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Data Protection

Privacy Statement

How Momentum Advisory collects, uses and protects personal information.

Controller
Andy Mallet, trading as Momentum Advisory
JOIC Registration
104183
Effective
17 October 2026  ·  Version 1.0
Section 01

About this statement

Momentum Advisory (“Momentum”, “we”, “us”) is a Jersey-based management consultancy serving regulated financial services businesses. Momentum Advisory is the trading name of Andy Mallet, a sole trader based in Jersey.

This statement explains what personal information we collect, why we collect it, how we look after it and the rights you have. It applies if you:

  • visit our website or download one of our free resources;
  • are a client, a prospective client, or work for one;
  • are an introducer, referral partner or professional contact;
  • take part in a meeting with us; or
  • work with us as an associate, subcontractor or supplier.

It does not cover personal information we handle on behalf of our clients while delivering an engagement. In that situation the client decides how the information is used, and the client’s own privacy notice applies. Section 8 explains how we handle that information.

Section 02

Who is responsible

Momentum is the controller of the personal information described in this statement. We comply with the Data Protection (Jersey) Law 2018 and, where they apply to the people we deal with, the UK General Data Protection Regulation and the EU General Data Protection Regulation.

We are registered with the Jersey Office of the Information Commissioner as a controller, under registration number 104183.

Andy Mallet, our Founder and Principal Consultant, is responsible for data protection at Momentum. You can contact him at info@momentumjersey.com.

Section 03

The information we collect

We collect only what we need for the purposes set out in section 4.

Who you areWhat we collectWhere it comes from
Website visitors and resource downloads
  • Name, email address, company and telephone number entered in our download or contact forms
  • Technical information such as IP address and browser type, logged by our website host for security
You, and our website host
Clients and prospective clients
  • Name, job title, employer and business contact details
  • Correspondence, meeting notes and records of our work together
  • Invoicing and payment details
You, your colleagues, introducers, and public sources such as LinkedIn and company websites
Introducers, referral partners and professional contacts
  • Name, job title, employer and business contact details
  • Notes of our conversations and introductions
You, mutual contacts and public professional sources
Meeting participantsA written transcript and notes of what is said in meetings where you agree to our AI note-taker being used (see section 6)The meeting itself
Associates, subcontractors and suppliers
  • Name and contact details
  • CV, qualifications and references
  • Contract, invoicing and payment details
You, and referees you nominate

We do not intend to collect special category information (such as health data) about our contacts, and our services are not aimed at children.

Section 04

How we use it and our lawful basis

Data protection law requires us to have a lawful basis for each use of personal information. Ours are set out below.

Why we use itLawful basis
To send you a resource you have requested and respond to your enquiriesOur legitimate interests in responding to requests made to us, and taking steps at your request before entering into a contract
To send you occasional insights, updates and invitations relevant to your professional roleOur legitimate interests in promoting our services to business contacts. You can opt out at any time using the link in our emails or by contacting us
To prepare proposals, deliver engagements and manage our relationship with clientsPerformance of our contract with the client; where you are an employee of a client, our legitimate interests in delivering that contract
To keep notes of meetings using an AI transcription toolOur legitimate interests in keeping accurate records. We ask everyone present before using it and do not use it if anyone objects
To engage and pay associates, subcontractors and suppliersPerformance of a contract
To keep accounting and tax recordsCompliance with our legal obligations
To keep our systems secure and to establish, exercise or defend legal claimsOur legitimate interests, and compliance with our legal obligations

Where we rely on legitimate interests, we have considered your interests and rights and concluded they are not overridden. You can ask us for details of that assessment.

Section 05

Our use of artificial intelligence

Momentum is an AI-native consultancy. We use a small number of approved AI tools to support research, analysis, drafting and note-taking. We govern this through our AI Acceptable Use Policy, which is available on request. In particular:

  • People stay accountable. Every piece of work we deliver is reviewed and validated by our consultant, who remains responsible for it.
  • No automated decisions about you. We do not use AI to make decisions that have legal or similarly significant effects on individuals, and we do not use it to profile people.
  • Your information is not used to train AI models. Our approved tools are configured, or contractually committed, not to use our content for model training.
  • Client personal information is protected. Personal information we handle for clients is processed only in tools covered by appropriate data processing terms.
Section 06

Meeting transcription

With your agreement, we may use an AI note-taking tool to transcribe meetings so that we can keep accurate notes. The tool we use runs on our own device and does not join the meeting as a visible participant. It does not keep an audio recording: audio is deleted once transcription is complete, and the transcript and notes are stored in Europe.

We will always ask at the start of a meeting before using it. If anyone present objects, we will not use it. Transcripts and notes are kept with the related client or prospect record and deleted in line with section 11.

Section 07

Our website and cookies

Our website does not use advertising, analytics or tracking cookies.

Our website host records technical information such as IP addresses to keep the site secure and running. When you submit a form, the details you provide are processed by our website host and, for resource downloads, the resource is sent to you by our email delivery provider.

To display our pages, your browser loads fonts from Google Fonts and some images from an external image hosting service. These providers receive your IP address when your browser requests these files.

If we introduce analytics or other non-essential cookies in future, we will update this statement and ask for your consent where required.

Section 08

When we act for our clients

During engagements we may see personal information that belongs to our clients, such as information about their staff, customers or, for some clients, other individuals connected with their business. In these cases the client is the controller and Momentum acts as its processor. We:

  • use that information only on the client’s documented instructions and for the purpose of the engagement;
  • keep it confidential and protect it with appropriate security measures;
  • do not enter it into AI tools that are not covered by appropriate data processing terms;
  • do not use it for our own purposes; and
  • return or delete it at the end of the engagement, unless the client instructs otherwise or the law requires us to keep it.

If you want to exercise your rights over that information, please contact the client organisation. If you contact us, we will pass your request to them promptly.

Section 09

Who we share it with

We never sell personal information. We share it only with the service providers we use to run our business, and only as far as they need it to provide their service.

ProviderWhat they do for usWhere data is held
MicrosoftEmail, document storage, collaboration and Microsoft 365 CopilotEuropean Union, United Kingdom and United States
AnthropicClaude AI assistant for research, analysis and draftingUnited States
Jamie (meetjamie.ai)AI meeting transcription and notesEuropean Union
NetlifyWebsite hosting and form handlingUnited States
ResendDelivery of resources requested through our websiteUnited States
RevolutBusiness banking and paymentsUnited Kingdom and European Economic Area
LinkedInProfessional networking and messagingIreland and United States

We may also share information with our professional advisers (such as lawyers, accountants and insurers), with associates working on an engagement under confidentiality obligations, and with regulators, courts or law enforcement where the law requires it.

Section 10

International transfers

Some of our providers hold information outside Jersey. Transfers to the United Kingdom and the European Economic Area are permitted because those jurisdictions are recognised as providing adequate protection. Where information is transferred elsewhere, including to the United States, we rely on an approved safeguard such as the EU–US Data Privacy Framework (and its UK Extension) or standard contractual clauses. You can ask us for details of the safeguard that applies.

Section 11

How long we keep it

InformationHow long we keep it
Client engagement records and correspondenceSix years after the engagement ends, then securely deleted
Personal information processed on behalf of clientsReturned or deleted at the end of the engagement, unless the client’s contract or the law requires otherwise
Financial and accounting recordsAs long as the law requires
Website enquiries and marketing contactsUntil you unsubscribe or ask us to delete your details. We review inactive contacts periodically. If you opt out, we keep a minimal record so that we do not contact you again
Meeting transcripts and notesWith the related client or prospect record, and deleted in line with it
Associate, subcontractor and supplier recordsSix years after the relationship ends
Section 12

How we protect it

We use appropriate technical and organisational measures to protect personal information, including multi-factor authentication on our business accounts, encrypted devices, access limited to those who need it, and the security controls of our business platforms. Associates who work with us are bound by confidentiality obligations and our data protection and AI policies.

If a personal data breach occurs that is likely to put your rights at risk, we will notify the Jersey Office of the Information Commissioner within 72 hours and tell you without undue delay where required.

Section 13

Your rights

You have the right to:

  • ask for a copy of the personal information we hold about you;
  • ask us to correct information that is inaccurate or incomplete;
  • ask us to delete your information or restrict how we use it;
  • object to our use of your information, including an absolute right to object to direct marketing;
  • ask us to transfer information you provided to another organisation;
  • withdraw consent at any time, where we rely on consent; and
  • not be subject to decisions based solely on automated processing that significantly affect you.

To exercise any of these rights, contact us at info@momentumjersey.com. We will respond within four weeks. In some circumstances the law allows us to extend this period, and we will tell you if so. We do not normally charge a fee.

Section 14

Complaints

If you have a concern about how we handle your information, please contact us first so we can try to put it right. You also have the right to complain to the Jersey Office of the Information Commissioner at jerseyoic.org. If you live in the United Kingdom or the European Union, you can complain to the Information Commissioner’s Office or your local supervisory authority.

Section 15

Changes to this statement

We review this statement at least once a year and whenever our use of personal information changes. The current version will always be available on this page.

Andy Mallet
Founder & Principal · Data Protection
Location
Jersey, Channel Islands
JOIC Registration
104183