Privacy Policy

Manalo Advisors Ltd is committed to protecting your privacy and we recognise that we have a duty of care to the people within our data set. We will never spam you, or sell, rent or otherwise distribute or make public your personal information.

We believe:

  • User privacy and data protection are human rights
  • We have a duty of care to the people within our data
  • Data is a liability, it should only be collected and processed when absolutely necessary

In this Privacy Policy (“Policy”), you can read about the information we collect from you and how we use it. If you have any questions or concerns, you can email us at

By using our website and services you consent to our collection and use of your Information as described in this Policy. If we change our Policy and/or procedures, we will update this Policy to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it. Your continued use of the website or services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of this Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.

1. Relevant Legislation

Along with Manalo Advisors Ltd’s business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:

  • UK Data Protection Act 1988 (DPA)
  • EU Data Protection Directive 1995 (DPD)
  • EU General Data Protection Regulation 2018 (GDPR)

Manalo Advisors Ltd’s website compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our Data Protection Officer for clarification.

2. Personal Information this Website Collects and Why We Collect it.

2.1 Information You Give Us

You may give us information about you by filling in forms on our site or by corresponding with us by phone, email or otherwise and we will only use that information as we specifically state when you provide that information or as set out in this Policy. If you are under 16 years of age you MUST obtain parental consent before filling in any forms on this website.

Some examples of the information that we collect and how we use it are:

  • Report Alerts:
    If you sign up for our Report Alerts, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third-party data processor (see section 7 below). We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our Report Alerts. While your email address remains within the MailChimp database, you will receive periodic (approximately 1-2 times a month) Report Alert emails from us.

    Neither we nor Mailchimp will ever sell your email address or share it with any other party, unless we are legally compelled to do so. If you contact Mailchimp directly regarding your subscription to our Report Alerts, Mailchimp may contact you directly; otherwise, Mailchimp will never contact you. Only authorised Mailchimp employees have access to our subscriber list. You are always free to unsubscribe from our Report Alerts, but as long as you are registered with Manalo Advisors Ltd we may use Mailchimp to send you information about your account.

    Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

    For more information, please see Mailchimp’s privacy notice.
  • Email and Other Contact Details:
    You may wish to contact us by sending letters, emails or by filling out the contact form on our website. We will only use this information to respond to your query or suggestion.

2.2 Information We Collect About You

We may automatically collect technical information about each of your visits to our website.

Like most websites, Manalo Advisors Ltd’s website uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you, but Google do not grant us access to this. We consider Google to be a third-party data processor (see section 6 below).

GA makes use of cookies, details of which can be found on Google’s developer guides. Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within Manalo Advisors Ltd’s website.

3. How We Store Your Personal Information

Manalo Advisors Ltd uses a third-party service called Heroku that allows us to collect data entered manually by visitors to our website who sign up for our Report Alerts. We do not keep information longer than we deem necessary. Information is stored on the website in a non-identifiable fashion and is wiped manually at the end of every month. This is currently the only occasion where personal data will be stored on this website. The email address that you submit will not be stored within any of our internal computer systems. For more information, please see Heroku’s privacy notice.

With regard to filling out the contact form on our website, we will only use the information you provide to respond to your query or suggestion. We do not keep information longer than we deem necessary.

4. Request a Copy of the Information We Hold About You

Under the Act you have the right to request a copy of the Information that we hold about you. This is known as a Subject Access Request. To process this request, we will require two pieces of identification to prove your identity. Please make a written application to the Data Protection Officer, Manalo Advisors Ltd, 19 Heathmans Road, London SW6 4TJ. We will respond within 30 days of the receipt of your request.

If any of the Information that we hold about you is incorrect and you’d like it amended, please contact the Data Protection Officer who will review your request.

Please note that:

Even if you delete Information, we may retain your Information in conformance with our data retention policy most specifically for legal and tax reasons and to honour your opt-out requests; and

We are not responsible for updating or removing your Information contained in the lists or databases of third parties who have previously been provided with Information as permitted by this Policy.

5. How We Use Cookies

When you visit this website, we use session/transient cookies - these cookies only last for the duration of your browsing session and will normally be deleted by your browser when you close it. Session cookies do not collect information from the user’s computer.

6. About this Website’s Server

This website is hosted by Heroku. Full details of Heroku’s data security can be found here. All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.

7. Our Third-Party Data Processors

We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 1. All 3 of these third parties are based in the USA and are EU-U.S. Privacy Shield compliant.

8. Data Breaches

We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

9. Data Controller

The data controller of this website is: Manalo Advisors Ltd, Company number OC403660. Registered Office: 19 Heathmans Road, London SW6 4TJ.

10. Data Protection Officer

Mr. Roderick Manalo

CEO, Manalo Advisors Ltd

Telephone: +44 (0)20 8220 9134