your personal data, you may lodge a complaint with the Information Commissioner’s Office at https://ico.org.uk/.
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
Email: enquiries@astor.network
We aim to respond to all legitimate requests within one month.
SCOPE OF THIS POLICY
This Policy applies solely to personal data collected through the Website. It does not apply to data processed in connection with Astor’s fund structures or investment vehicles, which are governed by separate privacy notices.