DAO SPV Customer Privacy Notice

Registered name: DAO SPV is a trading name of Ballasquale Limited, a company registered in England & Wales under company number 15534483

This privacy notice tells you what to expect us to do with your personal information.

1. Contact details

1. Post: 3rd Floor, 207 Regent Street, , London, UK, W1B 3HH

2. Email: admin@daospv.com

2. What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details

• Addresses

• Gender

• Occupation

• Date of birth

• Payment details (including card or bank information for transfers and direct debits)

• Financial data (including income and expenditure)

• Transaction data (including details about payments to and from you and details of products and services you have purchased)

• Usage data (including information about how you interact with and use our website, products and services)

• Account access information

• Website user information

We collect or use the following personal information for the operation of client or customer accounts:

• Names and contact details

• Addresses

• Purchase or service history

• Account information, including registration details

• Information used for security purposes

• Marketing preferences

• Technical data, including information about browser and operating systems

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details

• Profile information

• Marketing preferences

• Purchase or account history

• Website and app user journey information

We collect or use the following personal information to comply with legal requirements:

• Name

• Contact information

• Identification documents

• Client account information

• Any other personal information required to comply with legal obligations

• Criminal offence data

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details

• Account information

• Purchase or service history

• Financial transaction information

• Correspondence

1. Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

3. Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

• To improve our website and services by understanding customer interactions with the website and services

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

• To improve our service to customers

Our lawful bases for collecting or using personal information to comply with legal requirements:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

1. Where we get personal information from

• Directly from you

• Legal bodies or professionals (such as courts or solicitors)

• Suppliers and service providers

1. How long we keep information

Data is kept for as long as the User of the Service remains a client. After termination, data is retained for two years.

2. Who we share information with

1. Data processors

Cloud storage providers

This data processor does the following activities for us: Store and manage data

Local Agents

This data processor does the following activities for us: They provide company secretarial services in various jurisdictions. As such they must therefore process data.

2. Others we may share personal information with

• Professional or legal advisors

• Organisations we’re legally obliged to share personal information with

• Suppliers and service providers

1. Sharing information outside the UK

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Various local agents outside of the UK

Category of recipient: Local Agents - legal and administrative service providers

Country the personal information is sent to: Various countries, depending on the client needs

How the transfer complies with UK data protection law: the agreement between DAO SPV and its Local Agents stipulates that Local Agents must comply with UK data protection standards.

2. How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

3. Last updated

1. 24/03/2025