1. Who we are

On Data Limited (“On Data“, “we“, “us“, “our“) is a data and analytics consultancy serving the luxury hospitality sector. We are the controller responsible for the personal data described in this notice, unless we state otherwise (see section 11, where we act as a processor for our clients).

• Registered company: On Data Limited, registered in England and Wales, company number 07712807.
• Registered office: 7 Bell Yard, London, England, WC2A 2JR.
• ICO registration number: ZB023240.
• Website: https://www.on-data.com
• Privacy contact: hello@on-data.com.
• Data protection lead / DPO: Edward Miles

If you have any questions about this notice or how we handle your personal data, contact us using the details in section 14.

2. Scope of this notice

This notice explains how we collect and use personal data when you:

• visit or interact with our website;
• enquire about, or engage us for, our services;
• are a client, prospect, partner, or supplier contact;
• access, evaluate, or obtain one of our data products or listings on the Snowflake Marketplace (see section 7); or
• otherwise communicate with us.

Where we process personal data on behalf of our clients as part of a consultancy engagement (for example, guest data held in a client’s Snowflake environment), we do so as a processor under that client’s instructions and their own privacy notice governs that processing. Section 11 explains this further.

3. The personal data we collect

Depending on how you interact with us, we may collect the following categories of personal data.

Website visitors and enquirers

• Identity and contact details you provide (name, email, telephone, company, job title).
• The content of enquiries, messages, or form submissions.
• Technical and usage data collected automatically (IP address, device and browser type, pages viewed, referring pages) via cookies and similar technologies — see section 5.

Clients, prospects, partners, and suppliers

• Business contact details and role information.
• Records of our dealings, correspondence, meetings, proposals, and contracts.
• Information held in our CRM and outreach tools to manage relationships and business development.

Snowflake Marketplace consumers (see section 7 for the full detail)

• Contact information from your Snowflake user profile, general account details, trial status, and transaction and usage data that Snowflake discloses to us when you access, evaluate, or obtain one of our listings.

Marketing recipients

• Contact details and preferences, and engagement data (e.g. whether you opened or clicked a communication).

We do not seek to collect special category data through our website. Please do not send us sensitive personal data unless we have specifically requested it for a defined purpose.

4. How we collect personal data

• Directly from you — when you contact us, submit a form, request information, or engage our services.
• Automatically — through cookies and similar technologies when you use our website (section 5).
• From third parties — including the Snowflake Marketplace (section 7), professional networks such as LinkedIn, publicly available sources, business-data providers, and referrals.

5. Cookies and analytics

Our website uses cookies and similar technologies to function, to remember your preferences, and to understand how the site is used.

• Strictly necessary cookies are used to operate the site and do not require consent.
• Analytics and other non-essential cookies are used only with your consent, which you give via our cookie banner and can withdraw at any time.

We use Google Analytics to measure site usage.

For details of the specific cookies we set and their duration, see our. You can also control cookies through your browser settings.

6. Why we use your personal data, and our lawful bases

We only use your personal data where the law allows. Our purposes and corresponding lawful bases under UK GDPR are:

Where we rely on legitimate interests, we have assessed that our interests are not overridden by your interests or rights. You can ask us for more information about that assessment.

7. Snowflake Marketplace consumers

We make data products and related listings available on the Snowflake Marketplace. When you access, request a trial of, or obtain one of our listings, Snowflake discloses certain personal data to us as the provider, which may include:

• the contact information in your Snowflake user profile;
• general account details and your status as a trial or paid customer; and
• details of the transaction, including listing usage data that identifies you or your organisation.

How we use this data. We use it to fulfil and support the listing, to respond to your requests within the timeframes required by Snowflake’s policies, to administer billing and transactions, to provide product updates and support, and — where permitted — to tell you about our own related products.

Marketing. Consistent with the Snowflake Provider and Consumer Terms and Policies, where we use personal data supplied to us by Snowflake for marketing, we will: limit those communications to our own products and services; act in accordance with this privacy notice; obtain any consents required; and honour your right to opt out at any time (see section 9).

Personal data within our data products. Where any of our data products contain personal data, we confirm we are legally authorised to share it, hold any required consents, and comply with the applicable Snowflake terms. We do not include actual or synthetic personal data within listing information itself, and we do not disclose sensitive personal data through products offered publicly via the Marketplace. Where we share anonymised or aggregated data, we structure it so that it remains anonymous, including when combined with other information.

Snowflake processes your data in accordance with Snowflake’s own privacy notice (https://www.snowflake.com/privacy-policy/). On Data is not responsible for Snowflake’s processing.

8. Who we share your personal data with

We share personal data only where necessary, with:

• Service providers (processors) acting on our instructions — for example Microsoft 365, Google Workspace, Attio
• Snowflake, in connection with Marketplace listings and transactions (section 7).
• Professional advisers (legal, accounting, insurance) where needed.
• Authorities or third parties where required by law, or to establish, exercise, or defend legal claims.
• A buyer or successor in the event of a sale, reorganisation, or transfer of our business.

We require our processors to act only on our instructions and to keep personal data secure under a written contract that meets UK GDPR requirements. We do not sell your personal data.

9. Marketing and your choices

We will only send you marketing where we are permitted to do so. You can opt out of marketing at any time by using the unsubscribe link in any message or by contacting us at hello@on-data.com. Opting out of marketing does not affect communications we send to manage an existing engagement or transaction.

10. International transfers

Some of our service providers — including Snowflake — operate outside the UK. Where we transfer personal data outside the UK, we ensure an appropriate safeguard is in place, such as a UK adequacy regulation, the UK International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses, together with any additional measures required. You can request details of the safeguards we use by contacting us.

11. When we act as a processor for clients

When we deliver consultancy and analytics services, we often process personal data on behalf of our clients — for example, guest or customer data held within a client’s own systems and platforms. In those cases:

• the client is the controller and determines the purposes and means of processing;
• On Data acts as a processor, processing that data only on the client’s documented instructions under a written data processing agreement; and
• the client’s own privacy notice governs how that data is used and how individuals can exercise their rights.

If you are a guest or customer of one of our clients and have a query about your data, please contact that organisation directly. We will support our client in responding.

12. How long we keep personal data

We keep personal data only for as long as necessary for the purposes set out in this notice, including to meet legal, accounting, tax, or reporting requirements, and to resolve disputes. In general:

• enquiry and prospect data is retained for  24 months  from last contact, unless you become a client;
• client and contract records are retained for the duration of the engagement and for 7 years afterwards to meet legal and tax obligations; and
• marketing data is retained until you opt out or until it is no longer current.

When no longer needed, personal data is securely deleted or anonymised.

13. How we keep personal data secure

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse, including access controls, encryption in transit, supplier due diligence, and staff training. Where we hold personal data within third-party platforms, we rely in part on those providers’ own security controls and certifications.

14. Your rights

Under UK data protection law you have the right to:

• be informed about how we use your data;
• request access to your data;
• request correction of inaccurate data;
• request erasure of your data in certain circumstances;
• restrict or object to certain processing, including direct marketing;
• request portability of data you provided to us; and
• withdraw consent at any time, where we rely on consent.

To exercise any of these rights, contact us at hello@on-data.com or:

On Data Limited 7 Bell Yard, London, England, WC2A 2JR

We will respond within one month. There is normally no charge.

If you are unhappy with how we have handled your data, you can complain to the UK Information Commissioner’s Office (ICO) at ico.org.uk, by calling 0303 123 1113, or by writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. We would, however, appreciate the chance to address your concerns first.

15. Changes to this notice

We may update this notice from time to time. The “Last updated” date at the top shows when it was last revised. Where changes are significant, we will take reasonable steps to bring them to your attention.

On Data Limited is registered in England and Wales (company number 07712807). Registered office: 7 Bell Yard, London, England, WC2A 2JR.